1
APRIL 1972

Re: 3MGS- IS - DC -I

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U. S. Naval Research Laboratory
i- Raw Sewage
'• Pumping Station
Primary
ischarge Point
Sludi
EXISTING WATER POLLUTION CONTROL
FACILITIES, DISTRICT OF COLUMBIA

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DRAFT 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
April, 1972
Regional Administrator

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SUMMARY SHEET
District of Columbia Water Pollution Control Plant
(Expansion and Upgrading)
(X) Draft	( ) Final Environmental Impact Statement
ENVIRONMENTAL PROTECTION AGENCY
REGION III
Philadelphia, Pennsylvania
1.	Type of action: (X) Administrative	( ) Legislative
2.	Description of action: The proposal would expand from 240 mgd to
309 mgd and upgrade (from secondary to tertiary treatment) the
existing District of Columbia Water Pollution Control Facilities.
Outside 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.
3a. Beneficial Environmental Impacts:
(1)	Significant water quality effects on downstream reaches
of the Potomac Estuary.
(2)	Long-term enhancement of Dyke Marsh once the restoration
project is completed by 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.
3b. Adverse Environmental Effects:
(1)	Negligible 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 generation, aesthetic intrusion, and land use
changes.
i

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(4) Short-term effects daring construction activities include:
(a)	Increased turbidities during dredging and spoiling
operations.
(b)	Fugitive dust emissions.
(c)	Erosion and siltation caused by disturbed areas
at the site.
(d)	Increased noise levels.
(e)	Inconvenience to the surrounding communities.
4. 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
ii

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5. Review and Comment requests.
Comments have been solicited from Federal, State and local agencies,
private organizations, and individuals. A complete distribution list
is attached for ready-reference.
6. Date draft statement made available to CEQ and public: April 20, 1972
iii

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LIST OF FEDERAL, STATE AND LOCAL AGENCIES,
PRIVATE ORGANIZATIONS AND INDIVIDUALS
Blue Plains Sewage Treatment Plant, District of Columbia
FEDERAL
Mr. Philip Handler
President
National Academy of Sciences
2101 Consituttion Avenue, N. W.
Washington, D. C. 20418	(2)
D. B. Charter, Jr.
Commander
U. S. Coast Guard
Chief, Environmental
Coordination Branch
400 Seventh Street, S. W.
Washington, D. C. 20591	(2)
Office of Communications
U. S. Department of the Interior
Room 7214
Washington, D. C. 20240	(2)
Mr. Mark Abelson
Regional Coordinator, Northeast Region
U. S. Department of the Interior
J. F. K. Federal Building
Room 2003 J & K
Boston, Massachusetts 02203	(2)
Director
Bureau of Sport Fisheries & Wildlife
U. S. Department of the Interior
Washington, D. C. 20240	(2)
Director
National Park Service
U. S. Department of the Interior
Washington, D. C. 20240	(2)
Director
Geological Survey
U. S. Department of the Interior
Washington, D. C. 20240	(2)
Director
National Marine Fisheries Service
U. S. Department of Commerce
Washington, D. C. 20240	(2)
Richard H. Broun
Director, Environmental & Land-Use
Planning Division
Department of Housing and Urban
Development
Washington, D. C. 20410	(2)
Assistant Secretary for Programs
ATTN: Director, Office of Environmental
Project Review
Department of the Interior
Washington, D. C. 20240
(2)
Mr. Theodore R. Robb
Regional Administrator
Department of Housing and Urban
Development
Curtis Building
6th & Walnut Streets
Philadelphia, Pennsylvania 19106	(2)
Dr. T. C. Byerly
Office of the Secretary
U. S. Department of Agriculture
Washington, D. C. 20250	(2)
Dr. Sidney Galle^
Deputy Assistant Secretary
for Environmental Affairs
U. S. Department of Commerce
Washington, D. C. 20235	^
Colonel Louis W. Prentiss, Jr.
District Engineer
Baltimore District
Corps of Engineers
P. 0. Box 1715
Baltimore, Maryland 21203
Russell E. Train, Chairman
Council on Environmental Quality
722 Jackson Place, N. W.
Washington, D. C. 20006	(10)
iv

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FEDERAL (CONT'D)
George A. Cunney, Jr.
Acting Chief, Environmental Office
Directorate of Installations
Office of the Deputy Chief of Staff
for Logistics
Department of the Army
Washington, D. C. 20310	& (2)
Mr. Edward Jon Guss
Coordinator
Department of Health, Education &
Welfare
401 North Broad Street
Philadelphia, Pennsylvania 19108	(2)
Frederick H. Warren
Advisor on Environmental Quality
Federal Power Commission
441 "G" Street, N. W.
Washington, D. C. 20230	(2)
Mr. August Schofer
Regional Administrator
Region 3
Federal Housing Administration
U. S. Department of Transportation
Room 1633
George H. Fallon Federal Office Bldg. (2)
31 Hopkins Plaza
Baltimore, Maryland 21201
U. S. Forest Service
Northeastern Area
Department of Agriculture
6816 Market Street
Upper Darby, Pennsylvania 19082	(2)
Martin Convisser
Director, Office of Program Co-Ordination
U. S. Department of Transportation
400 7th Street, S. W.
Washington, D. C. 20591	(2)
Rod Kreger
Deputy Administrator
General Services Administration -AD
Washington, D. C. 20405	(2)
W. Don Maughan
Director of U. S. Water Resources Council
2120 L Street, N. W.
8th Floor
Washington, D. C. 20037	(2)
Director
Naval Research Laboratory
Washington, D. C. 20390	(2)
S. N. Carvos
Director, Utilities Division
Department of the Navy
Chesapeake Division
Naval Facilities Engineering Command
Building 57
Washington Navy Yard
Washington, D. C. 20390	(2)
STATE AND LOCAL AGENCIES
Mr. Howard E. Chaney, Director
Environmental Health Services
Maryland Department of Health & Mental
Hygiene
610 North Howard Street
Baltimore, Maryland 21401	(2)
Noman M. Cole, Jr.
Chairman
Virginia State Water Control Board
5917 River Drive
Lorton, Virginia 22079	(2)
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STATE AND LOCAL AGENCIES (CONT'D)
Mr. Thomas D.McKewen, Director
Maryland Environmental Services
State Office Building
Annapolis, Maryland 21401	(2)
Mr. A. H. Paessler
Executive Secretary
State Water Control Board
P. 0. Box 1143
Richmond, Virginia 23230	(2)
Mr. Samuel W. Shafer
Engineer - Director
Alexandria Sanitation Authority
835 S. Payne Street
Alexandria, Virginia 22314	(2)
Mr. Bert W. Johnson, County Manager
Arlington County
1400 N. Court House Road
Arlington, Virginia 22201	(2)
Mr. Robert J. McLeod
General Manager & Chief Engineer
Washington Suburban Sanitary Commission
4017 Hamilton Street
Hyattsville, Maryland 20781	(2)
Mr. C. Richard Foote, City Manager
City of Rockville
1115 Perry Street
Rockville, Maryland 20850	(2)
Mr. George J. Kelley, Jr.
County Executive
County of Fairfax
4100 Chain Bridge Road
Fairfax, Virginia 22030	(2)
vi

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State Clearinghouses
D.C. Mr. Elmer S. Coppie
Special Assistant to the Mayor
Office of Budget and Program Analysis
District Building
14th & E Streets, N. W.
Washington, D. C. 20004	(10)
i Md. Mr. Edwin L. Powell, Jr.
Chief, State Clearinghouse
Maryland Departmentof State Planning
301 West Preston Street
Baltimore, Maryland 21201	(10)
Va. Mr. Charles Burbach
A-95 Information Officer
Virginia Division of State Planning
and Community Affairs
1010 James Madison Building
109 Governor Street
Richmond, Virginia 23219	(io)
Regional Clearinghouses
Va. Mr. John W. Epling
Executive Director
Northern Virginia Planning District
Commission
7309 Arlington Boulevard
Suite 300
Leohmann's PIaza
Falls Church, Virginia 22042	(10)
D.C. Mr. Walter A. Scheiber
Executive Director
Metropolitan Washington Council
for Governments
Metropolitan Clearinghouse for D. C.
1225 Connecticut Avenue, N. W.
Suite 201
Washington, D. C. 20036	(30)
State & Local
Mr. James P. Alexander, Director
District of Columbia Department of
Environmental Services
Presidential Building
415-12th Street, N. W.
Washington, D. C. 20004	(10)
Interstate Commission on the Potomac
River Basin
1025 Vermont Avenue, N. W.
Suite 27
Washington, D. C. 20005	(2)
National Capitol Planning Commission
1325 "G" Street, N. W.
Washington, D. C. 20005	(10)
Private Organizations and Individuals
Mr. David Sanders Clark
Chairman
Committee of 100 on the Federal City
1307 New Hampshire Avenue
Washington, D. C. 20036	(1)
Mrs. John A. Bross
Committee of 100 on the Federal City
4501 Crest Lane
McLean, Virginia 22101	(iy
VI i

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News Media
Washington Daily News Co.
1013 13th Street, N. W.
Washington, D. C. 20005
Washington Post Co.
1515 L Street, N. W.
Washington, D. C. 20005
The Evening Star Newspaper Co.
225 Virginia Avenue, S. E.
Washington, D. C. 20003
Northern Virginia Sun
3409 Wilson Boulevard
Arlington, Virginia 22210
Private Organizations and Individuals
Mr. William Shands
Central Atlantic Environmental Service
1717 Massachusetts Avenue, N. W.
Washington, D. C. 20036	(1)
Citizens Council for a Clean Potomac
P. 0. Box 1972
Wheaton Station
Silver Spring, Maryland 20902	(1)
Northern Virginia Conservation Council
c/o Elizabeth Hartwell, Secretary
7968 Boiling Drive
Alexandria, Virginia 22308	(1)
Environmental Defense Fund
1712 "N" Street, N. W.
Washington, D. C. 20036	(2)
Prazier Kellogg
Cabin John Citizens' Association
7725 Tomlinson Avenue
Cabin John, Maryland 20731	(1)
National Wildlife Federation
1412 16th Street, N. W.
Washington, D. C. 20036	(2)
Mr. Jonas Morriss
Special Representative
Citizens' Permanent Conference on the
Potomac River Basin
206 Georgetown Building
2233 Wisconsin Avenue, N. W.
Washington, D. C. 20007	(1)
Mr. Arthur W. Sherwood
Chesapeake Bay Foundation
P. 0. Box 209
17 State Circle	(1)
Annapolis, Maryland 21404
Mr. John S. Winder, Executive Director
Metropolitan Washington Coalition for
Clean Air, Inc.
1714 Massachusetts Avenue, N. W.
Washington, D. C. 20036	(2)
Northern Virginia Conservation Council
c/o Marian K. Agnew, Chairman
Box 304
Annandale, Virginia 22003	(1)
League of Women's Voters of the U. S.
1200 17th Street, N. W.
Washington, D. C. 20036	(2)
Accokeek Foundation, Inc.
525 School Street, S. W.
Washington, D. C. 20024	(l)
Chesapeake Bay Foundation
P. O. Box 209
Annapolis, Maryland 21404	(1)
Mr, Orris Herfindahl
Member, Conservation Committee
Association
(Canoe Cruisers)
Canoe Cruisers Association
902 Madison Lane	(1)
Falls Church, Virginia 22046
viii

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TABLE OF CONTENTS
District of Columbia Water Pollution Control Plant Upgrading and Expansion
Section	Description	Page
I	Introduction	1-14
II	Description of the Proposed Action	15-31
III	Environmental Impact of the Proposed Action	32-49
IV	Adverse Impacts Which Cannot be Avoided	50-51
Should the Proposal be Implemented
V	Alternatives to the Proposed Action	52-111
VI	Relationship Between Local Short-Term Uses	112-113
of Man's Environment and the Maintenance and
Enhancement of Long-Term Productivity
VII	Irreversible and Irretrievable Commitments	114-115
of Resources Which Would be Involved in the
Proposed Action Should it be Implemented
VII	Problems and Objections	116-118

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TABLE OF CONTENTS (CONT'D)
Appendices Description	Pages
A	Dredging and Spoil Disposal	A1-A23
B	Unit Processes	Bl-BlO
C	Sludge Incineration	C1-C40
D	Spray Irrigation	Dl-Dll
Dl'-D41
Summary and Conslusions of Technical	E1-E20
Report #35, Water Resources - Water
Supply Study of the Potomac Estuary
Prior District of Columbia Sewerage	F1-F15
Systems and Existing Water Pollution
Control Facilities
Pertinent Contracts Concerning Waste-	G1-G7 6
water Treatment in the Metropolitan
Washington Area
H	Recommendations to Speed Action on	H1-H8
Potomac Cleanup - Prepared by
Vincent W„ Bacon, Professor of
Civil Engineering, the University of
Wisconsin - Milwaukee
I
Environmental Statement and Supplements,
Prepared by the District of Columbia
Department of Environmental Services
11-126

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TABLE OF CONTENTS (CONT'D)
Appendices	Description
J	Temporary Environmental Controls
Required of District of Columbia
Contractors
K	Conditions for Temporary Use of Land
as Contractor's Storage Area, Prepared
by the National Park Service
L	Proposed Pollution Prevention
Regulations for Vessel and Oil
Transfer Facilities, U. S. Coast Guard,
Department of Transportation
M	Pertinent Correspondence
Pages
J1-J4
K1-K2
Ll-Ll3
Ml-Ml21

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Draft
Environmental Impact Statement
(P. L. 91-190)
District of Columbia Water Pollution Control Plant
(Expansion and Upgrading)
INTRODUCTION
A. General Background
The primary cause of pollution in the upper Potomac Estuary
is municipal wastewater discharges. This includes raw
sewage released 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 as Appendix (F ). The amount
of water used for industrial processes is insignificant.
Industrial use consists primarily of cooling water.
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
treatment 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 exhaust 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.

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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 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 265
million gallons per day (mgd) is as follows-.
Washington Suburban Sanitary Commission	119 mgd
(Prince Georges and Montgomery Counties, Md.)
District of Columbia	135 mgd
Potomac Interceptor	5 mgd
Pimmit Run Interceptor	6 mgd
(Fairfax County, Va.)
The Potomac Rivei> 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
Potomac River will be referred to as the Potomac Estuary.
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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
management 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 standards
consist of (1) planned water uses; (2) quality criteria designed
to protect those uses; and (3) a plan for implementation 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 1975 in
limited zones of the Potomac River and Rock Creek.
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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
Commission on the Potomac River Basin; and the Department of the
Interior - Federal Water Quality Administration.
The Conference resulted in the issuance of 15 recommendations
to enhance water quality of the Potomac Estuary. The most
significant recommendation was the one calling for construction
of advanced 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
Potomac River mud flats for plant expansion to 419 mgd, the
expected flow for the year 2000. However, subsequent Department
of the Interior opposition to the reclamation proposal made
approval by the Federal Government unlikely. As a result, it
was necessary to abandon plans for full expansion of the plant
to 419 mgd.
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In recognition of this impasse, the conferees reached a compromise
set forth in a "Memorandum of Understanding" completed on October 7,
1970 (see Appendix G). The Memorandum called for the
development of the Blue Plains site to provide advanced waste
treatment for 309 mgd by the end of 1977. Thus the size of Blue
Plains was limited by physical constraints rather than by the
normal procedures of designing for a population 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
completion 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.
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Existing 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 support the Potomac Enforcement
Conference. A synopsis of T. R. 35 is enclosed as Appendix (E ).
The unedited document, which has been used to prepare the water
quality aspect of this report, is available at the Region III
Office of the Environmental Protection Agency.
For purposes of Conference discussion and investigation, the
Potomac Estuary was divided into three reaches (1) upper reach -
Chain Bridge to Indian Head; (2) middle reach - Indian Head to
U. S. Route 301 Bridge; and (3) lower reach - U. S. Route 301
Bridge to Chesapeake Bay.

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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 waste-
water 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.
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For the study purposes, it was assumed that increased waste-
water volumes would be treated at three proposed locations:
Uppsr Potomac, Anacostia, and the existing Piscataway
locations. 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 were made using the Dynamic Estuary
Model developed by Federal Water Quality Administration personnel
and future wastewater 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 supply diversion. 300 cfs
Dissolved Oxygen (DO) in the
treated effluent.	6 milligrams per liter (mg/1)
Dissolved Oxygen standard for
receiving water, average	5 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 Budget's (0MB) A-95 review procedures in the
Metropolitan Area.
8

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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 estuary after water
supply diversion.	300 cfs
Average maximum phosphorus
in upper reach from Chain
Bridge, Washington, D.C. to
Indian Head, Md.	0.067 mg/1
Average maximum phosphorus
below Indian Head, Md. for
algal control.	0.03 mg/1
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 mg/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
9

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To facilitate the determination of wastewater loadings and
water supply requirements for the Metropolitan Area,
population 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 to'
existing treatment facilities, future wastewater trends were
developed for the 13 service areas 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 mgd, it is evident that
provisions will have to be made for additional capacity at
another location. The need for another regional facility has been
recognized in the "Memorandum of Understanding." The actual
location of this proposed regional plant has not been established
to date.
* 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.
10

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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 District 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 is 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 in critical stream segments
during low flow periods. This design flow is used throughout
the report and all discussions 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 Washington Metropolitan Are are
11

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listed below:
Year
Water Demand
rogd (yearly average)
1969
1980
2000
2020
370
556
1,009
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 water supply
requirements in 1980 is almost equal to the critical low flow.
Additional provisions for water supply must 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.
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.
12

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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 assured. 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 Understanding"
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
sustaining further urbanization. This development will require
additional regional facilities which will be substantially
distant to Blue Plains.
13

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As noted earlier, population projections used in the Water
Resource - 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 investment
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, HGS
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
1980
2000
2020
2,800,000
4,000,000
6,700,000
9,300,000
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II 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,
Nitrification 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 average flow of 309 mgd. The units will be designed hydraulically
to handle flows up to a rate of 650 mgd. In addition, flows between
650 mgd and 939 mgd will receive grit removal, primary sedimentation and
chlorination in the excess flow facilities before being discharged
directly to the Potomac through the existing plant outfall. The excess
flow facilities are designed to partially treat flows emanating during
rainstorms from combined sewers in the District. These facilities are
expected to be used approximately 400 hours per year. Flows in excess
of 939 mgd will either be stored within the sewer system or will be
bypassed to the Potomac and Anacostia Rivers at various upstream points.
Bypassing would be expected approximately 240 hours per year during
more intense storms.
15

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PROPOSED EXPANSION AND UPGRADING OF
EXISTING WASTEWATER TREATMENT FACILITIES

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Design flows are normally expressed in terms of daily quantities,
i.e., 309 mgd. Actual designs of Sewage Treatment Plants are based on
the maximum 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 other units, such as cubic feet per second (cfs) or gallons per
minute (gpm).
The following flow rates are equivalent:
Average Daily Flow	309 mgd	480 cfs 214,000 gpm
Peak Flow to Complete 650 mgd	1,000 cfs 450,000 gpm
Treatment
Excess Flow	289 mgd	450 cfs 200,000 gpm
Total Flow	939 mgd	1,460 cfs 650,000 gpm
It may be interesting to note that a flow of 309 mgd would take
approximately 3.8 seconds to fill an average sized living room (121 x 18" x 8V).
The facilities are being constructed with the aid of EPA grant funds
under several projects. Federal grants will total approximately $200.0
Million at 55% of the estimated cost of $364 Million. In addition to the
EPA contribution, the District of Columbia will contribute $82.2 Million,
WSSC $4.4 Million, the State of Maryland $43.0 Million, Fairfax County,
Virginia $1.9 Million, and the Commonwealth of Virginia $2.3 Million.
The D. C., Maryland and Virginia shares of the costs are allocated on the
basis of capacity assigned in the "Memorandum of Understanding" (Appendix G).
Under Section 8 of the FWPC Act, if the Federal grant is to equal
55% the State must contribute 25% of the eligible cost of a project.
Since the District can recover its capital investment for facilities to
handle the flows from the Potomac Interceptor under existing agreements.
17

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these flows have been included as part of the District allocation of
153 mgd. Since the plant will provide treatment for wastes emanating
from two States and the District of Columbia, the costs of Federal grant
projects have been divided among the various State allocations. The
various projects and their status are as follows:
1. Raw Sewage Pumping and Conduits
Project No. Eligible Cost Grant Amt. Date of	Grant
	 		Grant Offer Paid
WPC-DC-20	$4,679,000 $1,854,440* 12/28/66 $1,854,440
* Eligible for an additional $485,060 under the reimbursable provisions
of the FWPC Act.
Status: Construction Complete.
The project consisted of the construction of miscellaneous conduits
and raw sewage pumping facilities to bring the pimping capacity to 939 mgd
plus spares.
Construction of the Pump Station commenced in November, 1967 and
completed in September, 1970. Construction of the conduits began in
July, 1957 and completed in January, 1969,
Final inspection of these facilities by EPA has not been made,
since they will not be operated until the primary treatment facilities
being constructed under project WPC-DC-22, etc. (see below) are completed.
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2. Primary Treatment Facilities
Project No. Eligible Cost
WPC-DC-22
WPC-Md-283
WPC-Va-351
$9,427,700
9,121,100
493,200
Grant Amt.
$5,185,230
2,750,000*
271,260
Date of	Grant
Grant Offer	Payments
10/27/70	$2,660,600
11/ 6/70	1,403,800
5/18/71	139,100
* Eligible for $2,266,600 under reimbursable provisions of FWPC Act.
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 construction contract
for the primary sedimentation basins and grit removal facilities was
awarded on May 6, 1971 and was approximately 57% complete on March 30, 1972.
It is anticipated that these facilities will be completed by November, 1972.
The construction contract for additional sludge dewatering facilities was
awarded on April 13, 1971 and this work was 99% complete on March 30, 1972.
Plans and specifications for the chlorination facilities have not been
submitted to EPA for review.
3. Solids Handling Facilities
Project No. Eligible Cost Grant Anrt.
WPC-DC-23 $13,828,100
WPC-Md-296 13,378,500
WPC-Va-352	723,400
Status: Under Construction
$7,605,450
7,358,170
397,870
Date of
Grant Offer
5/20/71
5/20/71
5/20/71
Grant
Payments
-	0 -
-	0 -
-	0 -
19

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The approved project consists of the construction of eight flotation
thickening tanks, four sludge blending tanks, twenty vacuum filters, six
multiple hearth incinerators and miscellaneous appurtenances within a
solids processing building. The District has requested that the scope
of the project be revised to include ten additional flotation thickening
tanks, ten additional vacuum filters and two additional multiple hearth
incinerators at an estimated cost of $11,618,000 which will be prorated
as follows:
Locality	Estimated Cost	Federal Grant
District of Columbia $5,752,600	$3,163,930
W.S.S.C.	5,564,600	3,060,530
Fairfax County	300,800	165,440
The contract ($2,494,000) for construction of the foundations of
the Solids Processing Building was awarded on September 29, 1971 and
is approximately 46% complete. Plans and specifications for the remainder
of the building and equipment within it are being prepared by the
consulting engineer. The entire facility is scheduled for completion in
April, 1974, eights months before completion of the AWT facility.
4. Secondary Treatment Units
Project No. Eligible Cost Grant Amt, Date of	Grant
	 Grant Offer Payments
WPC-DC-24 $22,095,900 $8,845,700* 9/28/71	- 0 -
WPC-Md-299 21,373,800 7,984,023** 10/ 7/71	- 0 -
WPC-Va-354	1,155,300	667,860 10/ 7/71	- 0 -
* - Eligible to receive an additional $3,307,040
** - Eligible to receive an additional $3,771,567
Status: Under Construction
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The project consists of the construction of two aeration basins,
twelve secondary sedimentation basins, additional aeration facilities,
an operations center for secondary treatment units, chemical feed
facilities and miscellaneous plant modifications and appartenances
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 was 12% complete on March 30, 1972.
Plans and specifications for modifications to the existing aeration
basins have been approved by EPA.
The construction plans for the remaining facilities have
been submitted to EPA for review. These facilities will provide
approximately 90% BOD and initial phosphorus removal and are scheduled
for completion in June, 1974.
5. Excavation, Dredging, Dock and Concrete Plant
Project No. Eligible Cost Grant Amt. Date of	Grant
	, 	 	 Grant Offer Payments
WPC-DC-26 $23,222,300 $12,772,260 7/28/71	- 0 -
WPC-Md-297 22,463,400 12,354,870 8/24/71	- 0 -
WPC-Va-353	1,214,300	667,860 9/ 9/71	- 0 -
Status: Under Construction
The approved project consists of dredging and construction of
docking facilities, a concrete batch plant located on the dock and mass
plant excavation to serve initially as an expedient to construction of
major plant components included in other projects. The District has
requested that the scope of the project be expanded to include an increase
in the capacity of the plant's electrical system and the construction of
additional parking facilities for use by contractors' employees.
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The dredging and dock construction contract for the amount of
$4,376,175 was awarded on December 14, 1971 and was approximately 21%
complete on March 30, 1972. The $14,268,468 excavation contract was
awarded on February 24, 1972 and was approximately 4% complete on
March 30, 1972.
Plans and specifications for the concrete batch plant have been
tentatively approved by EPA. The specifications for electrical system
modifications are currently under review in the Regional Office.
6. Nitrogen Removal Facilities
Project No. Eligible Cost Grant Amt.* Date of
Grant Offer
WPC-DC-27 $62,656,200 $34,460,910 Not made
WPC-Md	60,608,600 33,334,730 Not made
tfPC-Va-358 3,276,200 1,801,910 Not made
* - Anticipated
Status: Application being reviewed.
The project consists of construction of twenty-four nitrification
reactors, twenty-eight nitrification sedimentation basins, twelve
denitrification reactors, twelve nitrogen release tanks, twenty-eight
denitrification sedimentation tanks plus various chemical feed facilities,
aeration facilities and miscellaneous appurtenances to provide nitrogen
and final stage phosphorus removal.
The facilities included in this project are currently being designed.
No plans and specifications have been submitted to EPA for review.
22

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7.	Multimedia Filters
Project No. Eligible Cost Grant Amt.* Date of
	 	 Grant Offer
WPC-DC-28 $23,740,300 $13,057,160 Not made
WPC-Md-	22,964,400 12,630,420 Not made
WPC-Va-358 1,241,303	682,710 Not made
* - Anticipated
Status: Applications being reviewed.
The project consists of the construction of a pumping facility,
thirty-two multi'-media filters with chlorine contact channels and
related appartenances to enhance removal of biological and nutrient
constitutents and to disinfect the plant effluent.
No plans and specifications for facilities included in this project
have been submitted to the Regional Office for review. These facilities,
along with the nitrogen removal features are the final major treatment
units in the system and are scheduled for completion in December, 1974.
8.	Miscellaneous Cleanup
A final project may be provided to cover cleanup operations
and other minor facilities not included in previous projects. If necessary,
its maximum eligible cost may approach $34,698,000 with an EPA grant of up
to $19,083,900.
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 675 employees will be required
to properly operate and maintain the facilities.

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The existing facilities are operated by a staff of approximately
250 people. The average operation and maintenance cost for the past
two 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. Of this amount
129.5 tons will be produced by the AWT facility. The tonnages mentioned
are 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 230 tons of alum or 118 tons of ferric
chloride or a combination of these.
Nitrogen removal - Approximately 86 tons of methanol, 58 tons of
lime and 2.4 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), the District is providing facilities which should
reduce the BOD discharged to the Potomac to 100,000 lbs per day by
May 15, 1972. Facilities to provide metal salt (alum or ferric chloride)
addition to the existing secondary treatment units are under consideration.
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TABLE 1

PROJECTED RESIDUAL
POLLUTANTS FROM
DCWPC PLANT AFTER
VARIOUS STEPS IN
THE PROCESS

CHARACTERISTICS
AFTER
SECONDARY
SEDIMENTATION
mfi/1
AFTER
NITRIFICATION
SEDIMENTATION
mg/1
AFTER
DENITRIFICATION
SEDIMENTATION
me/1
FINAL
EFFLUENT
mg/1
TOTAL LOADING
TO POTOMAC AT
309 mgd
lbs
STANDAR]
lbs
BOD, 5 Day
20
10
6
3
7736.
12,700
Phosphorus, Total
2
2
0.5
0.2
516.
560
Nitrogen, Org
4
3
2.5
1.5
3868.
-
nh3
14
0.1
0.1
0.1
258.
-
no2 + no3
0
14.5
0.5
0.5
1289.
-
Total Nitrogen
18
17.6
3.1
2.1
5415.
6,±30
* As Recommended by the Potomac Enforcement Conference

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Sludge produced during the construction period will be disposed of
by Maryland Environmental Services on state owned lands. It is
anticipated that minor quantities of the sludge will be trucked to the
Agricultural Research Center at Beltsville where it will be used in a
research project to determine the effects of land disposal by the use
of deep trenches.
Other Projects Affected by the Plant Expansion and Upgrading
1. District of Columbia
a.	WPC-DC-12; POTOMAC FORCE MAIN from the Potomac Pumping Station
at Theodore Roosevelt Bridge to Boiling AFB. The total eligible cost
is $5,593,700 and the approved grant $600,000. Construction is nearing
completion and the facilities are expected to be operable in the Spring
of 1972. This is the last section necessary for full operation of the
Potomac Pumping Station.
b.	WPC-DC-18; 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 with the exception of approximately 800
feet of the section.
The current construction consists of a 96-inch diameter sewer segment
in the "Georgetown Gap," a 3000-foot missing link in the Potomac
Interceptor Sewer System. An annual average of approximately 6 mgd of
untreated sewage is bypassed to the Potomac River in this area. The
overflow is caused by a restriction in the downstream sewer system capacity
where the Rock Creek sewer system discharges into the Potomac system.

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This condition causes a backup in the Rock Creek sewer and the
overflows come from there. Flows from the Upper Potomac Interceptor (UPI)
are pumped into the overloaded sewer thereby aggravating the situation.
Flows which would be conveyed by the proposed UPIR are connected
to the existing UPI of much smaller diameter (48") which was previously
operating near its design capacity. The additional flows further
aggravate the situation by surcharging the UPI, causing some overflows
from manholes in the area. The situation will be alleviated when the
Potomac Pumping Station is fully operational and flows from the overloaded
sewers are diverted through this facility. Upon completion of the UPIR,
flows from the Potomac Interceptor will be conveyed directly to the
Potomac Pumping Station. Excess flows from the UPI can also be diverted
to the UPIR, thus eliminating the current overflow problem.
c. WPC-DC-19? POTOMAC OUTFALL SEWER from Boiling AFB to the Blue
Plains site. The current grant of $758,740 was initially approved
December 23, 1965, for a project having a current estimated eligible
cost of $3,508,000. Construction is complete but the facilities will
not be operable until project WPC-DC-12 is completed.
27

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d. WPC-DC-25; PORTLAM) 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 $4,556,400.
Construction of this project under "Project C" will allow facilities in
the northeast part of Washington to be utilized to their full capacity.
The project is not under construction. Washington Suburban Sanitary
Commission's share of the cost is included in the project WPC-Md-304.
2. Maryland - Active Projects
a.	WPC-Md-170; WSSC (MUDDY BRANCH - ROCK RUN INTERCEPTING SEWERS)
The project consists of approximately 58,600 lineal feet of intercepting
sewer along Muddy Branch and Rock Run. The project is tributary to the
Potomac Interceptor.
Initial Population (1960 census)	1900
Design Population (year 2000)	73,900
Eligible Project Cost	$1,646,003
Grant Amount	$ 512,210
Date of Grant Offer	May 7, 1968
Status: Construction complete on basic grant construction program.
Increase in scope is being considered by Applicant.
b.	WPC-Md-173; WSSC (JAMES CREEK) *
The project consists of a pumping station and force main to convey
wastes from the Patuxent Basin to the Rock Creek sewerage system.
Initial Population (1960 census)	300
Design Population (year 2000)	6,100
Eligible Project Cost	$265,000
Grant Amount	$171,870
Date of Grant Offer	April 12, 19S8
Status: Construction complete
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c.	WPC-Md-174; WSSC (NORTHWEST BRANCH INTERCEPTOR)
The project consists of 37,500 lineal feet of intercepting sewer in
the upper reaches of the Northwest Branch.
Eligible Project Cost $820,000
Grant Amount	$215,470
Date of Grant offer	April 5, 1968
Status: Construction complete
d.	WPC-Md-219; WSSC (INDIAN CREEK, PAINT BRANCH AND LITTLE PAINT BRANCH)
The project consists of approximately 39,285 lineal feet of intercepting
sewer.
Initial Population	4,360
Design Population (year 2000)	47,200
Eligible Project Cost	$1,099,000
Grant Amount	$ 414,610
Date of Grant Offer	February 10, 1969
Status: Under construction - approximately 80% complete
e.	WPC-Md-209; WSSC (ROCK CREEK - R0CKVILLE INTERCEPTOR)
The project consists of approximately 4,700 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	6,250
Design Population	19,700
Eligible Project Cost	$201,500
Grant Amount	$ 20,800
Date of Grant Offer	April 12, 1968
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Maryland - Grant Applications
a.	WPC-Md-239; WSSC (HOLLY SPRINGS)
The project consists of intercepting sewers to serve the community of
Holly Springs.
Initial Population	70
Design Population	5,490
Estimated Eligible Project Cost	$65,100
Estimated Grant Amount	$35,800
b.	WPC-Md-240; WSSC (PRINCE GEORGE'S COUNTY)
The project consists of the construction of relief sewers along Northeast
Branch and Sligo Branch. The project is proposed to relieve a surcharging
sewer which due to development may result in overflows.
Initial Population	146,475
Design Population (year 2000)	620,700
Estimated Eligible Project Cost $4/355,300
Estimated Grant Amount	$2,177,650
C. WPC-Md-276; WSSC (CABIN JOHN CREEK)
The project consists of the construction of approximately 7,000 lineal
feet of relief intercepting sewer from the Potomac Interceptor along
Booze Creek and along MacArthur Boulevard.
Initial Popjlation	85,800
Design Popjlation	211,200
Estimated Eligible Project Cost	$782,200
Estimated Grant Amount	$430,210
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a. WPC-Md-249; ROCKVILLE
The project consists of the northeast Rockville intercepting sewers
which will divert flows pampsd by the First Street Pumping Station to
the Rock Creek system and allow the Pumping Station to be abandoned.
Initial Popalation	6,700
Design Popalation	14,090
Estimated Eligible Project Cost	$112,100
Estimated Eligible Grant Amount	$ 61,650
3. Virginia
a.	WPC-VA-240; HERNDON, VIRGINIA
Interceptor sewers along Sugarland Run and Folly Lick Branch which connecl
to the Fairfax County system and thence to the Potomac Interceptor sewer.
Initial Popalation	5,000
Design Popalation (year 2000)	30,000
Eligible Project Cost	$781,400
Grant Amount	$257,850
Date of Grant Offer	July 24, 1967
b.	WPC-VA-253; FAIRFAX COUNTY INTERCEPTOR sewers along Sugarland Run and
Folly Lick Branch which connect the Herndon sewers being constructed
under Project WPC-VA-240 to the Potomac Interceptor sewer.
Initial Population	4,600
Design Popalation (year 2000)	81,700
Eligible Project Cost	$880,000
Grant Amount	$263,990
Date of Grant Offer	August 25, 1967
Status: Construction complete
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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 around Washington.
Variations in salinity and nutrient enrichment from wastewater discharges
have a pronounced adverse effect on the ecology of the estuary. Historical
plant life cycles 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
to the effect 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 1960's. This problem is primarily attributable, on a
proportional basis, to present inadequately-treated sanitary discharges
from the Blue Plains and other plants in the area.
Biological observations during previous years indicate a
succession of more-dominant aquatic species as incoming nutrients increase.
During the summer season large populations of blue-green algae are pre-
valent 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 expires, an
(a) Available for inspection at the Region III Office of EPA
32

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additional demand is placed on the dissolved oxygen in the Estuary,
thus reducing the assimilative capacity of the Estuary during critical
flow conditions.
Mathematical model simulation of the dissolved oxygen budget
including carbonaceous, nitrogenous, benthic, and algal demands indicate
that the nitrogenous demand is the greatest cause of dissolved oxygen
deficit in the critical reach near the wastewater discharges and that
algal growths have the greatest effect on dissolved oxygen from
Piscataway to Indian Head, Maryland. The nutrient enrichment and
resultant 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. Control of accelerated eutrophication will thus preserve the
oxygen in the Estuary for assimilation of effluents which must be
discharged. It will also prevent growth of nuisance aquatic growths
which create objectionable odors and aesthetic conditions in the Upper
Estuary.
The upper reach of the Potomac Estuary received an approximate
average of 325 mgd of domestic wastewater during 1970. It is estimated
that the flow will increase to approximately 473 mgd by 1980.
The existing Blue Plains sewage treatment plant had an average flow
of approximately 252 mgd in 1970 and is projected to increase to 309 mgd
(average) before 1975. In 1970 Blue Plains was receiving almost 80
percent of the total domestic wastewater flow in the Upper Estuary and
in 1980, by projection, it will receive approximately 65 percent of the
wastewater flow.
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It is the opinion of this Office that advanced wastewater treatment
at Blue Plains will play a key role in the future enhancement of Potomac
River water quality by reducing BOD^^, nitrogen and phosphorous loadings
in the future effluent from the Blue Plains plant.
Completion of the current expansion and upgrading of the Blue
Plains facility will actually reduce the BOD,., nitrogen, and phosphorus
from approximately 145,500 lbs/day, 47,500 lbs/day, and 17,200 lbs/day ^
to less than 12,700 lbs/day, 61,130 lbs/day, and 560 lbs/day, respectively,
as adopted by the Potomac Enforcement Conference for the District of
Columbia. This will enhance the dissolved oxygen content in the Estuary
by removing carbonaceous and nitrogenous oxygen demand and reducing
nuisance algal growth by removing nutrients. Thus, the project will have
a beneficial impact on the aquatic environment of the Potomac Estuary.
The Potomac River is a source of water supply 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.
(a)	B0D5 is defined as that 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/1) or
pounds.
(b)	Average for July-December, 1971
34

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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 could be used for water supply. It was
determined that discharge of wastewater out of the Basin would con-
siderably reduce the water supply potential of the Estuary. The number
of days that the Estuary can be used for water supply depends on fresh-
water flow conditions and location of wastewater discharges. Therefore,
future cooperative planning efforts in the Washington Area is necessary
to coordinate water supply and wastewater treatment requirements since
the use of the Estuary for water supply depends on stream flows which may
be altered by upstream storage, the location of wastewater discharges,
and diversion of wastewater to other basins or to land if spray irrigation
disposal alternatives are environmentally and economically feasible in
future years.
In May 1970, Maryland's Secretary of Health and Mental Hygiene
placed a moratorium on sewer connections in portions of Prince Georges
and Montgomery Counties. This has essentially halted new connections
in the sections of Anacostia and Cabin John Creek Watersheds which
transport wastewater to Blue Plains sewage treatment facility.
Connections approved prior to May 1970 are permitted to utilize the
existing system.
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The induced impact of this action is to create artifically
higher prices for residential development land because of the decreased
supply in the supply and demand ratio. Thus, housing becomes more
expensive in one area and development increases in areas which may not
have planned for immediate growth. Patterns of growth are then dictated
by the moratorium rather than by a logical planning sequence.
Completion of the Blue Plains sewage treatment facility will
not automatically allow the moratorium to be lifted. However, it is
the first step toward solving the domestic wastewater treatment needs
in the Washington area. The next step is selection of the location for
another regional domestic wastewater treatment facility to handle flows
above 309 mgd.
The existing effluent outfall is designed to discharge into the
turning basin of the dredged docking facilities (See Frontispiece).
Dr. Lucian Brush of Johns Hopkins University is evaluating the effect
of the proposed discharge location for the District of Columbia
Department of Environmental Services' Consultant. The Environmental
Protection Agency will evaluate the Consultant's findings and make the
final determination and recommendation as to whether or not to locate
the discharge directly into the main ship channel of the Potomac. The
proposed additions to the Blue Plains plant, including the outfall
I
conduit are being designed and located so as to facilitate extension
to the main navigation channel should this action become necessary.
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Fuel oil will be brought to the plant by barge for use in the
sludge incinerators as well as in other heating units. Approximately
60,000 gpd will be required for incineration. The District has indicated
it plans to pump the oil to on-site storage tanks. These facilities will
be expected to be operated in accordance with the guidelines currently
being prepared by EPA.
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 is preparing regulations concerning prevention of
pollution at oil transfer facilities. These may be expected to apply
to the District. The proposed regulations were published in the Federal
Register on December 24, 1971.
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 countermeasure and control plan.
Chlorination of the plant effluent is being provided for dis-
infection. The District has been chlorinating the effluent since 1955
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and has observed no adverse impacts on the biota of the river. Since
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.
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 percentage increase will be reduced to approximately
1/10 of one percent. Emissions of carbon monoxide and organic compounds will
be essentially zero. Trace amounts of toxic mercury and lead compounds may
also be added to the atmosphere with a negligible effect on ambient air quality.
The predicted effect of the emissions of oxides of nitrogen, particulates,
and sulfur dioxide show that no meaningful degradation of air quality will
occur in the immediate vicinity, the city, or the metropolitan area. For
severe limits of meteorological conditions, the quality of ambient air may
be diminished by small amounts to a level not exceeding 12 of national
air quality standards - such degradation would be restricted to local points
in the vicinity which are generally expected to occur 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. 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.
Odors from the existing plant have been a problem in the area
for many years. The adjacent Naval Research Laboratory has complained
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that odors become intense and produce nausea. There is also claim
that structural finishes are damaged by the fumes. Complaints have
also b^en received from persons utilizing the Anacostia Freeway.
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.
Consequently, 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
well as the sludge processing facilities, particularly the thickening,
elutriation, and vacuum filtration unit processes. A particularly
severe source of odors is the sludge stockpiled on the site. Because
of restrictions based on considerations of public health, the material
must be retained at least one year before it is made available to the
general public.
Since virtually all the land at the site will be used for treatment
facilities, the sludge stockpiled on the site will be removed. Some
of the sludge will be utilized in the construction of the Oxon Run Golf
Course. The remainder will be disposed of at approved landfill operations
by contract.
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Since March 1969 the incoming sewage has been continuously
prechlorinated 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 become 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 incin-
eration process itself or in the fume furnace through which all exhaust
gases are passed.
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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.
Some concern exists as to the effects of organisms in the
wastes which may be discharged to the air by the activated sludge process.
From a review of the available literature it is apparent that little
research has been done along this line, especially with regards to viruses.
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 conclusions
reached in the report were:
1.	Under the worst conditions, contamination of the air in the
vicinity of the waste treatment plants extended 100 - 200 ft.
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 ft. downwind would result in an inhalation rate of 2
bacteria per minute. This was not considered to be a
significant hazard.
3.	There is no epidemiological evidence to indicate the danger
to public health from sewage treatment plant aerosols.
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4.	The predominant genera in these aerosols were Klebsiella,
Escherichia and Aerobacter. Klebsiella are frequently
implicated 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
unaware 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 be conducted concerning the public
health effects of airborne pathogens from STPs.
Incinerator destruction of most pathogens is assured by the high
temperatures and sludge residence time in the incinerator. 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 gas 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.
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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 building 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.
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 levels to satisfactory
1evels.
The visual impact of the plant from both the River and the
Anacostia 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
harmony with new architectural designs for this type of building in the
Washington area. The basic concrete facing panels encompass the whole in
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clean, horizontal lines, and interrupted by the introduction of
vertical ribs in the entrance way, thereby eliminating monotony. The
entrance way and the vertical ribs will project shadows which will
be continuously changing with the sun.
The building is located far enough from the waterline to be
properly 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 Commission
in their recommendations for the strip as well as other aesthetic
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 developing.
D. Short-Term Effects During Construction
It is anticipated that some siltation will occur during con-
struction of the facilities. This is unavoidable but is and will continue
to be minimized by construction procedures. (Appendices J and K) Under
the mass excavation contract, two 61 foot diameter settling basins are to
be constructed. Drainage from the plant site will be routed to these tanks
for settling of any silt prior to discharge of the water to the Potomac.
The basins are designed so that one may be taken out of service for
periodic cleaning as this becomes necessary.
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In addition to the settling basins 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
Appendix J.
The areas where most of the new construction will occur are pre-
sently being utilized as a sludge storage area. During a recent trip to
the site it was observed that little if any vegetation occurs in this area
and some of the sludge is washed away during rain.
Operation of the concrete plant should have little or no effects
on water quality near the site although it will be located on the dock.
Raw materials will be brought to the site by barge and unloaded directly
into the plant as needed.
This action will reduce the possibility of 'accidental spillage
versus site stockpiling for future use since materials would be double-
handled and hauled greater distances. Should materials be stockpiled,
there exists the possibility of pollution from runoff during adverse
weather.
The plant itself is to be operated in such a manner so as to prevent
materials from escaping into the River. A major source of water pollution
from concrete operations comes from the cleaning of trucks and other
equipment. Trucks used to deliver the concrete are often cleansed at
the nearest stream and the wastewater, with concrete residue is purposely
washed into the stream. The rigid D. C. contract specifications require
that mixing and delivery units be washed out and waste concrete be separated
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with:
1.	the wastewater conveyed to the silting basin, and
2.	the concrete residue disposed of at approved locations.
Also, no waste materials or washwater is to be dumped or allowed to run
into the bay or River.
Since the batch plant is on the wastewater treatment site, trucks
will be operated only on the premises and therefore control will be
simplified than if they left the site to pick up loads elsewhere.
The plant may be expected to meet its present or a higher
efficiency during the construction of the new facilities. Under a
current contract, facilities to provide alum or ferric chloride feed to
the existing aeration basins are under construction. These facilities are
to be completed by May 15, 1972 and when they are in operation, a sub-
stantial increase in plant efficienty can be anticipated.
Some decrease in efficiency may be expected as individual units
are taken out of service for modification; however, the efficiencies should
not reduce below the current plant level.
EPA guidelines for Design, Operation and Maintenance of Waste
Water Treatment Facilities require continuation of the same degree of
treatment by the existing plant during the construction period for
alterations. If this is not feasible, a minimum of primary treatment and
disinfection must be provided at all times. Bypassing of raw sewage during
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the construction of the additions is not allowed unless it is
absolutely necessary. If untreated effluent must bypass the system,
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 3 shifts of 8 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 expected to
be a significant problem. The main access road around the plant site is
paved and will reduce dust generation caused by traffic movements. The
contractors are required to provide and maintain temporary measures to
control dust during construction (Appendix J).
Some minor siltation is expected to occur during dredging
operations which is caused by the disturbance of river bottom materials
as they are lifted into scows and again as it is released by scows in
the Dyke Marsh restoration area. Siltation is being minimized by use of
a clamshell bucket in lieu of hydraulic dredging which dissolves 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
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removed by clamshell bucket or by hydraulic means.
EPA has been monitoring the dredging operations continuously
since they began. Samples have been taken approximately once per
week and tests have shown no adverse affect on water quality from the
operation. Also, no changes in benthic biota, attributable to spoil
disposal, have been observed. Should adverse affects on water quality
be noted in the future, dredging will cease until a barrier is con-
structed to protect the mainstem of the Potomac River.
The dredged spoils are being 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).
Heavy metals contained in the bottom sediments at Blue Plains
are not in solution. During dredging operations, they generally will not
dissolve since they are removed in large masses of earth. The metals are
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 diluted by the material itself.
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
to complete the restoration. Any heavy metals in the dredged spoils will
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be trapped under the fill and should they migrate to the surface
through saturated material, they will be sufficiently diluted so as to
not be harmful.
During construction operations local noise levels are anticipated
to be higher than normal. Under the proposed expansion the time avail-
able for construction is being reduced from the original 5-3/4 years
to 2-3/4 years. This will reduce the short-term noise impact by 3
years but during the construction period will be more intense because
of simultaneous activities.
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 residential in nature, night construction
should not be particularly intrusive.
The use of the on-site concrete plant and docking facilities
should reduce rail and truck traffic in surrounding neighborhoods. These
facilities are located approximately 2300 feet from the Naval Research
Laboratory property line and 900 feet from the Anacostia Freeway.
Land use in the area is not expected to be affected during con-
( struction with the exception of a small area located near South Capitol
Street and Oxon Run which will be used as a contractor storage area.
This land is owned by the National Park Service and will be restored
to its original condition as required by the NPS permit. (See Appendix J).
Some degree of general inconvenience will be experienced by the
surrounding area during the construction period. This impact cannot be
completely avoided but mitigative measures will be employed as discussed
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 is presently being implemented by use of clamshell bucket
and scow in lieu of more efficient and economical hydraulic techniques.
Since extensive disturbance and thus high turbidities of bottom materials
is associated with hydraulic dredging,the clamshell method was selected
for this operation. Adverse consequences from this project feature have
been and are expected to continue to be minimal. These findings are
documented in Appendix A.
The effect of disposal of spoil material downstream in Dyke Marsh is also
considered to be minimal and of a short-term nature. Use of bottom-dump scows
reduces the dispersion characteristics of the dredgings. Since this operation
integral to the National Park Service Restoration Plan, disposition of
this material at the designated site is considered to be a long-term
intangible benefit.
As presently planned, incineration of undigested sludge from future
AWT facilities will 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, the
incinerators will be designed utilizing contemporary abatement techniques
and sophisticated equipment. The air quality impact of the incineration

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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 plant's aesthetic impact on the Potomac Estuary has also been
minimized 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 residences to any significant degree as stated
in Section III.
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
conflict with the goals set forth in Section 101(b) of the National
Environmental Policy.Act of 1969.
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V. ALTERNATIVES TO THE PROPOSED ACTION
TREATMENT ALTERNATIVES
A.	No Action. Since the plant is currently overloaded (annual
average flow of 259 mgd in 1971 vs. the annual average design flow of 240
mgd), this is not considered to be a practical alternative. In addition
to the 259 mgd treated, approximately 6 mgd overflows into the Potomac
River at the Georgetown Gap. The continuing discharge of this quantity
of secondary-treated effluent to the Potomac without advanced waste-
water techniques would continue to degrade the River in the future no
matter how sophisticated other plants in the area treated their discharge.
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. 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.
Without 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
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of Wisconsin, Milwaukee, who was retained as a consultant by the
Department of the Interior. In his report, Mr. Bacon recommended
the following 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.	Tertiary facilities - begin design within one year and
complete within one year; complete construction by December 31, 1975.
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Mr. Bacon recommended that flows to the D. C. plant be allocated
as follows:
Flows from:
District of Columbia
Potomac Interceptor;
Maryland
Virginia
Other than Potomac
Interceptor;
Virginia
Marry land (WSSC)
Actual Present
Inflows (mgd)
Year 1970
124
1
4
7
113
Projected
Inflows (mgd)
Year 1980
135
10
14
6
45
Year 2000
180
22
42
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
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"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.
Bacon stated in his letter report to the Department of the Interior
that the Blue Plains plant "cannot be expanded to treat the waste load
which will be generated in the metropolitan area by the year 2000
(420 mgd estimated) simply because the Potomac estuary does not have
the capacity even if the degree of treatment exceeds 99% removal."
Professor Bacon based his conclusions upon a review of the work done by
Dr. Norbert Jaworski, Federal Water Pollution Control Administration,
Chesapeake Technical Support Laboratory (now part of the Region III
Office of EPA).
Dr. Jaworski*s Technical Report #39 indicated that the Water Quality
Standards minimum Dissolved Oxygen (D.O.) of 5.0 could be met if 57,000
pounds of Ultimate Oxygen Demand (U.O.D. is a combination of the
carbonaceous and the nitrogenous oxygen demands) is discharged to Zone 1.
This report stated that at a capacity of 419 mgd, Blue Plains would have
to provide 98% removal of 5-day BOD, 93% removal of nitrogen, and 98%
removal of phosphorus.
(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.
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The 240 mgd capacity Bacon recommended was arbitrarily established
since it is the current average annual flow that the existing plant
was designed to treat. The plant is designed to treat an average
daily flow of 290 mgd during the maximum summer months. However, with
the necessity to bypass the secondary units when flows exceed a 300 mgd
rate, the 290 mgd design figure does not seem practical to use.
The pros and cons of Bacon's argument are listed below:
1.	ADVANTAGES
a. Initially, a smaller design flow will be handled at
the plant, 240 vs. 309 mgd. However, the total discharge of pollutants
to the Potomac at this point will remain approximately the same in
either instance so any advantages would be minimal. Under Bacon's
proposal the design capacity would ultimately be increased to 297 mgd
which is only 4% less than the current project.
2.	DISADVANTAGES;
a.	The Blue Plains project would be completed one year
later than currently planned.
b.	Other plants in the area which would complement Blue
Plains in enhancing water quality of the Potomac would probably be
further delayed as a result of future court actions concerning
"capacity rights."
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) led to the establishment of plant capacity at 309 mgd.
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Bacon recommended that disposal of digested sludge on a crop
rotation 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 or 12.3 square
miles. The area of Alexandria is approximately 9,600 acres or 15 square
miles. Sludge disposal alternatives will be subsequently discussed in
this section.
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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 activated 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 Conference 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
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treatment studies were reported in June 1970. This report did not include
a detailed discussion of all aspects of each alternative, but did include
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 use at Blue Plains were:
1.	Independent physical-chemical treatment.
2.	Biological treatment.
a.	Conventional-tertiary treatment (physical-chemical additions)
b.	Bio-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) Metcalf & Eddy Report - Comparative Evaluation of Advanced Waste
Treatment Systems 6/17/70
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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 objectionable 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
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 the winter season.
The system incorporated the use of a carbon adsorption 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
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during construction.
At this time(6/7P) 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
disinfection.
Capital Cost, $Millions	395
Operating Cost, $Millions/Year	34.0
Total Annual Cost, $Millions/Year	62.5
Total Cost/mil gal treated, $	554.00
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.
b. Excess flows to receive primary sedimentation in storm tanks
followed by disinfection.
Capital Cost, $Millions	350
Operating Cost, $Millions/Year	31.5
Total Annual Cost, $Millions/Year	56.5
Total Cost/mil gal treated, $	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
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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 frequency 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.
Capital Cost, $Millions	360
Operating Cost, $Millions/Year	32.0
Total Annual Cost, $Millions/Year	58.5
Total Cost/mil gal treated, $	519
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
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2.	Phosphorus Removal processes
a.	2-stage lime precipitation
b.	Single-stage lime-soda precipitation
c.	Metal ion precipitation (mineral addition)
3.	Nitrogen Removal processes
a.	Ammonia stripping
b.	Ion exchange
c.	Biological nitrification-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 introduced into the step-aeration system employing a relatively
long biological growth period, could stimulate the reproduction of
these organisms.
During the operation of the system, it became apparent that
filamentous growths could by eliminated only by addition of hydrogen
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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 subsequent nitrification system or to nitrogen removal
by breakpoint chlorination or ion exchange. Some denitrification
occasionally occurred in the secondary settling tank with a resulting
loss of solids in the overflow. 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 reliability observed during the operation
of the step-aeration system in the pilot plant was not consistent with the
degree of reliability necessary 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
to enable high overall oxygen adsorption efficiency at a high overall
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
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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
operating at the EPA-DC pilot plant since May 1970 and problems of
solids sepration and growth of filamentous organisms have occurred. During
the winter months when wastewater temperatures were low, solids separation
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 similar impact on subsequent nitrogen
removal processes as occurred in step-aeration.
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
Memorandum of Understanding called 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.
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Research conducted at the EPA-DC pilot plant indicated that
raodified-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 demonstrated
in the pilot plant.
3.	Nitrification did not occur in the modified-aeration system
even in the summer months.
4.	Filamentous growth was not a problem in solids separation.
Phosphorous Removal Processes
The April 1969 Enforcement Conference effluent requirements resulted
in limiting phosphorus concentration in the effluent to 0.22 mg/L at
309 mgd. Studies at the EPA-DC pilot plant indicated that these
requirements could be met by two-stage lime precipitation and possibly
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 phosphorus 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
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in the first stage to raise the pH above 11. Precipitation of
hydroxyapatite, Ca CO^, and MgtOH)^ occurs. Between the first and
second stage settlers carbon dioxide is added to reduce the pH to 10
where Ca C0^ precipitation occurs. Phosphates included in the
hydroxyapatite are removed when the precipitate 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.
The data obtained from operation of the two-stage lime precipitation
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 is added to the wastewater to raise the pH to a desired
value, usually less than 10, where the calcium carbonate (C CO )
a 3
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 subsequent
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 phorphorus
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 consistently 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
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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. However, American Cyanamid could
manufacture 35,000-43,000 tons per year of alum, available immediately,
and Pennwalt Corporation could supply about 20,000 tons per year of
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 industrial
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
The ammonia stripping and ion exchange processes were previously
described in the physical-chemical systems.
3. Biological Nitriciation-Denitrification
Nitrification and dentrification 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)
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by two types of bacteria in an aerobic activated sludge process.
Denitrification is a anoxic activated sludge process (carried out in the
absence of air) where bacteria use the oxygen in nitrate (NO^) to
oxidize a carbonaceous source, i.e., methanol. In the reaction the
nitrate is reduced to nitrogen gas, and discharged to the atmosphere.
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
D.C. effluent into the Potomac. 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
sufficient 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 reducing organic nitrogen to low levels. Nitrification in upstream
systems cannot be tolerated since the nitrate nitrogen would not be
removed by the process.
Breakpoint chlorination would not appear to be compatible with
the step-aeration or oxygen process in which nitrification occurs
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unless operating techniques are employed to prevent nitrification in
the activated sludge process. 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.
Processes employing breakpoint 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 quantitites 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.
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2. Biological Treatment System
The treatment processes previously described were evaluated by the
District of Columbia and its consultants in the following treatment
systems:
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
breakpoint chlorination. Mineral addition within the biological secondary
could be considered as an alternate to two-stage lime precipitation.
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, filtration
and breakpoint chlorination.
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5.	Step-aeration, mineral addition, filtration, breakpoint
chlorination, carbon adsorption.
6.	Oxygen activated sludge, mineral addition, filtration,
breakpoint chlorination, carbon adsorption ~
7.	Modified aeration, mineral addition, filtration, breakpoint
chlorinationj 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 occassionally occurred in the
step-aeration process prevent nitrogen removal requirements from being
met.
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f. This alternative would require the use of multi-level
construction to accommodate the plant on the existing site.
2.	Oxygen activated sludge, two-stage lime precipitation,
filtration 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
creating additional difficulties in maintaining present treatment levels
during construction.
b.	Nitrogen removal requirements could not be met due to
the nitrification which occurred in the oxygen process during the
summer months.
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 chlorination .
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, filtration
and breakpoint chlorination.
This system was rejected for the reasons given under alternative
3 plus the oxygen process problems listed under alternative 2.
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5.	Step-aeration, single-stage mineral addition, filtration,
breakpoint chlorination, 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 chlorination 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 requirements,
even with filtration.
6.	Oxygen activated sludge, single-stage mineral addition, filtration,
breakpoint chlorination, 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
chlorination, 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.
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.
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B. Bio-Chemical 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-
denitrification process for nitrogen removal, thus eliminating many
of the disadvantages associated with ion-exchange or breakpoint
chlorination which were considered in the other two major 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 be 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 confidence
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 present
plant with a minimum of interruption to plant operation and
efficiency.
Nine separate alternates within this system were evaluated. These
combinations are as follows:
1. Step-aeration, nitrification-denitrification, two-stage lime
precipitation and filtration.
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2.	Oxygen activated sludge, nitrification-denitrification, two-stage
lime precipitation and filtration.
3.	Modified aeration, nitrification-denitrification, two-stage
lime precipitation and filtration.
4.	Step-aeration, nitrification-denitrification, single-stage
lime precipitation and filtration.
5.	Oxygen activated sludge, single-stage lime precipitation and
filtration.
6.	Modified aeration, single-stage lime precipitation, filtration.
7.	Step-aeration, mineral addition, nitrification-denitrification,
filtration.
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 alternatives:
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
nitrification which occurred^each prevented the satisfactory operation
of the nitrogen removal processes.
b.	This system would require the largest land area or the
maximum 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.
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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
construe tion.
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.
This system is capable of producing an effluent of high quality
which would meet the requirements set by the Potomac Enforcement Conference.
It was considered until the final design decision was made and was rejected
when it was determined that two-step mineral addition could achieve the requirec
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 the current project would be required for lime
recalcination. Emissions from these could be expected to be similar to
the proposed facilities.
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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 considered
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 precipitation, 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 precipitation, filtration.
This system was rejected for reason b listed under alternative 4.
1. Step-aeration, mineral addition, nitrification-denitrification,
filtration.
This system was rejected for the following reasons:
a.	Reasons "a" under alternative 1.
b.	The system would 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-dentrification,
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
addition-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 occassionally 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
consistently producing an effluent which will meet Enforcement Conference
requirements.
D. South Tahoe Design
The mgd South Tahoe treatment plant consisted of conventional
biological treatment including primary settling, aeration, and secondary
settling followed by chemical treatment and phosphate removal, nitrogen
removal by ammonia stripping, mixed media filtration, activated 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.

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The biological treatment units are of conventional design. Phosphates
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 wastewater is then
recarbonated using carbon dioxide to recover calcium as calcium carbonate
which is settled in the second stage clarifier and passed through
mixed-media filters and carbon columns. The mixed-media filters remove
all suspended solids and significant 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 remaining BOD, color and detergents.
Some problems have occurred 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 raises
the pH to a level where the ammonium ions are 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 due to freezing
problems and calcium carbonate deposits. The plant is now considering
breakpoint chlorination for nitrogen removal.
The wastes are finally disinfected by chlorination before discharge
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 duplicate,
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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 precipitation was abandoned when it was determined 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 considered
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.
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E. Spray Irrigation (Muskegon Plan) -
The treatment system being constructed for the Muskegon,
Michigan area was first brought to this office's attention in November
1971, over a year after the District of Columbia had been committed to
enlarging and upgrading the existing Blue Plains facility by the end
of 1974. 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
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
domestic and industrial sources.
Before a system of this type can be designed or its cost estimated
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 of Washington to make it feasible at all to construct. 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.
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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 pimped back through the city or
pimped around it to reach those locations. Should further consideration
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 pimped 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
considered practical since they will be virtually developed in the next
50 years.
From discussion with Maryland Environmental Services 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.
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Potential land areas were calculated for several systems.
Design criteria similar to Muskegon's were used where practical and
Virginia's "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.
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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.
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.
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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
discharges, however, there is minor industrial wastes in the
District of Columbia area.
b, Disadvantages
1. Delay in reducing pollution in the Potomac. Blue
Plains is scheduled for completion in December, 1974. A spray
irrigation system would probably take several additional 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.
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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 pamp wastes a distance of 100 miles would be approximately
3 7,220 kw, which is sufficient to meet the average demand of 52,000 homes.
4.	Reliability of pimping and treatment - Several pamp 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 compensate
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.
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6.	The possibility of crossing Chesapeake Bay where the
maximum depth ranges from 60 to 120 feet would cause severe
construction difficulties 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 is 81,600 acres.
8.	The major consumer costs involves the land which is
currently not eligible for Federal participation. This cost must
be directly borne by the pablic.
9.	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.
10.	Transfer of large volumes of water out of the
Potomac Basin.
11.	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.
12.	Siltation during construction may be reduced but not
entirely eliminated.
C. Unknowns
1.	Effects of increased flows in local streams due to spray
irrigation. Will this increase the chances of flooding downstream?
2.	Effects of waterfowl utilizing storage ponds for nesting
areas. Will they transmit pathogenic viruses and bacteria?
j
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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 reasonable construction
and operating costs.
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 appreciatle quantities in the supernatant liquor.
(a) Culp Advanced Wastewater Treatment, P. 180
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Each of the processes currently employed at the District's plant (gravity
sludge thickening, anaerobic sludge digestion, digested sludge elutriation,
and dewatering) involves 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 digestors. 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
(b)	Land Disposal
(a) Ocean Disposal: The disposal of partially stabilized liquid
sludge to the ocean either through a subaqueous pipeline or a specially-
designed vessel has been practiced in some coastal cities for many years,
including New York City, Philadelphia, and Los Angeles. At the time a
preliminary engineering report was completed in February 1969, the
FWPCA (an agency whose function are now included under EPA) was considering
a nationwide policy on ocean disposal. Compliance with the following
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guidelines was required before any water pollution control project
involving ocean disposal of sludge would be considered eligible for
construction grants under PL 84-660:
(1)	Such a disposal system should be supported by an
adequate demonstration that alternative methods of disposal have
been reviewed and are either not economically justified or create
a greater pollution hazard;
(2)	Adequate and effective assurances must be given
that the sludge to be disposed of will receive satisfactory
treatment in every case;
(3)	The selected disposal area must, on the basis of
adequate study, demonstrate that there is no foreseeable hazard
of pollution or violation of applicable standards;
(4)	Arrangements must be made for appropriate monitoring
and a commitment made to move the disposal area when, in FWPCA
judgment, a pollutional hazard is created and a commitment made to
abandon ocean disposal if another site cannot be found or if long-
term effects of sludge dumping are found, in the judgment of FWPCA,
to be unduly deleterious to water quality;
(5)	Adequate assurance must be given that the sludge will
be dumped in the selected area and in the manner prescribed either
by FWPCA or in the dumping permit.
The District's engineers concluded that ocean disposal could not
be considered a long-term solution to the sludge problem.
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The Council on Environmental Quality in its report to the President
of the United States in October 1970 recommended that ocean dumping of
digested or other stabilized sludge should be phased out and no new
sources allowed. Also, elimination of ocean dumping of undigested
sewage sludge was recommended. In cases in which substantial facilities
and/or significant commitments exist, continued ocean dumping may be
allowed only until alternatives can be developed and implemented.
Continued dumping was recommended only as an interim measure.
It has been this office's policy for several years to discourage
any communities not presently using ocean dumping of sludge from starting
this practice. Municipalities within the region which do practice this
method of sludge disposal are also being encouraged to develop alternative
methods.
(b) Land Disposal; Prior to January 1969, when Metcalf and Eddy's
preliminary 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.
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All the above-listed alternatives with the exception of incineration
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 coagulation would not be returned
in appreciable amounts. Research indicates that the use of alum has no
effect on the digestion process. No information 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 digestor
problems generally have increased because of the conversion to biodegradable
detergents.
Anaerobic digestion has one advantage in that the process results in
the production of methane gas which may be used as a fuel.
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. Should
uncovered beds be desired, a buffer 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 provisions for
access roads to remove the dried sludge.
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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.
For this metho-d 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 hearty
cooperation of the other affected States. It is felt that some delay will
be experienced in completing the solids handling facility should a pipe-
line be constructed. Siltation would occur during construction of the
pipelines.
The Maryland Environmental Services has contracted to conduct research
on the practicality of utilizing Blue Plains sludge as a fertilizer by
"deep plowing" into agricultural land. They propose to truck the sludge
to the points of disposal. The use of trucks would add to odors in the
vicinity of the plant as well as to traffic problems.
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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 4 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 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
additional lagoon sites.
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 the gradually decreasing demand
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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 environmental impact at final disposal.
The major disadvantage of this method is the potential air
pollution which may be caused by incineration. It is felt that this
pollution can be adequately controlled so as to meet applicable
standards. Air pollution implications resulting from the incineration
featuifeof this project is addressed in detail in Section III and
Appendix C of this report.
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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. At present EPA is not supporting any research on this subject.
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 filtration
would continue to be required.
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ALTERNATIVES TO DREDGING
Several alternatives for conveying construction materials, excavated
soils, chemicals, process wastes, etc., to and from the plant site have
been considered. Access to the site is limited to three possible
transportation 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
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 controlled 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.
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

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-------
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 con-
struction until the interchange was complete would mean a several
year delay in cleaning up the Potomac.
Permission to construct a temporary exit ramp from the
plant site has been requested from the District of Columbia
Department of Highways; however, no action has been taken.
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 railroad 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. Approximately
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.
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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. With a substantial increase in rail traffic
there is a definite possibility that a 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 substantial delay in the completion of the treatment facility.
3. Water. There is currently no water access to the plant site.
Under the proposal, a navigation channel to the Federal project
in the Potomac and a turning basin is being dredged and dock
facilities 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 transportation in the Washington Metropolitan
Area.
All forms of access are somewhat limited in their usefulness during
and upon completion of the expansion. There will be very little, if any,
land available for the contractors use for storing and assembling materials
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on the site. Area for these purposes has been designated at South
Capitol Street near the District of Columbia - Maryland line on land
owned by the National Park Service. A copy of the Park Service permit
conditions is included in Appendix K. From this area the contractors
will haul supplies into the site when they are to be utilized in the
construction.
Use of the roads is somewhat limited due to the necessity of
minimizing interruptions to the operations of the Naval Research
Laboratory. The Laboratory has expressed their concern in this regard
to the District when they stated that the traffic volume impact of a
construction force of 1000 to 2200 workers at the Laboratory's main
gate could well be intolerable inasmuch as the Interstate 295 interchange
serving NRL is now functioning at full capacity (Appendix M). An
increase in traffic of 750 to 2000 automobiles daily and the truck
traffic serving an accelerated construction effort will produce traffic
congestion and road hazards which will seriously hamper the operations
of the Laboratory.
The District has indicated that although the peak construction
workforce will reach 2300, it does not anticipate that there will be
a corresponding increase in automobile traffic passing the main gate
of the Naval Research Laboratory. Except for the initial stages of
construction, it will be impossible, due to the very limited area
available for construction to accommodate more than a handful of
private automobiles on the site; accordingly, arrangements will be
made to transport construction workers from a nearby parking location
to the construction site each day by bus. Therefore, while a modest
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increase in the number of private automobiles on Interstate 295 may
be anticipated, traffic in the vicinity of NRL is not anticipated to
increase significantly.
Also, the normal construction hours of 7:30 a.m. to 4:00 p.m.
should blend reasonably well with the 7"-45 a.m. to 4:15 p.m. and 8:00 a.m.
to 4:30 p.m. shift schedules of NRL.
With regard to truck traffic, the use of massive construction
techniques are planned to meet construction deadlines. Construction
materials and much of the spoils are expected to be transported in and
out of the site by barge. This will involve, among other things, the
erection of docking facilities and a temporary concrete plant. Again,
while we must recognize that there will be some truck traffic which
is not presently experienced, this increase will be modest in comparison
to the amount of truck traffic generated during construction activities
if waterborne transportation is not utilized.
It should be noted, however, that first stage development (additional
primary facilities and sludge processing) which is now under construction
involve conventional construction methods. Excavated material is being
removed from the site by truck, while construction materials will be
transported by truck and rail. As of March 30, 1972, the major excavation
contractor is hauling the material away by truck. A major portion of
his trucking is being accomplished at night and on weekends to minimize
impact on traffic. Trucking during peak rush hours has been prohibited.
The following quantities of materials will be required during
construction and operation of the treatment facilities:
1. During Construction:
a. Approximately 450,000 cubic yards of concrete for use in
10 A

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construction of the various structures at rates up to
2,000 yards per day.
b.	Approximately 2,500,000 cubic yards of excavated materials
must be removed from the plant site for disposal.
c.	Equipment utilized in processes.
2. During Operation:
a.	Approximately 60,000 gallons per day of #2 fuel oil for
the sludge incinerators. Natural gas may be used if
sufficient supplies become available.
b.	Approximately 230 tons of alum per day or 120 tons of
ferric chloride per day for phosphorous removal for a
combination of the above.
c.	Approximately 86 tons of methanol per day for nitrogen
removal.
d.	Approximately 58 tons of lime per day for nitrifications.
e.	Approximately 30 tons of chlorine per day for odor control
and disinfection.
f.	Approximately 2.4 tons of anionic polymers per day for
nitrogen removal.
g.	Various chemicals for laboratory tests.
la. Concrete: The District plans to construct a concrete batch
plant at the docking facilities and supply concrete to the
various contractors as they require it. The coarse aggregate,
sand and port land cement will be barged in and unloaded
directly from barges into the batch plant, thus eliminating
the need for large storage areas for the materials. Concrete
105

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will be loaded into "ready-mix" trucks for hauling to site
locations where it will be placed.
No alternate locations for the batch plant within
the site were considered due to the need for large material
storage areas for which there is no space available.
Should a batch plant be set up at a location beyond the
plant site, the concrete would be trucked to the site using
ready-mix trucks. The District estimates that a peak rate
of 200 - 10 yard truck loads of concrete must be placed to
meet the December, 1974, completion date. This additional
amount of traffic would have a significant adverse impact on
the operation of adjacent facilities.
Raw materials would be hauled to the batch plant site
by barge, rail or truck. Extensive delays could result if
highway transportation or rail are utilized.
The Environmental Defense Fund and Mrs. Agnew (Section VII
and Appendix M) suggested that Boiling AFB be used as a site
for the batch plant and concrete be hauled by rail to Blue
Plains for placement. This is impractical for several
reasons:
(1)	Boiling AFB has planned uses for all its vacant land.
(2)	Noise created by the plant and rail traffic will
affect persons living in the Base housing which will
be constructed in the near future.
(3)	Raw materials must be transported in by rail and
stored on site. Use of the railroad for this would
106

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aggravate traffic problems on the Suitland Parkway
since there is a grade crossing at that point.
Boiling has no dock, facilities capable of accommodating
barge traffic.
(4)	Ready-mix trucks must be loaded onto flat cars for
transport to Blue Plains. High-quality concrete must
be homogeneous and must be continuous agitated from
the time water is added until it is poured. There
are no known railroad cars with revolving drums for
concrete.
(5)	The rail traffic through the Naval Research Laboratory
to Blue Plains would creat noise and traffic problems
with the Base as well as security problems.
Another alternative considered was to require the contractor
to purchase concrete from local plants. The concrete would be
trucked to the site, again creating traffic problems. If normal
portland cement is use, the concrete batch must be mixed and
poured once water is added within 1-1/2 hours, or one hour if
the temperature is about 85°F. This time limit does not allow
a flexible transit time.
Under the present contract for construction of the primary
units, the District encountered difficulty in controlling the
quality of concrete purchased from local suppliers and several
batches were rejected. The contractor later set up a batch
plant on-site for his use and since that time the quality of
concrete has always exceeded minimum standards.
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The District expects to save approximately $460,000 in
the cost of concrete by the use of the on-site batch plant,
b. Excavated Materials: Excess suitable materials which are
excavated from the site will be disposed of in several
locations. Approximately 210,000 cubic yards of excavated
earth plus 35,000 cubic yards of digested sludge from the
plant stockpile will be utilized in the Oxon Cove Landfill
which is to ultimately be utilized as a golf course. The
materials will be trucked from the plant site to this location.
The remaining sludge stockpile will be employed at various
landfills at the contractor's disposal areas in the Metropolitan
Area.
Some of the excavated material
with the exception of the sludge may be expected to be hauled
to the Dyke Marsh restoration project and placed within the
top several feet of the fill (Appendix A). This material
will be placed on spoil materials generated as a result of the
navigation feature of this project and deposited in the Marsh
area.
Removal of excavated materials by rail would require a total
of 56,000 carloads or 300 cars per day and would be impractical
due to:
(1)	Increased traffic and noise through military bases.
(2)	Need to construct second track before proceeding which
would considerably delay construction.
(3)	Stoppage of traffic on Suit land Parkway while trains
passed.
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(4)	Construction of a railroad yard at Blue Plains to
store cars while they are loaded. As previously
stated, area restrictions would not permit a railroad
car storage area at the site.
(5)	Load transfers from railroad cars to trucks for
hauling to final landfill location, or construction
of a railroad spur to that site.
Some of the materials will be removed by trucks. Should
the entire volume be removed by truck, approximately 1000
truckloads per day must be removed over a period of nine months.
Peak rates of removal would approach 1700 truckloads per day or
approximately 1.4 trucks per minute. Unless a second access
route to the site is constructed, traffic at the entrance to
the Naval Research Laboratory would be severely affected.
In addition to the effects on traffic, the use of highways
for hauling in concrete and removing excavated materials could
result in a significant adverse impact on ambient air quality and
noise levels.
c. Process Equipment: Some of the larger pieces of equipment 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.
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2. During Operation
a.	Fuel oil: Approximately 60,000 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 $3000 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 230 tons of alum
or 120 tons of ferric chloride will be used each day
in the treatment plant operation. This amount of alum
would require approximately 5 railroad 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 $600,000 over rail and $2,600,000 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 the above listed
materials is expected to reduce the daily traffic to
the site by a total of 9 railroad cars or 26 trucks during
operation.
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The lime and chlorine is expected to be transported
to the site by rail and the polymers and laboratory
chemicals by truck.
Ill

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VI. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT
AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
Upgrading and expansion of the secondary wastewater treatment facilities
to tertiary (AWT) is the first 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
municipalities 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
treatment 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 environmental costs of a negligible effect on ambient air
quality appears to easily justify this undertaking. It should also be reintera
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
112

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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 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.
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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) will further reduce the
probability of this occurrence.
As asserted in the environmental impact section of this report and
documented in Appendix C, 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
development 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
transportation 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.
1H

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The only other resource commitments associated with project
implementation that are known to this office consist of the various
fuels, chemicals, and other materials required to operate the plant
throughout its useful life.
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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 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 and nitrogen 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 quantities 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.
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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 concern 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.
4.	Northern Virginia Conservation Council (Former Position)
Marian K. Agnew, former President of the 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 statement 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 region-
wide waste treatment strategy, not just a solitary project."
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B. Proponents of the Blue Plains AWT Plant:
1.	Northern Virginia Conservation Council (Current Position)
On January 12 and 26, 1972, the Board of Directors and the membership
respectfully, modified their positions of November 10, 1971. Upon
reconsideration, they endorsed the "proposals of the Conference to
expand the capacity of the District of Columbia's Blue Plains sewage
treatment plant to 309 mgd by December, 1974, 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
within the Potomac River Basin.
2.	Citizens Council for a Clean Potomac. The Council passed
a resolution on January 18, 1972, urging "the U. S. 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. 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.

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APPENDIX A
DREDGING AND SPOIL DISPOSAL

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APPENDIX A
DREDGING AND SPOIL DISPOSAL
DISTRICT OF COLUMBIA WATER POLLUTION CONTROL PLANT
(BLUE PLAINS)
INTRODUCTION
Dredging for an entrance channel and turning basin at Blue Plains
began in mid-January, 1972. Early establishment of these facilities,
along with the proposed pier, were a prerequisite for the waterborne
delivery of construction materials and equipment for plant expansion
and modification (Photos 1 and 2, page A-ll). These facilities will
subsequently be used for delivery of maintenance material following
completion of plant modification.
The dredging is being done by a barge-mounted crane equipped
with a clamshell bucket (Photo No. 3, page Aril) . The spoil is loaded
directly into bottom dumping hopper scows (Photo No. 4, page.A-12},
which are then moved to the disposal site by tugs. The disposal site,
Dyke Marsh, is located about 3 1/2 miles downstream, along the
Virginia shore, immediately below New Alexandria (Exhibit 3, page A-15}.
Much of the Marsh, which encompasses about 385 acres, has been
demolished by commercial dredging for sand and gravel, a practice still
on-going at the north end of the Marsh. Most of the Marsh is owned
by the National Park Service (NPS) , with the bulk of the acreage
acquired from the dredging company. NPS plans to restore the marsh
and re-create a marsh environment.
Disposal of spoil from Blue Plains is being restricted to the
20 to 40 feet deep holes created by the removal of sand and gravel
A-l

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(Photo Nos. 6 and 7, page A-12). Separating these deeps from the main
stem of the River is a bar or barrier sill which rises to within
3 feet of the surface. An auxiliary channel crosses this sill and
connects the deep with the navigation channel in the Potomac
(Exhibit 4, page A-16). Present development plans by NPS project the
filling of the deep holes to -8 feet below mean low water (mlw) with
barged material. Trucked landfill material will be used in the parts
of the marsh which are to be filled to or above water level.
The landfill is also in progress, moving out from the northwest corner
of the area now being spoiled (Photo Nos. 8 and 9, page A-13). As the
material is dumped from the tracks, a bulldozer pishes it into the marsh.
In the final phase, as shown in Exhibit 5, page A-17, an island will be
constructed on the barrier sill and will enclose a lagoon. Bridges
constructed across channels connecting the lagoon with the river will be
removed after the fill is complete, to isolate the island.
An integral part of the agreement under which NPS acquired 260
acres of the Marsh from Smoot and Gravel Company (now Potomac Sand and
Gravel), was the right of the Grantor to continue dredging 150 acres of
the transferred marsh until 1999. Also, an additional 85 acres of
contiguous marsh, original property of NPS, can be dredged until 1989.
About 3 acres, leased by NPS as a marina, at the extreme northwest corner
of the marsh are exempted from dredging. Of the approximately 385 acres
included in Dyke Marsh, all but 28 acres on the south edge are now
owned by NPS.
A-2

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BACKGROUND
A Public Notice (Exhibit 1, page A-8), was issued on
November 16, 1970, describing an application by the District of
Columbia Government for a Permit "to construct a pier and a bulkhead,
to dredge a channel and a turning basin, and to place fill material
in the Potomac River." This application was the culmination of
several years of study, discussion and discarded alternatives. The
application represented another effort by the District to begin work
in modifying, expanding, and improving the Blue Plains Sewage
Treatment Plant. The controversial section of the application
concerns the deposition of the spoil material from channel and turning
basin construction into the Potomac River at Dyke Marsh.
Sediment samples were taken by Region III, EPA technicians on
December 8, 1970 and February 18, 1971 at the proposed dredging sites.
These were than analyzed at the Chesapeake Technical Support Laboratory
(now Annapolis Field Office) and were found to be polluted beyond the
parameters set forth in EPA's "Criteria for Determining the Acceptability
of Dredged Spoil Disposal to the Nation's Waters" (Exhibit 6, page A-18).
These criteria are guidelines, disseminated to the Regional Offices on
January 11, 1971, to be used on a case-by-case basis in determining
if dredged spoil could be dumped in open water.
This Office notified the District in March 1971, following analysis
of the muds, that the bottom sediments at Blue Plains were contaminated
and were not acceptable for open water disposal. It was recommended
that alternative disposal methods, including containment devices at
Dyke Marsh, be considered.
. A-3

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Core samples were taken at varying depths to -18 feet below
the water/mud interface by the applicant on June 8, 1971, to
determine the vertical extent of pollution in the bottom at Blue
Plains. CSTL technicians were present to sample the cores at the
time of coring. Analysis of the samples disclosed that contamination
was also present in the natural material underlying the sediment
blanket (Exhibit 7, page A-19)i Further examination of the cores
revealed that the underlayment was a heavy, clay-like material with
sufficient consistency to retain its identity when dumped on the barge.
This weight and consistency would ensure rapid settling and minimal
particle dispersion if the material was dropped into water from a
bottom dump scow.
The urgent need for a spoil disposal site to expedite acceleration
of the Blue Plains Treatment Plant expansion led to consideration of
optimal benefits. The upgrading of the Sewage Treatment Plant will
have a far reaching beneficial effect on a much longer reach of the
Potomac Estuary than might conceivably be adversely affected by
localized impact at the Dyke Marsh site. Spoil from Blue Plains
dredging is proposed to be used for fill no closer than 8 feet below
water surface (mlw)j with clean overburden used to complete the fill to
marsh level. Presuming the overburden, similar to that now being
filled from land, to be free of deleterious substances, any metals
that might migrate through saturated sediments would be diluted. If
the marsh is restored according to plan, conditions of the restored
portion should have physical characteristics comparable to the presently
existing marsh.
A-4

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Examination of nautical charts of the proposed spoil site
revealed that it was, in fact, a deep hole separated from the
navigation channel and river main stem by a submerged sill, or bar,
about 3 to 5 feet under the surface. This obstruction reduced the
possibility of dispersion of dumped material by water currents to a
bare minimum. Since normal river flow through the spoil site was
almost non-existent, particle dispersion and water-mixing would occur
during periods of ebb-tide, if at all.
A decision was made, subject to approval of acceptance of the .
dredged spoil as fill for the base of the marsh by NPS, to permit
the dumping of the spoil in Dyke Marsh. Conditions attached to such
permission were:
1.	Dredging would be done by clamshell bucket so as to minimize
turbidities and effect on water quality at the disposal site.
2.	Spoil would be loaded directly into bottom dump barges or
scows. No other disposal method would be used at Dyke Marsh.
3.	Water quality would be monitored by EPA and, if dumping
was found to be having an adverse effect, operations would be stopped.
4.	In the event that spoil disposal did adversely affect water
quality, a containment dike would be constructed riverward of the
spoil area before operations could be re-started.
The decision to restrict dredging to use of a clamshell bucket
was made in order to minimize mixing of spoil with the receiving
waters. A corollary condition was the requirement for disposal
from bottom dump scows only. These conditions precluded use of
A-5

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hydraulic dredging with attendant problems arising from dissolving
the spoil into a slurry and the resultant return of the water solvent
to the River.
SUMMARY
Water quality, as well as bottom sediments, at Dyke Marsh, Blue
Plains and in the Potomac River directly across from the marsh, have
been monitored by the Annapolis Field Office (Exhibit 8, page A-22),
Monitoring and sampling has been accomplished on an average of once
per week for the period January 26 (initial disposal) to March 8, 1972
(date of writing). Tests have disclosed no adverse affect on water
quality from the spoil disposal. This same negative result has been
found on chemical and biological composition of the bottom adjacent
to the spoil area. Samples from the River, across from the Marsh, have
been used for comparison in addition to data obtained from Dyke Marsh
prior to spoil disposal. No changes in benthic biota, attributable
to spoil disposal, have been observed (Exhibit 9, page A-22).
On February 23, 1972, an AFO craft, equipped with a depth finder
sensitive enough to chart the spoil as it settled below the hopper
barges, was held close to a scow as the dump was made. The depth
finder was started at the opening of the final compartment. As soon
as the scow was empty, it was moved away by the tug and the AFO boat
was moved over the dumping site. All of the shadows charted by the
depth finder as the spoil sank to the bottom disappeared within
10 minutes (Exhibit 10, page A-23). The only trace of the dump came
from a water discoloration. Approaching darkness, associated with a
A-6

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storm, precluded meaningful observation as to persistance of the
discoloration.
List of Attachments:
1.
Public Notice
Pages
A-8/10
2.
Photographs
Pages
A-ll/14
3.
Map - General Area
Page
A-15
4.
Map - Dyke Marsh Area
Page
A-16
5.
Map - NPS Development Plan
Page
A-17
6.
Dredge Spoil Criteria
Pages
A-18/19
7.
Analysis - Bottom Samples
Page
A-20
8.
Analysis - Water Samples
Page
A-21
9.
Analysis - Benthic Biota
Page
A-22
10.
Depth Finder Graph
Page
A-23

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DEPART[ENT OF THE ARMY
BALTIMORE DISTRICT, CORPS OF ENGINEERS
P. 0. BOX 1715
BALTIMORE, MARYLAND 21203
NABOP-P(Govt. District of Columbia)18
16 November 1970
PUBLIC NOTICE
TO WHOM IT MAY CONCERN:
The U. f.. Arr.iy Engineer District, Baltimore has received an application from
government of the district of Columbia, department of sanitary engineering,
PRESIDENTIAL MJ.rjJJlNG, 415 12 th STREET, N0 W., WASHINGTON, D. C. 20004, for
a Department of the Army permit: to construct a pier and a bulkhead, to dredge
channel and turning basin, and to place fill material in the POTOMAC RIVER
AT MARBURY POINT, UASKINGTON, D. C.
Plans showing the proposed work are on file in the Operations Division,
1628 Federal Building, 33 Hopkins Plaza, Baltimore, Maryland 21201, and may
be seen by interested parties. Copies of the plans arc attached to this sheet
The plans indicate that none of the proposed structures will extend more than
300 feet channeIward of the moan high water shoreline at a point on the caster
shore immediately downstream from Marbury Point, The plans also indicate that
approximately 470,0C0 cubic yards of material, consisting of sand, silt, and
mud, will be dredged and transported to and deposited at Dyke Marsh, Virginia,
The dredging will be accomplished with a bucket dredge.
The decision as to whether a permit will be issued will be based on an evalua-
tion of the impact of the proposed work on the public interest. Factors
affecting the public interest include, but are not limited to, navigation,
fish and wildlife, water quality, economics, conservation, aesthetics,
recreation, water supply, flood damage prevention, ecosystems, and, in
general, the needs and welfare of the people. Comments on these factors
will be accepted and made part of the record and will be considered in
determining whether it would be in the best public interest to grant a
permit. All comments should be furnished in writing to this office on or
before 16 December 1970.
It is requested that you communicate the foregoing information concerning
the proposed work to any persons known by you to be interested and who, not
being known to this office, do not receive a copy of this notice.
FOR THE DISTRICT ENGINEER:
Exhibit #1

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)K: CC-.-IT/.:. : :KT OF SPOIL I .'I 1L ?1 SP03AL A SEA W'LL 5E JWOYIStD IE .P. ECUI RED pY TIC L,'!VI"CMlE'iTAL
a-hncy	pf,:c-^.:i to maimai»: applicable f^ip.al-state water quality
STA,»L-A;:D CEHEHCIAL i.VTES US£S.
CONC. 'JOCK (ELIIV + v.^-' D.C.)
i!." of ;'KO?o:ed or-.^l-2i;;g
'D DOCKING FACILITY
:: PCTOVAC r, i V!_ f v
WATV.r< fOVLVntOM f.o:n?iOi

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4 Mo D C.
r
-f.J.L V/ :-l.7G D.C.

~~ T^-e^'S¦?d -
a-io
SECTION OF Pr'IOPOSL'O.'J.IEDC'wG
AND DOCKING TACILITY
IN: THE f^OT O.V.AC KiV n fi

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DISTRICT OF COLUMBIA
WATER POLLUTION
CONTROL PLANT
(BLUE PLAINS)
January 26, 1972
As seen from
Dredging Site
Incinerator Stack
at Left
Photo No. 1
.. ^	np
:UJ 'ji ft
Old Pilings
at Dredging Site
Incinerator Stack
in Center
Photo No. 2
Bottom Dump
Hopper Barge
being Loaded
by Dredge
Photo No. 3
Exhibit No. 2
A—11

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Loaded Hopper
Barge approaching
Dyke Marsh
Photo No. 4

Barge in Position
to Empty at Dyke Marsh
Photo No. 5
Sign Marking
Limit of Dyke Marsh
Spoil Area
On Barrier Sill
Photo No. 6
A-12

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Dyke Marsh
Spoil Area
Looking Northwest
from Barrier Sill
4tM 1 , * |£j»v
T~	
Photo No. 7
*>¦

t> —V
Trucks Dumping
Fastland Excavation
Material for Dyke
Marsh Landfill
Photo No. 8
Bulldozer pushing
Landfill Material
into Dyke Marsh
New Alexandria
in Background
Photo No. 9 A_i3

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Remnant of
Original Marsh
Orange Navigation
Photo No. 10
Boundary of
Original Marsh
Area still to be
Dredged
Photo No. 11
A-14

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»\Ol
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A-16

-------
PAGE NOT
AVAILABLE
DIGITALLY

-------
Y... volatile solids and C.0,1). analyses should be made first. If tha
i,., , i limits ere exceeded i:he sample can be characterised as polluted
and me additional pa^aj.^'.crr. wouM not have to be investigated.
Dredged sr-iincat hivinr; concentrations of constituents less than the
.Units stated abo>c id LI no': be automatically i onsidered acceptable for
disposal. A judfr.ent nuf.L' be i.iade on a caso-by~casc basis after
eonsiduring the factors listed in (a) through (h) above.
In addition to tbo analyses required to determine compliance with the
stated nv.Kiri ca.1. criteria , the following additional tests arc reccrr.-.end'
v.'horo appropriate and pertinent:
Total Phosphorus
Total Organic Carbon (T.O.C.)
IiiiMediate Oxygon Demand (I.O.D.)
Sl: ttleability
Sulci des
Trac j ".'jtals (iron, cadmium, copper, chromium, arsenic^ and nickel)
Pcst.i ci des
Jii onssay
The first four analyses would be considered desirable in a J most all
.instances. They ;nay be added to the mandatory list when sufficient
ex-.Kvienc.e with their interpretation is gained. For exeY.p je, as
experience .is gained, the: T.O.C, xest uay prove to l^e a valid sub-
stitute or the volatile so.lids and C.O.D. analyses. Tests for trace
metals and pesticides should be made where significant concearracioas
of the.so materials are expected from known waste discharges.
All analyses and techniques for sample collection» preservation and
prcper it ion shall be in accord with a current FV.'QA analytical manual
on seei'; oats.
A-19

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A-22
Exhibit No. 9

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February 23, 1972
Depth, finder graph, February 23, 1972 on site of
barge dump at Dyke Marsh. Note spoil shadow appearing
at 1410 (2:10 p.m.) and completely dissipated at 1420
(2:20 p.m.). Total life of spoil shadow (until spoil
settled on bottom) was 7 minutes
A-23
Exhibit No. 10

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APPENDIX B
UNIT PROCESSES

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APPENDIX B
UNIT PROCESSES
I.	Aerated Grit Chambers
The primary function of the aerated grit chamber is the removal from
the wastewater of sand and other inorganic materials. This operation is
essential in that the sand and inorganic materials, if not removed, would
contribute to excess wear in pumps and other plant components. The sand
when settling out, would constitute inorganic sludge build-ups in basins
and channels throughout the facility - thus reducing detention time and
efficiency. The application of air at this stage improved sedimentation
and grease coagulation. The air also replenishes oxygen depleted from
the waste water by natural biological processes prior to induction to
the waste treatment process.
Chambers of the design used at Blue Plains are efficient in removing
inorganic particles 0.2mm and over.
Twelve (12) additional grit chambers each 20 feet wide, 70 feet long
and 15 feet deep are to be constructed under the expansion.
II.	Primary Clarifiers (Sedimentation Tanks)
The purpose of the primary clarifiers is to remove settleable and
floatable solids and suspended solids from waste water. The clarifiers
maintain the waste water in a relatively quiescent state and the particles
suspended in the waste water which have a higher specific gravity than the
liquid tend to settle. These particles are then removed from the bottom
of the tank by a system of mechanical plows and surface skimmers and pumps
to a sludge holding tank. The removal of the solids from the waste water
Bl

-------
results in a reduction of 50 to 60% of the bacteria and a BOD reduction
of 25 to 40% in relation to the degree of efficiency in operation. The
average efficiency of this type unit is 35 to 65% removal of suspended
solids.
Twenty (20) circular clarifiers be each 120 feet in diameter with
14 feet sidewall water depth are to be added. Eight (8) of these are
necessary to treat excess flows received at the plant during storms.
All primary sedimentation tanks will be operated continuously
regardless of the incoming flow. Any flows in excess of a 650 mgd rate
will be conveyed directly to the excess flow chlorine contact tanks from
the clarifiers.
III.	Excess Flow Chlorine Contact Tanks
Chlorine contact tanks having a total detention time of not less
than 20 minutes at peak flow rates (289 mgd) will be constructed to
provide disinfection of the excess flows before their discharge to the
Potomac River.
IV.	Aeration Basins (Secondary Reactors)
The aeration basins produce a sludge floe by stimulating the growth
of zoogleal bacteria and other organisms. The waste water is aerated and
charged with activated sludge. By maintaining a well affected condition
conducive to aerobic growths, the biological degradation of organic
materials is accelerated, thus resulting in a diminishing of the oxygen
demand of the wastewater. The injection of air also replenishes the
oxygen depleted during previous semi-septic conditions. Upon leaving the
basins, the waste is of such nature that solids are easily removed through
sedimentation.
B2

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V.	Secondary Sedimentation
(At this location, the addition of metal salts for phosphorus removal
is made. The affects of this is discussed later under Phosphorus Removal).
The solids in the waste water after leaving the aeration basins are in a
highly flocculent state and settle to the bottom of the secondary
sedimentation tanks. The secondary sedimentation tanks are similar in
operation to the primary clarifiers and are also equipped with mechanical
surface skimmers to remove coagulated oil foams and gaseous sludge which
rise to the surface of the waste water.
Twelve (12) additional tanks are to be constructed each 260 feet
long, 80 feet wide and 12 feet deep.
VI.	Nitrogen Removal System
The system implemented in the Blue Plains facility is a three (3)
stage biological system designed to produce an effluent containing 2 mg/1
or less of total nitrogen. The three stages are:
1.	Carbonaceous Oxidation (previously discussed)
2.	Nitrification
3.	Denitrification-nitrogen release
The three-stage system allows management of the separate biological
transformations which are necessary for successful denitrification. The
high rate system discussed previously handles the bulk of the carbonaceous
removal and also removes some nitrogen at this station, the waste activated
sludge is removed. The nitrification stage receives a predominately
ammonia nitrogen feed and an enriched culture develops because each system
has its own sludge recycle.
B3

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The high rate system also protects subsequent nitrification stages
from toxic chemicals. Heavy metals, cyanides, thiocyanides and toxic
organic materials will be either absorbed or biologically degraded
before they reach the nitrification stage. Since this is a staged
system, there can be no direct short circuiting of materials from the
influent to the effluent.
Nitrification is the two-step biological oxidation of ammonia in
the wastewater to nitrite then to nitrate. It is accomplished by nitrite
and nitrate forming bacteria in the presence of air. During the process,
alkalinity is destroyed which unless replaced may cause the pH of the
wastewater to fall to levels which will inhibit nitrification. Therefore,
lime must be added to maintain the alkalinity especially if alum or other
alkalinity-reducing chemicals have been added previously for phosphorus
removal.
The nitrification system consists of:
1.	Twelve (12) nitrification reactor tanks, each 260
feet long, 83 feet wide and 30 feet deep.
2.	Twenty-eight (28) nitrification sedimentation
tanks each 242 feet long, 80 feet wide and 15 feet deep.
3.	Aeration equipment and pumps to return sludge from the
sedimentation tanks to the nitrification reactor tanks.
Denitrification is the reduction of nitrate nitrogen to nitrogen gas
which is discharged to the atmosphere. Once controlled nitrification has
been established, the biological denitrification process can be optimized.
B4

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The nitrified effluent flows to a stirred anaerobic reactor where methanol
is added in proportion to the nitrate nitrogen concentration. The
denitrification organisms utilize the oxygen component of the nitrate
radical to oxidize the organic carbon of carbonaceous matter. A carbon
source, usually methanol which is the cheapest commercial source, must be
added to create the reaction. This reaction takes place in the absence of
oxygen from the air and results in the formation of carbon dioxide and
nitrogen gas. The chemical reaction is as follows:
5CH3OH / e/1 / 6NO3 —> 5C02f / 3N2 / 13H20
Both carbon dioxide and nitrogen gases have limited solubility in
water. Gas bubbles tend to form and adhere to the solids in the liquid
thus inhibiting their settleability in the final clarifier. By agitating
the liquid by pumping air through it in the nitrogen release tanks, the
C02 and N2 are driven off. The sludge is then allowed to settle in the
final clarifiers. Units involved at Blue Plains include the following:
1.	Eight (8) denitrification reactor tanks. The exact
dimensions are presently unknown since they are in the early
design stages.
2.	Six (6) nitrogen release tanks. The exact dimensions
are presently unknown since they are in the early design stages.
3.	Twenty-two (22) denitrification sedimentation tanks,
each 265 feet long, 80 feet wide and 16 feet deep.
VII. Phosphorus Removal
Phosphorus removal is accomplished in two points in the system:
1.	Secondary sedimentation
2.	Nitrogen release tanks
B5

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The removal is by chemical precipitation and subsequent removal will
produce sludges in the various basins. Materials used as precipitants in
this plant are alum or ferric chloride and polymers.
1.	Alum is a phosphorus precipitant. The aluminum
ions combine with the phosphate ions to form
aluminum phosphate, an insoluble precipitate.
2.	Ferric chloride is a phosphorous precipitant.
The ferric ions combine with the phosphate ions
to form ferrous phosphate, also an insoluble
precipitate.
Alum and/or ferric chloride is added to the wastewater at the
influent to the secondary clarifier and the precipitated sludge containing
phosphates is settled in that unit.
At the nitrogen release tanks, alum or ferric chloride is added to
precipitate the phosphorous. Polymer may be added to coagulate the
phosphorous precipitate which is settled out of the wastewater and
removed from the denitrification sedimentation tanks.
Additional facilities for phosphorous removal consist of chemical
storage and feed equipment.
VIII. Filtration and Disinfection
Effluent filtration will be accomplished by the use of mixed media
filters.
Mixed media filtration refers to filtration through filter beds in
which the filter media is stratified from large to small particle size in
the direction of flow. Mechanically, this is accomplished by utilizing
media of different specific gravities.
B6

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This process removes almost all remaining solids as well as much of
the residual BOD, phosphorous, and nitrogen from the water.
Chlorine contact chambers are constructed under the filter beds. At
this point, sufficient chlorination takes place to kill all nitrifying
organisms and almost all remaining bacteria.
Units involved in this phase of treatment include:
1.	Thirty-six (36) multimedia filters, each 40 feet long,
52 feet wide and 16 feet deep.
2.	Four (4) chlorine contact channels 840 feet long, 25
feet wide and 17 feet deep located beneath the multi-
media filters.
The total detention time in the plant is 24 hours at average flow.
The dimensions of the above-described units may be slightly altered as the
final design is prepared.
B7

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IX. Sludge Handling Facilities
a.	Sludge Thickeners
The sludge removed from the primary sedimentation basins will be
pumped to the six existing gravity thickening tanks. These thickening
tanks utilize a sedimentation process similar to that which occurs in
the clarifiers. Scum which forms on the surface will be removed by
skimmers and pumped with the thickened primary sludge to the sludge
blending tanks. The remaining liquid supernatant will be returned to
the existing primary clarifiers and pass through the complete treatment.
Excess activated sludge from the secondary, nitrification and de-
nitrification systems will be wastes to flotation thickening tanks for
concentration. Biological sludges such as the waste activated sludges
are usually lighter, more bulky and tend not to concentrate in gravity
thickeners. In the flotation tanks, air is supplied to the fluid. The
rising bubbles increase the buoyancy of the solid particles and cause
them to concentrate at the surface of the liquid in the tanks. The
concentrated sludge normally is withdrawn to the sludge blending tanks.
The liquid supernatant is returned to the aeration basins and passes
through the remainder of the treatment process.
Eighteen flotation thickening tanks are proposed, each 60 feet long,
20 feet wide and 12 feet deep.
b.	Sludge Blending Tanks
Four tanks for mixing together into a homogeneous mixture gravity-
thickened primary sludge, flotation-thickened waste activated sludge, and
skimmings from the primary and secondary clarifiers will be constructed.
These facilities are needed to produce uniform sludge feed to the de-
watering facilities. Each tank will be 44 feet in diameter and 20
feet deep.
B8

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c.	Vacuum Filters and Associated Facilities
The blended sludge is conditioned by adding chemicals before it is
dewatered to a non-fluid form on vacuum filters. The vacuum filter
consists of a cylindrical drum with a filter media covering the outside
surface. Internally, the drum is divided into drainage compartments
which connect to the filtrate system. About 20 to 40% of the drum is
submerged in the filter "pan" containing the sludge as the drum is
rotated. A sludge mat is formed on the filter media as a result of
a vacuum (10 to 26 inches mercury) applied to the drainage compartments
servicing this submerged portion. As the mat, or cake, rotates out of
submergence, vacuum and dewatering are continued. The cake is scraped
from the drum just before it would be submerged in the pan once again.
The dewatered cake is then passed by conveyor to the incinerators. The
liquid withdrawn (filtrate) is returned to the plant for complete treatment.
Thirty vacuum filters, each with an area of 600 square feet are
proposed as well as associated chemical handling and sludge conditioning
facilities.
d.	Incinerators
Eight 12 hearth, multiple hearth incinerators are proposed to
incinerate the dewatered sludge to an inert ash. Thar: operation and
air pollution control equipment are discussed in detail in Appendix c
and will not be discussed here.
The incinerators are designed so that they may be operated also
as drying facilities to reduce the quantities of sludge to be disposed
of. When operated in this manner, the resultant material is suitable for
disposal by plowing into crop land. The pathogenic organisms in the
sludge would be destroyed by the heat, however, the organic matter in
B9

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the sludge which has value as a fertilizer would not be destroyed.
When used only for drying, the incinerators would operate at lower
temperatures and it may be expected that lower levels of gaseous
pollutants would be produced. In addition, the ash particles
associated with incineration, would be virtually eliminated at the
source.
BIO

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APPENDIX C
SLUDGE INCINERATION

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TABLE OF CONTENTS
Page
Section I Introduction	CI
Section II Incinerator Description	C3
2.1	General Description	C3
2.2	Detailed Description	C3
2.2.1	Incinerator Operation	C3
2.2.2	Costs	C7
2.2.3	Incinerator Control	C8
2.3	Design Parameters	C9
Section III Incinerator Evaluation	Cll
3.1	Introduction	Cll
3.2	Emission Characteristics	C12
3.2.1	Mass Emission Determinations	C12
3.2.2	Unissions vs. Standards and Regulations	C13
3.3	Effect of Emissions on Air Quality	Cl6
3.3.1	Meteorological Background Information	Cl6
3.3«2 Air Quality (N0X, Particulates, S02)	C21
3.3.2	a. Related to Mass Emissions	C21
3.3.2	t>. Related to Diffusion Estimates and
Statistical Studies	C23
3.3-2 c. Sunmary	C2J
3.3.3	Air Quality (Other Pollutants)	C28
3.4	General Considerations	C29
i

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Page
3A.1	Odor	C29
3.^.2	Noise	C29
3.^.3	Aesthetics	C29
3A.il-	Living Organisms	C30
3.^.5	Water Pollution	C30
3.b.6	Thermal Pollution	C30
3.5	Operation	C31
Section IV Findings and Conclusions	C32
U.l	General	C32
k.2	Mass Emissions	C32
^.3	Air Quality	C32
Costs	C33
4.5	Operation	C33
k.6	Other	C33
Supplement No. 1	Emission Calculations	C35
Supplement No. 2	Area Increases in Bnissions	C38
Supplement No. 3	Diffusion Calculations	C39
ii

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LIST OF FIGURES
Page
1.	D. C. Sludge Incinerator Process Flow Diagram	Cb
2.	Incinerator Efficiency Studies	C6
3.	Seasonal Wind Roses - Washington, D. C.	C17
k. Annual Wind Rose - Washington, D. C.	Cl8
5. Mean Summer Temperature, Washington Metropolitan Area	C20
iii

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APPENDIX-C, SLUDGE INCINERATION
SECTION I - INTRODUCTION
The disposal of sludge from sevage treatment plants has been limited to
3 "basic alternatives. These are ocean dumping, land disposal, and incineration.
In October 1970, the Council on Environmental Quality recommended in its "Ocean
Dumping - A National Policy," that ocean dumping of sludge should be phased out
as an ultimate disposal practice. The sludge from the Blue Plains Sewage
Treatment Plant has actually never been "ocean dumped." The choices presently
available are, therefore, to employ some form of land disposal or to incinerate
the sludge.
The purpose of this appendix is to examine the impact on the environment
of the sludge incineration alternative. Trade-offs with other alternatives
are discussed elsewhere in this report. At the outset, it must be recognized
that any alternative will result in some pollution and must be evaluated in
terms of the environmental degradation which inevitably will result. For
incineration, the prime concern is its inherent potential for air pollution.
In evaluating the incineration alternative, criteria in the following
categories were considered:
a.	Incinerator effluent in relation to emission standards and regulations.
b.	Impact of incinerator effluent on air quality.
c.	Guidelines developed from Environmental Protection Agency studies.
d.	General considerations based on engineering Judgement.
CI

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The design characteristics and description of the proposed incinerator
are given in the following section of this appendix. This information has
been provided by and reviewed with Whitman, Requardt, and Associates, the
engineering firm contracted for the engineering design of the incinerator by
the District of Columbia's Department of Environmental Services. Subsequent
sections of the appendix contain performance evaluations and summary findings
concerning the use of the sludge incineration process.
C2

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SECTION II - INCINERATOR DESCRIPTION
2.1	General Description
The incinerator will consist of 8 multiple-hearth furnaces, of which
a maximum of 7 are on-line and one on standby, each having a maximum capacity
of 6,860 pounds per hour (#/hr) dry solids, at up to 82$ moisture as fired.
Primary pollution control equipment consists of a high-energy venturi scrubber
for particulates and a direct flame afterburner for visible plume attenuation
and odor control.
The design of the incinerator will be completed by July 31> 1972, with
construction anticipated to begin by October 1, 1972 and completed by July 1, 197^-•
2.2	Detailed Description
2.2.1	Incinerator Operation (Refer to Figure l)
Raw sludge is generated by other portions of the waste treatment
plant which handles predominantly residential waste matter from the Washington,
D. C. Metropolitan Area. By means of conveyors, this sludge is fed into multiple
hearth furnaces where it is incinerated with the aid of auxiliary fuel. (No. 2
fuel oil or, if available, natural gas. The exhaust gas from this process will
be cooled from approximately 700°F to l8o°F by evaporative cooling using
filtered plant effluent water. Upon leaving the evaporative cooling section,
the cooled exhaust gas will be cleaned in a high energy venturi scrubber
automatically maintaining a constant 1*0 inches water gage pressure drop to
remove particulates and further condense gaseous compounds in the exhaust.
The cleaned exhaust gas will then pass into a sub-cooler where further condensing
of gaseous compounds and water vapor will occur in order to minimize the quantity
of water vapor in the exhaust gas before further treatment. All condensed
C3

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EXHAUST TO ATMOSPHERE
D.C, SLUDGE INCINERATOR
PROCESS FLOW DIAGRAM
Figure 1

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water vapor and scrubber effluent from the vet cleaning portion of the process
will be collected and routed to the head of the waste water treatment plant
for cleaning in the normal plant process.
Under some conditions of temperature and humidity a white plume
of water vapor will be evidenced if no further treatment is applied. Also,
the District of Columbia Department of Sanitary Engineering sponsored
independent tests on exhaust gases from similar furnaces at another installation
in the U.S. and determined that further treatment is required to remove a small
quantity of hydrocarbons present in the exhaust stream. Furthermore, the
location of the plant near the geographic boundary with the State of Maryland
created a desire to meet both Maryland's and D.C.'s emission standards,
including those for visible emissions. Although steam vapor plumes (resulting
from uncombined water) are specifically exempted from opacity regulations, the
afterburner will also satisfy aesthetic desires to eliminate all visible plumes.
For these reasons the scrubbed and cooled gases are passed through a
direct flame contact fume-furnace (utilizing auxiliary fuel) which is designed
to burn any carry-over gaseous compounds from the exhaust gas stream and reheat
it. The temperature will be raised sufficiently to ensure that no visible
water vapor plume will be evidenced at the point where the cleaned gases are
emitted to the atmosphere where they will quickly mix with the ambient air.
This reheating also facilitates plume rise which aids in diffusion of pollutants.
By exposing the total gaseous products of combustion to the flame of the after-
burner, a 0.5 second detention time in the unit was determined to adequately
complete the burning of any combustible compounds remaining in the exhaust.
(See Figure 2).
C5

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RESEARCH FUME INCINERATOR
INCINERATION EFFICIENCY STUDIES
OF A.P.CO. IN-LINE DESIGN
NOMINAL TEST CONDITIONS
CONTAMINANT: TOLUENE
INLET CONC: 3000 PPM CARBON
INLET TEMP: 600° F.
FLOW RATE: 1380 SCFM
RESIDENCE TIME: O.33 SEC.
FIGURE Z	INCINERATION EFFICIENCY STUDIES OF AIR
11 1	PREHEATER IN-LINE DESIGN OF DIRECT-FLAME r
TTtrmrn tut/^ imintA m^T^.	L»0

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Ventilation exhaust air from the entire solids processing building
is collected in an equalizing plenum from which the furnace combustion air
is drawn in order that any odors entrained in the building ventilation air
will be destroyed in the combustion process. Additional combustion air
which may be required will be drawn into the system through a "one way"
connection to a stack on the equalizing plenum above the incinerator roof
level. In the event that the ventilation exhaust gas quantity exceeds the required
furnace combustion air quantity, the excess will be diverted to one of the heat
exchanger fume furnaces where any odors will be destroyed by direct flame
contact.
There has been no operating by-pass capability provided in the air
pollution control system. This makes it impossible to operate the furnaces
without having the exhaust gases pass through the entire air pollution control
equipment arrangement. An emergency relief has been provided for the protection
of the plant personnel and equipment under extreme emergency conditions to
prevent an in-plant catastrophy until normal shutdown procedures can be
accomplished.
The residual ash is collected from the bottom of the furnaces for
ultimate disposal at a landfill site or possibly for use as construction
material. Transport of the ash will be by means of closed trucks or rail cars.
2.2.2	Costs
The system described is costly to install and will be costly to
operate because of the power and fuel requirements. Total capital costs are
estimated to be $21,250,000 and total operating costs at $3*737*000 year.
C7

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The system represents the maximum limit of presently proven air pollution
control technology and is expected to meet both the State of Maryland and
the proposed District of Columbia emission standards for the process when
tested with the procedures recommended by the Office of Air Programs of the
Environmental Protection Agency. The total incinerator facility anticipated
horsepower requirement is 5>^00 under normal operating conditions and the
electrical power is estimated to cost $378,000 annually, of which approximately
$88,000 can be attributed to the fume-furnace afterburner operation for odor
control and plume attenuation. The estimated annual consumption of No. 2
fuel oil in the sludge incineration process is estimated to cost $2,600,000,
of which approximately $620,000 is attributed to the fume-furnace for odor
control and plume attenuation. If natural gas were available, the estimated
cost would be reduced by approximately 1*0 percent at present fuel prices.
These annual costs are based on burning sludge at an average rate of 865,000
pounds of dry solids per day.
2.2.3	Incinerator Control
The incinerator furnaces will be controlled by a combination
automatic and manual system with combustion air being automatically regulated
by residual oxygen in the exhaust gas. This automatic system will be backed up by
a manual system monitored by metering the carbon dioxide in the exhaust gas.
In order to take full advantage of this refined control system, the design
engineer will prepare an operating instruction manual and be available for
initial and continued operator training to maintain maximum operator efficiency
that is necessary with the normal employee promotions and attrition.
C8

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3	Design Parameters *
No. of furnaces
No. of furnaces on line
Furnace diameter
Stack diameter
Stack height
No. of hearths/furnace
Hourly capacity/furnace
Maximum
Average
Minimum
Exhaust gas residence time
combustion chambers
@ Temperature of
Exhaust gas residence time in fume-
furnace afterburner
@ Temperature of
Effluent flow rate through flue (75$
excess
@ Temperature
@ Velocity
Flow @ STP, dry
Excess air:
Normal
Minimum
Maximum
Provided "by Whitman, Requardt & Associates
C9
8 (l is standby)
5-7 (depending on
throughput)
25*
5*
110*
12
6,860 #/hr (dry solids)
5,150 #/hr (dry solids)
3^30 #/hr (dry solids)
2 sec minimum
1700°F
0.5 sec minimum
1500°F
36,700 CFM
520°F
i860 FPM
18,300 CFM
75*
50#
150$

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Auxiliary fuel:
Type
Amount
Control Equipment
Type (for particulates )
Pressure Drop
Type (for moisture)
Oil
Gas
#2 Fuel oil or,
if available, natural gas
0
2 to gal/nr/furnace, and
78 gal/hr afterburner
or.
[32,800 ft. 3/hr/furnace,
and 10,too ft.3 ,/hr/
afterburner
Venturi Scrubber
^O" W.G., constant
Subcooler
Type (for odor control & plume attenuation) Direct flame afterburner
C10

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SECTION III - INCINERATOR EVALUATION
3.1 Introduction
The predicted levels of gaseous and particulate effluents from the
various portions of the proposed incinerator are based upon the following:
a.	Design parameters listed in the previous section.
b.	Tests and/or evaluations by the designer of various system
components similar to those proposed herein.
c.	Results of sewage sludge incineration studies performed by the
Environmental Protection Agency (Reference 1).
These predicted levels are listed in Table 3-1 below. The results of
the mass emission determinations of the major effluents for the entire
facility which are based on these levels are summarized in Table 3-2.
Appropriate calculations to support these values are given in Supplement
No. 1 of this Appendix.
TABLE 3-1, EMISSIONS PER FURNACE
(POUNDS PER MINUTE)
Location
NO
X
so2
Particulates
Furnace



Outlet
0.2
1 *
8
Scrubber



Outlet
0.2
0.1
0.024
Subcooler



Outlet
0.11
0.02
0.02
Fume Furnace



Outlet
0.11
0.11
0.04
* Per Reference 1, the sludge contribution to SO2 is a negligibly small
fraction of the auxiliary fuel oil contribution because sludge sulfur
content is primarily in the form of non-combustible sulfates.
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3.2 Emission Characteristics
3.2.1 Mass Emission Determinations
TABLE 3-2, QUANTITIES OF MAJOR EFFLUENTS
Effluent
Anticipated Concentration
in stack @ STP, dry
Pounds/Day
+ 33%*'
Tons/Year
NO
X
50 ppm
1085

197.4
Particulates
Furnaces
0.009 grains/SCF
(ASME Test Method)
237

43.3
Afterburner

196

35.7
SO Furnaces
2

202

36.7
Afterburner ^

930

169
CO
^ Essentially zero,
see note
(b)
	~
Organic Compounds
(PCB's, DDT, etc.)
^ Essentially zero,
see note
(c)

Hg
¦
2.596

0.474
PbU)
*
2.133

0.390
* Values listed for average incineration rate. Tolerances reflect
variations in sludge throughput rate.
Notes:
Ca) Due to combustion of #2 fuel oil, limited to 0.5% S (July, 1975).
(b)	Automatic combustion control for Oxygen is expected to provide for
appreciably no CO. A C0^ monitoring instrument in conjunction with
manual control will provide a backup.
(c)	The direct flame fume afterburner will destroy essentially all organic
compounds (See Reference 1 and Figure 2).
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(d)	Weight of mercury in form of vapor or volatile compounds such as
mercuric oxide is based on an Hg concentration of 3 ug per gram of
sludge at Lorton, Va. (See Reference 1). It is assumed that Blue Plains
sludge will have a similar concentration and that all the mercury in
the sludge is emitted into the atmosphere.
(e)	Weight of lead as part of lead compounds is based on a lead concentration
of 9 mg/g in stack particulates at Lorton, Va. (See Reference 1). It
is assumed that Blue Plains particulate emissions upstream from control
equipment will have a similar concentration.
3.2.2 Emissions vs. Standards and Regulations
Federal
At the present time there are no Federal emission standards which apply
to Sludge Incinerators. The standards expected to be proposed are as
follows (Reference 2):
"1. Particulate emissions to the atmosphere are to be no more than
2. Visible emissions shall be less than 10 percent opacity. (This
does not include condensation effects of uncombined water)."
The predicted emissions from the Blue Plains incinerator plant are as
follows:
The No. 2 oil which is presently proposed as auxiliary fuel in the afterburner
will increase the particulate emissions. Although auxiliary fuel effects were
2.0 pounds per ton of solids fed to the incinerator. The feed
rate is to be expressed on a dry basis.
Particulate Output
Dry Sludge Input
158,000 Tons/Year
43.3 Tons/Year
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not included in the 2 lb/ton requirement and auxiliary fuel emissions are
exempted per DC Regulation 8-3:607d the total Output/Input ratio was
calculated to be 43.3 + 35.7 tons/year = 1.0 lb/ton
158,000 tons/year (dry)
No visible emissions will occur on the basis of the design of the
exhaust gas treatment system and afterburner. (Opacity would still be
less than 10% if the afterburner were not incorporated in the design)
There are no other Federal emission standards applicable to sludge
incineration which are presently contemplated.
Local D. C. Regulations
(a) Present District of Columbia Regulations which apply to a new
incinerator source are as follows:
Regulation	Subject	Requirement (Abbreviated)
8-3:607d
Incinerator Particulate
Emissions
0.01 gr/scf, dry
12% CO^, Max. 2 hr. avg.
8-2:706
Fuel Burning Particulate
Emissions
Computes to be .065 #/min
8-2:711
Visible Emissions
20% opacity discounting
uncombined water
8-2:715
Odors
No. 2 on Barneby-Cheney
Scentometer
8-2:716
Test Methods
Particulates:
ASME Test Code,PTC21-1941
ASME Test Code,PTC27-1957
Visible Emissions:
Ringlemann Chart
Odor: Barneby-Cheney
Scentometer

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The predicted emissions from the Blue Plains incinerator plant
are as follows:
Particulates (Incineration with gas-fired afterburner):
0.009 gr/scf, dry, 12% CO^,
Max 2 hr. avg. (43.3 Tons/Year)
Particulates (from oil-fired afterburner):
0.0195 lbs/min
(35.7 Tons/Year)
Visible Emissions: No visible emissions will occur on the basis
of the design of the exhaust gas treatment
system and afterburner
Odors: No odors will emanate from this plant on the basis of the
ventilation system design, incineration temperatures and
operation of fume-furnace (afterburner).
(b) Sulfur dioxide emissions resulting from burning fuel oil are
to be limited by use of fuel oil containing not more than 0.5%
Sulfur by weight per Regulation 8-2:704.
Sulfur dioxide emissions will be limited by the above
requirement if natural gas is unavailable as a fuel for the
incinerator and afterburner.
C15

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3.3 Effect of Emissions on Air Quality
3.3.1 Meteorological Background Information
The geographic area of this study is a tri-state area consisting of
Montgomery and Prince George's Counties in Maryland; the Virginia Counties
of Arlington and Fairfax; the independent Cities of Alexandria, Falls
Church, and Fairfax; and the District of Columbia. The discussion in the
paragraphs below provides the basis for determinations of pollutant
concentrations which follow.
Metropolitan Washington is situated at the western edge of the
Atlantic Coastal Plain, 35 miles west of Chesapeake Bay. The Blue Ridge
Mountains rise to 3,000 feet about 50 miles to the west and affect
Washington's weather by markedly warming and drying winds from the west.
The coastal plain to the east is essentially flat. Although no topographic
barrier exists between the area and Chesapeake Bay and the Atlantic Ocean,
the city is too far inland to be affected by the summer sea breezes.
The terrain of the city itself varies from sea level to slightly over
400 feet. Bluffs along, the Potomac River and Rock Creek, and to the
southeast and east of the Anacostia River suggests some channeling of the
airflow, but, generally, the terrain does not seriously impede the free
movement of air about the city.
Surface winds as measured at the National Airport, which has an
excellent exposure for wind measurements and which is also near the center
of the metropolitan area, are most frequently from the northwest during the
colder months and south and southwest during the warmer months. Wind roses
for each season and the year are shown in Figures 3 and 4.
Cl6

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xx£
(Figures on
radials are
average speeds.
Figure in center
is percentage of
calm)
FIGURE 3 Seasonal Wind Roses -
Washington, D.C., National Airport
inn	i Ci£.ri

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Cl8

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All meteorological elements are influenced to some extent by cities.
There are several causes for the differences between urban and nearby
rural climates. The reflection, radiation, and evaporation characteristics
of the swamps, meadows, forests, and fields typical of rural areas are
quite different from corresponding characteristics of the buildings and
streets of asphalt, brick, concrete, and steel in the cities. The roughness
of the surface varies between rural and urban areas. Winds are usually
somewhat stronger in the rural areas. The combustion processes that
take place in the city emit a sizeable quantity of heat. Finally, the
Justs, gases, and vapors emitted in the city change the composition of the
jrban atmosphere.
Woollum has made detailed analyses of maximum and minimum temperatures
it 13 to 29 points in the metropolitan Washington area. He has shown that
ninimum temperatures in rural areas average 4°F to 5°F cooler than those
Ln the vicinity of the Washington National Airport. His studies show that
naximum temperatures tend to be higher in the northwest portion of the
)istrict near the Potomac River and in the northeast portion along the
^nacostia River. Figure 5 shows the results of some of his analyses.
An analysis of wind data at the Dulles International Airport, Washington
lational Airport, Andrews Air Force Base, Suitland and CAMP stations,
friendship International Airport and meteorological towers at Silver Hill
md Tysons Corner conducted by the Division of Meteorology (then part of
IAPCA) in 1967 did not reveal a consistent circulation that might be
ttributed to the variations in temperatures.
The nighttime stability in the city center should be less and inversions
nd stable layers more frequently elevated than in rural areas. Pollutants
C19

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WASHINGTON METROPOLITAN AREA
»» oc
High Temperature
Low Temperature
M^ure 5 Mean Summer (June, July, Aug.) Temperature, °F.
C20

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emitted at building-top level in the city would tend to accumulate somewhat
above street level and then be brought to the surface the following morning.
In rural areas, it would be somewhat easier to emit pollutants above the
low-lying inversion, where they would be susceptible to better dispersion.
The microclimatology of the metropolitan Washington area showy the
same urban influences as other major cities. It does not seem to have any
unusual patterns which would contribute to particular zones of pollutant
buildup.
3.3.2 Air Quality Determinations
a. Related to Mass Emissions
The potential impact of the mass emissions of N0X, SC^, and particulates
upon the air pollution burden from sources within the District of Columbia
is shown in Tables 3-3, 3-4, and 3-5 below. In order to facilitate an
understanding of the magnitude of the problem, limiting conditions for
emission projections are shown in these tables. The effects upon predicted
air quality of this additional burden on the metropolitan area will be
discussed shortly.
TABLE 3-3, NO BURDEN (D.C.), TONS/YEAR
x
Condition
Baseline*
Without Blue
Plains
Incinerator
With Blue Plains
Incinerator
(gas or oil-fired
fume furnace)
Percentage
Increase
Current estimate,
Jan. 31, 1972
44,311 T/Y
45,509 T/Y
0.45%
Estimate for July
31, 1975, assuming
50% Stationary
Source Control on
Jan. 31, 1972
42,983 T/Y
43,181 T/Y
0.46%
Estimate for July
31, 1975, assuming
0% Stationary
Source Control on
Jan. 31, 1972
29,798 T/Y
29,996 T/Y
0.67%
* See D.C. Implementation Plan
Jan. 1972
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TABLE 3-4, S02 BURDEN (D.C.), TONS/YEAR
Condition
Baseline*
Without Blue
Plains
Incinerator
With
Blue Plains
Incinerator
(gas-fired
fume furnace)
Wi th
Blue Plains
Incinerator
(oil-fired
fume furnace)
Maximum
Percentage
Increase
Current estimate,
Jan. 31, 1972
57046 T/Y
57083 T/Y
57252 T/Y
0.36%
Estimate for
July 31, 1975
with full
control strategy
28523 T/Y
28560 T/Y
28729 T/Y
0.72%
* See D.C. Implementation Plan
Jan. 1972
TABLE 3-5, PARTICULATES BURDEN (D.C.), TONS/YEAR
Condition
Baseline*
Without Blue
Plains
Incinerator
With
Blue Plains
Incinerator
(gas-fired
fume furnace)
With
Blue Plains
Incinerator
(oil-fired
fume furnace)
Maximum
Percentage
Increase
Current estimate
Jan. 31, 1972
19575 T/Y
19618 T/Y
19654 T/Y
0.4%
Estimate for
July 31, 1975
with full
control strategy
4133 T/Y
4176 T/Y
4212 T/Y
1.9%
* See D.C. Implementation Plans of
Aug. 1970 & Jan. 1972
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The percentage increase in the pollution burden for the metropolitan
area (as defined in paragraph 3.3.1) is even less than it is for D.C.
Calculations based on emission inventory summaries given in the Implementation
Plans for Virginia, Maryland, and the District of Columbia show the maximum
percentage increase to be as presented in Table 3-6.
TABLE 3-6, MAXIMUM EMISSION INCREASE - D.C. & METROPOLITAN AREA,
IN PERCENT *
^^ollutant
Locale
NO
X
Particulates
SO
2
D. C.
0.45%
0.407.
.36%
Metropolitan
0.113%
0.165%
.085%
Area



* Based on estimates of current
emissions listed in Implementation
Plans of Jan. 31, 1972. See
Supplement No. 2
As can be seen from the above table, the output of NO , SO and
X	z.
particulates by the proposed incinerator would be very small. To make an
accurate quantitative estimate of their effect on ambient air quality is
impossible because the magnitude of errors involved in modeling is much
larger than the effect produced by this relatively small additional source,
b. Related to Diffusion Estimates and Statistical Studies
An alternative method of estimating effects of emissions on air quality
was then considered. Diffusion estimates, using two contrasting sets of
data, were made to estimate 1 - hour ground level concentrations downwind of
the incinerator. Using statistical data these were then converted to long
C23

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term (1 year) averages in order to permit evaluations against national
standards. One hour averages were assumed so that minor short-term variations
would be averaged out and large scale changes in the synoptic conditions
would not have time to develop. The equations used are given in Supplement
No. 3.
In the first case, an unstable atmosphere with a high wind was assumed
in order to give high concentrations near the plant.
Specifically, the following was assumed:
Stability	B
Wind Speed	6 meters/second (13.4 mi./hr.)
Effective Stack Height	59 meters
Mixing Height	1500 meters
This yielded down wind values of:
Distance	Particulate	N0„
A
3
250 meters	4.5 ug/m	.0097 ppm
1500 "	8.6 "	.018 "~1
1000 "	3.6 "	.008 "
2000 "	1.04 "	.002 "
In the second case, a stable atmosphere with very light wind was
assumed. This yielded a smaller maximum further from the plant.
Stability	D
Wind Speed	2 meter/second (4.5 mi./hr.)
Effective Stack Height	104 meters
Mixing Height	450 meters
C2h

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Distance	Particulate	NO^
250 meters	zero	zero
500 "	zero	zero
1000 "	.31 ug/m^	.0007 ppm
2000 "	3.8 "	.0081 "
)3000 "	4.9 "	.011 " 1
4000 "	4.7 "	.010 11
Certain meteorological conditions will produce higher concentrations
than these for short time periods. Such conditions might be caused by
strong turbulence which causes the plume to loop down to the ground; or
by the break up of a low level inversion causing a fumigation. These
higher levels of air pollution concentration will be of short duration, will
not occur frequently, and when they do happen are expected to be confined
to the plant boundary.
By considering the historical records of pollutant measurements, one
can statistically relate the frequency distribution of measurements to
various averaging times. This has been extensively studied by Larsen, who
has reported on his findings in a number of publications. In "A Mathematical
Model for Relating Air Quality Measurements to Air Quality Standards"
(Reference 4) Larsen presents the following data which was extracted from
a table of N0X data taken in Washington, D. C. from 1962 to 1968.
C25

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TABLE 3-7 *
NITROGEN OXIDES CONCENTRATION (PPM) AT WASHINGTON, D. C. CAMP STATION

Percent
of time concentration
is exceeded



.01
.1
1
10
30
50
70
90
Averaging
Time








5 min
1.00
.70
.38
.14
.07
.05
.03
.02
1 hr
.97
.71
.38
.14
.07
.05
.04
.02
8 hr

.54-
.31
.13
.07
.05
.04
.03
1 day


.25
.12
.08
.06
.05
.03
1 mo



.10
.08
.06
.05
.04
1 yr





.07


*
The values given in the table are the measured concentrations exceeded
a certain percent of the time. For example, the table shows that on 1% of
the hours in the year, the one hour average of N0X is greater than .38 ppm.
Under these conditions, the annual mean is .07 ppm.
The meteorological parameters used above were chosen to give high
ground,level values of pollutants, but it is realized that worse conditions
do exist from time to time. By making the assumption that conditions more
extreme than the ones chosen will not occur more frequently than one hour
every four days (or approximately 1% of the time) and that the distribution
of pollutant concentration levels will be in ratios similar to the variations
shown in Table 3-7 the annual mean local contribution of the incinerator can
be estimated. Using this method, the annual contribution of N0^ will be a
maximum of .003 ppm.
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Similar calculations were made for annual contribution of
particulates and sulfur dioxide using statistical data from Reference 4
that apply to those pollutants. Their contribution (along with N0X) to
values of annual concentrations are shown in Table 3-8 below.
TABLE 3-8, INCINERATOR POLLUTANT ANNUAL MEAN LOCAL CONTRIBUTION
Pollutant
Concentration*
Downwind
Distance, Meters
Percent of
Primary Std.
Percent of
Secondary Std.
N°x
.003 ppm
500
6.65%
6.65%
Particulates
3
1.4 ug/m
500
1.85%
2.3%
so2
.0025 ppm
400
12.5%
8.3%
* Too small to be measured directly
c. Summary
The two methods discussed above - one which considers the overall effect
of the incinerator on the city and the other which looks at the local
effects - show that the contribution of pollutants to the area's air will
neither meaningfully deteriorate the overall air quality nor present
any detrimental local problems. It is realized that the methods used
to arrive at these conclusions are necessarily crude, but the state of
the art has not yet advanced to the point where much more accurate
answers are available. At this time, it is believed that any more complex
modeling of the problem would only serve to compound the errors. Other
assumptions could be made and other approaches used which could lead
to equally proper, but different numbers. Properly calculated, they
C27

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would be no more "right" or "wrong" than what is developed here, but
only would show the difficulty at arriving at one set of exact answers.
The important result is not the exact amount of pollutant at a particular
point for a particular time, but an estimate of the magnitude of the
effect of this incinerator. This has been done here and has shown that
the expected effects on air quality will be very small.
3.3.3 Air Quality (Other Pollutants)
The proposed emission standard for mercury is 5 lb./24 hrs.
Although this standard applies only to facilities producing mercury
from ore and mercury cell chlor-alkali plants (see Reference 7),
a comparison of the anticipated emissions from the Blue Plains
incinerators against this proposed standard shows that it will be
approximately \ of the standard. Since the project area is not known
to have plants such as those covered by the standard, it is anticipated
that the small quantity of mercury compounds that may be emitted by the
incinerator will have a negligible effect on any atmospheric concentrations
of mercury compounds. Calculations show that such concentrations are
expected to be well below 1 ug/m , which is sufficient to protect the
public health from illness due to inhalation of mercury compounds.
(see Reference 7).
Presently, no standards exist for emissions of lead from stationary
sources, or for lead concentrations in the ambient air. Since the
amount of lead emitted is even less than that of mercury, it is felt
that its impact on air quality will also be negligible.
With respect to organic compounds in the gas stream, the direct-
flame afterburner is designed to totally eliminate any possible emissions
of these (see Section 2.2.1 and Figure 2).
C28
I

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3.4 General Considerations
3.4.1	Odor
A fume-furnace afterburner associated with each of the 7 operating
incinerators has been incorporated in the design of the facility.
The afterburner is intended to destroy any remaining odor-causing
products which may have become trapped in the exhaust gas stream or
in the exhaust air of the solids processing building. The combustion
time/temperature relationship (0.5 seconds/1500°F) is sufficient to
ensure destruction of any such substances. (Also see paragraph 2.2.1)
3.4.2	Noise
There is no equipment required by the sludge incineration process
which offers any unusual noise potential and the normal equipment and
operating noise will be contained in the building. The air-conditioned and
enclosed operating room will offer protection for the plant operators
from even the normal process equipment noise within the building.
3.4.3	Aesthetics
Aesthetic degradation of the environment will occur as a result of
the appearance of four stacks (one for each pair of furnaces) protruding 20
beyond the building profile. The operation of the sub-cooler
and afterburner will be such as to remove visible-flume causing moisture
and to reheat the exhaust gas stream to further ensure no visible water
vapor plume. The particulate loading of the exhaust gas stream
(aggravated by an oil-burning afterburner) will be sufficiently low that
if no afterburner were used, a less than 10% opacity plume would result.
C29

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3.4.4	Living Organisms (See Reference 8)
The destruction of most pathogens is assured by the high temperatures
in the incinerator, ranging from 300°F to 1700°F in the various hearths.
The duration of burning of the sludge at these temperatures is approxi-
mately one hour. Any pathogens in the exhaust gas stream will be subjected
to the same temperatures, with the incinerator design ensuring a residence
time of at'least 2 seconds at the maximum temperature of 1700°F. Thus,
neither the gas 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.
3.4.5	Water Pollution
The entire quantity of evaporative cooling water and scrubber
water required in the exhaust gas cleaning process will be returned to
the head of the plant where it will receive the same treatment as the
standard plant influent. The water discharged from the sub-cooler will
be introduced into the plant effluent sewer at a point where it will be
mixed thoroughly before it leaves the plant and no additional pollution
load is anticipated from the mixing of the sub-cooler effluent with the
normal plant effluent.
3.4.6	Thermal Pollution
The volume of process water from the cleaning and sub-cooling
process associated with the sludge incineration will have a minimal
effect on the overall plant effluent water temperature. If the total
heat input is considered added to the normal plant effluent, it is
anticipated that the total effluent temperature will be raised
approximately 3°F. However, the dirty portion of the process water
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is returned through the plant cleaning process and it can be expected
to receive some cooling. It is reasonable to expect that only the
sub-cooler discharge heat will affect the normal plant effluent
temperature. This effect is estimated to raise the effluent temperature
approximately 2°F. before it enters the river.
3.5 Operation
The proper operation of the sludge incinerator with its manual
and automatic controls will require well-trained operators. It will
be necessary for the operators to be trained both initially and recur-
rently. To this end, the incinerator designer will prepare an operating
manual.
Sufficient flexibility is incorporated in the incinerator design
to permit shutting down of one furnace* without affecting normal operation
(i.e. at average feed rate). If circumstances forced the shutting down
of two furnaces* simultaneously, the minimum feed rate could still be
maintained, as indicated below:
TABLE 3-9, FEED RATE, DRY SOLIDS
	3,430 #/hr (min) 5,150 #/hr (avg) 6,860 #/hr (max)
Number of furnaces
normally operating	7 or 5	7	7	
* Since an eighth furnace is on standby, this actually represents the
failure of one more furnace than stated.
a) If long-term operation at the minimum feed rate is anticipated, two
furnaces would be deliberately shut down. For a similar operation of
only short duration, all seven furnaces would continue to operate.
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SECTION IV - FINDINGS AND CONCLUSIONS
4.1	General
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
engineering judgment - the degradation has fallen within acceptable
limits. The obvious air pollution due to incineration has been quan-
tified for every pollutant that is emitted in a predictably significant
amount using the best available evaluation tools. The water quality
and temperature effects on the Potomac and the general aesthetic,
pathogenic, odor, and noise aspects were also evaluated. The solid
waste residue in the form of ash was also considered. It is necessary
that all of these forms of pollution be compared with those that re-
sult from other disposal means in order to ensure that the most
rational decision in favor of the environment be made.
4.2	Mass Emissions
Mass emissions of the major pollutants, oxides of nitrogen, par-
ticulates, and sulfur dioxide, show potential percentage increases for
the District of Columbia which are less than \ percent. Those percen-
tages for the metropolitan area are correspondingly reduced - by a
factor of approximately 4 to 1. Trace, but predictable amounts of
the toxic mercury and lead compounds may also be added to the atmos-
phere. Emissions of carbon monoxide and organic compounds will be
essentially zero.
4.3	Air Quality
The mass emissions of the major pollutants (N0X, particulates,
and SO2) were also related to air quality. The results show no mean-
C32

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ingful degradation can be predicted for the immediate vicinity, the
city, or the metropolitan area. Percentage degradation of ambient
air, using primary and secondary air quality standards as a baseline,
range downwards from 12^% - these at the local maximum points in the
vicinity which are generally expected to occur within either the con-
fines of the facility, or the air bases, or along the non-residential
areas along the eastern shore of the Potomac River. The potential
degradation at other locations rapidly falls off from the predicted
maximum sites.
4.4	Costs
Both capital and operating expenditures for the proposed incinerator
facility are high. This is attributable to the design of the equipment
at the limits of present day incinerator technology and to the high
levels of electrical and fossil fuel requirements. Future availability
of natural gas could save an estimated 40 percent of fuel costs.
Further savings could be effected by elimination of the afterburners
from the design at the expense of ensuring total destruction of organic
compounds, odors, and the total elimination of visible plumes.
4.5	Operation
Operation will require a reasonably high level of operator pro-
ficiency to complement the semi-automatic equipment. This is necessary
to maintain optimum combustion as conditions vary. Personnel must also
be capable of reacting quickly in emergency situations in shutting down
and transferring incineration from on-line to standby furnaces.
4.6	Other
Preliminary information suggests the distinct possibility that the
electrical power requirements for land disposal of sewage or sludge are
C33

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significantly greater than the incinerator's electrical requirements.
This is primarily attributable to the energy needed to pump the wastes
for great distances. Such excess electrical power can be converted
into units of pollution (for NO , particulates, and S0o) per unit of
x	z
power. The resulting air pollution burden must then be charged to
the land disposal alternatives before fair trade-offs can be made.
This is particularly important when considering the probability that
PEPCO, whose generating stations are in the metropolitan area, is
the most likely source of all required electrical power.
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SUPPLEMENT NO. 1 - EMISSION CALCULATIONS
I.	Nitrogen Oxides (NQy):
a.	Furnace emissions:
0.2 #/Min/Furnace, per Designer
By using the relationship that
ug NO /m^ = /ppm / X 10^ (Federal Register, 4/30/71)
X	5.32'
This is equivalent to 93 ppm, which is in agreement with EPA
information on multiple-hearth incinerator capabilities
(reference 1).
b.	System emissions:
50 ppm per Designer
By using the same conversion factor as above, this is equivalent
to 0.1073 #/Min/Furnace = 28.2 tons/year/furnace, X 7 Furnaces =
197.4 tons/year.
II,	Particulates:
a. Furnace emissions are 8#/Min/Furnace, per the Designer. The
maximum collection efficiency of the scrubber is 99.8%, per the
Designer. Therefore, emissions at the scrubber outlet are
0.016 #/Min/Furnace.
A more conservative efficiency, including a 50% safety factor,
is 99.7%. Thus, emissions are 0.024 #/Min/Furnace = 6.2 tons/
year/ furnace X 7 Furnaces = 43.3 Tons/Year.
Using appropriate conversion factors
0.024 #/Min/Furnace = 0.009 gr/SCF.
18,300 SCFM
C35

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Efficiencies of 99.7% or greater are achievable with a AO"
W.G. pressure drop scrubber, for a range of typical particle
sizes.
c. Afterburner:
Emission factor - 15	gallons (Ref. 3)
1.3 gallons/Min/Furnace (per Designer) X 15	Gallons
= 0.0195 #/Min/Furnace - 5»1 tons/year/Furnace
X 7 = 35.7 tons/year, total.
III.	Sulfur Dioxide (SOj :
a.	0.02 #/Min/Furnace, per Designer, = 5.2 tons/year Furnace
X 7 (Furnaces = 36.7 tons/year.
b.	Afterburner:
Emission factor » 142 (% sulfur) ijl0^ Gallons (Ref. 3).
D. C. regulations will require the use of 0.5% S fule on
7/1/75.
Therefore,
142 (0.5) X (1.3 gall/Min/Furnace) (per Designer) = 0.092
///Min/Furnace - 24.1 tons/year/Furnace X 7 Furnaces = 169 tons/
year.
IV.	Mercury (Hg):
Sludge burned in the Lorton, Virginia incinerator had 3 ug of Hg per
lg sludge. The Lorton, Virginia sludge incinerator is the nearest
of the sludge incinerators tested by EPA (Ref. 1) to Blue Plains.
It is anticipated that Blue Plains sludge will have a similar
concentration of Hg. Since none of the Hg remained In the ash at
Lorton, it appears that all of it was emitted through the stack.
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Therefore,
5150 ///Hr sludge/Furnace X 3 ug/g sludge X 24 Hrs/Day
= 0.371 ///Day/Furnace = 0.068 tons/year/Furnace X 7
Furnaces = 0.474 tons/year.
V. Lead (Pb):
The Pb concentration is also based on the Lorton, Virginia study
(Ref. 1). Particulates emitted at Lorton had a Pb concentration
of 9 mg/g. It is assumed that the Blue Plains particulate emis-
sions will have a similar concentration.
Therefore, using the 237 #/HR particulate emission value listed
in Table 3-2 of this Appendix, 237 #/HR X (9 X 103) = 2.133
///Day/All Furnaces
Similarly,
-3
43.3 tons/year X (9 X 10 ) g/g = 0.3897 tons/year
C37

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SUPPLEMENT NO. 2 - AREA INCREASES IN EMISSIONS
The emission inventory summaries given in the various state Imple-
mentation Plans submitted January 31, 1972 are listed below for N0X,
particulates, and SO2. These were used as a basis for computing maxi-
mum percentage increases to the metropolitan area pollution burden due
to the Blue Plains incinerator assuming it were in operation now.
N0V, T/Y Particulates, T/Y SOq, T/Y
Fairfax County, Virginia
23600
9400
_ *
Montgomery County, Md.
41600
6700
66000
Prince George County, Md.
45600
8200
70900
Alexandria, Virginia
12000
1200
_ *
Arlington County, Virginia
6600
2800
_ *
Washington, D. C.
44300
19600
57000
Virginia
-
-
48000*
173,700	47,900	241,900
* Total for Virginia Counties was obtained from 1972 Maryland Implementa-
tion Plan.
N0X percentage increase =	197/173700 = 0.113%
Particulates percentage Increase = 79/47900 = 0.165%
SO2 percentage increase =	206/241900 = .085%
C38

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SUPPLEMENT NO. 3 - DIFFUSION CALCULATIONS
Diffusion calculations were made using the standard gaussian plume
diffusion model assuming the plume is trapped under the stable layer
aloft and reflected at the ground. The equation that represents this
condition is:
dispersion coefficient (x - plane)
u = wind speed
z = height
H = effective stack height
n = number of reflections
L = mixing height
Values for andwere as presented by Turner (1969) in the "Workbook
of Atmospheric Dispersion Estimates" (Reference 5). Values for plume
rise were calculated using a method described by Briggs (Reference 6)
C39
5C ¦ ground level concentration
Q = source strength
Cfy= dispersion coefficient (y - plane)

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REFERENCES
1.	Report, Environmental Protection Agency, Task Force on Sewage
Sludge Incineration, January, 1972.
2.	Background Information for Proposed New-Source Performance
Standards, February, 1972.
3.	Compilation of Air Pollutant Emission Factors, February, 1972
(AP-42).
4.	"A Mathematical Model for Relating Air Quality Measurements to
Air Quality Standards", R. I. Larsen, PH.D., Environmental Protec-
tion Agency, November, 1971.
5.	Workbook of Atmospheric Dispersion Estimates, D. B. Turner,
Department of Health, Education and Welfare, Revised - 1970.
6.	"Plume Rise", G. A. Briggs, E.S.S.A., TID-25075, Library of
Congress Catalog Card Number: 72-603261.
7.	Federal Register, Volume 36, No. 235, December 7, 1971.
8.	"Microbiological Evaluation of Incinerator Operations", Mirdza
L. Peterson and Fred J. Stutzenberger, Applied Microbiology, July,
1969.
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APPENDIX D
SPRAY IRRIGATION

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APPENDIX D
SPRAY IRRIGATION
Description
An alternative to advanced waste treatment and sludge incineration
that will be considered in this Appendix of the impact statement is a
land disposal system. Basically, this method involves conveying
secondary effluent from an existing sewage treatment plant to a suitable
site for disposal by spray irrigation. Hopefully, irrigated effluent
would stimulate growth of agronomic crops and the wastewater would be
renovated to the level of tertiary effluent through various biological
and physical processes that naturally occur in the soil. The renovated
wastewater can be returned to the natural ground water supply or collected
in a series of underdrains or wells and transported to a centralized
discharge point.
History
In 1952, Pennsylvania State University initiated a program to
determine "(1) the feasibility of the year-round disposal of sewage
effluent on land, (2) the degree of renovation of sewage effluent by
means of biological, chemical, and mechanical processes in the soil,
(3) the extent of conservation of water by returning it to the ground
water supply, and (4) the effects of the application of effluent on
soils, crops, trees, and wildlife."^
(1) R. R. Parizek et al., Waste Water Renovation and Conservation,
The Pennsylvania State University Studies No. 23, University
Park, Pennsylvania, 1967, p. 9.

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Effluent was pumped from the joint University - Borough of State
College Sewage Treatment Plant to spray irrigation sites located in
the agronomy, forestry and gameland areas. The wastewater was distributed
to sprinkler areas via a fixed aluminum pipe irrigation system. The
sewage affluent was sprayed on both forest land and cleared agricultural
cropland at rates ranging from one to six inches per week. During the
winter months, research was conducted to determine the feasibility of
winter operation. An extensive monitoring system was established to
measure baseline conditions and the changes that later occurred in ground-
water quality.
After two years of operation, the researchers reached the following
major conclusions:
"1. With adequate information regarding the soil mantle and
underlying rock structure, the safe disposal of effluent on land
can be carried out under a wide variety of field conditions with
proper management.
2.	Irrigation of wastewater was accomplished in below
freezing weather.
3.	Effluent was renovated when applied at rates of one, two,
or four inches per week from April to December on agronomic and
forested areas. Ninety to ninety-five percent of the surfactants
were removed during passage through one foot of soil. Phosphorous
concentration was reduced by ninety-nine percent and nitrate by
sixty-eight to eighty-two percent.
D2

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4.	Approximately eighty percent of the water, when applied
from April to December at the rate of two inches per week, was
recharged to the groundwater reservoir...
5.	The quality of water in sand-point and deep wells at the
site showed no significant change...
6.	The harvesting of agronomic crops contributed to the
renovation of effluent through removal of nutrient constituents.
Agronomic crops... are superior to forest crops which recycle
some of the nutrients by redeposition of leaf and stem litter.
At the same time, economic benefits were obtained in the form of
increased yields ranging from seventeen to three hundred percent.
Pennsylvania State University researchers have continued to investigate
the spray irrigation treatment method. In a recent presentation to the
Interstate Commission on the Potomac River, the Pennsylvania State
University scientists stated that the "Living Filter" system continues to
perform well. A representative of the Pennsylvania Department of Environ-
mental Resources also spoke at the meeting and advised that the Pennsylvania
State University spray irrigation operation was well-managed and well-
located. He commented that some spray irrigation operations in the State
were obtaining poor results and warned that the process was being applied
without adequate consideration of soil, groundwater and wastewater factors.
(2) Ibid, p. 64.
D3

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In September of 1970, the Muskegon County Board and Department
of Public Works published the results of their investigation of the
feasibility of a lagoon treatment - spray irrigation system for waste-
(3)
water treatment. Muskegon County's research program consisted of
six parts:
(a)	An extensive analysis of the wastewater that would be
treated in the proposed aerated-lagoon - spray irrigation-system.
(b)	An in-depth review of the available literature concerning
the effects of trace elements on soil and crops.
(c)	A bench-scale test to determine the treatability of the
combined municipal - industrial wastewater.
(d)	Development of a simulation model to aid in predicting
lagoon storage requirements and intra-system changes in water
quality.
(e)	A soil and groundwater investigation program to determine
the feasibility of groundwater management.
(f)	A study of possible agricultural - agronomic techniques
that could be applied to the present project site.
The Muskegon County wastewater management system is designed to serve
a 1992 population of 170,000 persons and an industrial flow of 24 mgd.
The total design average flow for the system is 43.3 mgd. Wastewater
will be collected at eleven points in the existing sewerage system and
conveyed to a central pumping station. The wastewater is then pumped
(3) Engineering Feasibility Demonstration Study for Muskegon County,
Michigan, Wastewater Treatment Irrigation System, U. S. Department
of the interior Federal Water Quality Administration, Water
Pollution Control Series. Program #11010 FMY, September 1970, p. 1.
D4

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eleven miles through a 66-inch diameter force main to the treatment
site. At the treatment site, the wastewater receives secondary
treatment in three eight-acre aerated lagoons and is then discharged
to one of two 850-acre storage lagoons. The main purpose of the storage
lagoons is to contain wastewater so irrigation will not be necessary
daring rainy weather and freezing conditions. The 5.1 billion-gallon
volume of storage lagoons, also provides buffering capacity against
hydraulic and biological shock loads. The lagoon effluent is chlorinated
and then flows to one of two irrigation pjmping stations for transmission
to the irrigation machines. The irrigation machines apply the treated
effluent to land where its high nutrient content is expected to stimulate
the growth of agronomic crops. As the wastewater percolates through the
soil, various physical and biological processes remove waterborne contam-
inants. The renovated wastewater is collected in a well-underdrain system
which also controls the elevation of the groundwater table. The collected
water is then discharged into the Muskegon River and Black Creek.
Advantages of Spray Irrigation Methods
The most important advantage of the spray irrigation wastewater
treatment method is the high degree of water renovation obtained by this
process. The Pennsylvania State University study previously discussed
in this reported excellent removal of all contaminants except nitrate
nitrogen. The study concluded that "average concentration of all constit-
uents in the percolate were well below maximum permissible levels for
potable water."^
(4) Parizek, op cit., p. 63.
D5

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The Muskegon County Wastewater Management system is designed to
meet or exceed ail present and anticipated future water quality
standards of the Federal Government and the State of Michigan. The
anticipated removal rates of the typical pollutants in the mixture of
industrial, commercial and domestic wastes are as follows
Anticipated Performance
Pollutant
BOD (mg/1)
Suspended
Solids (mg/1)
Phosphorous (mg/1)
Total Nitrogen (mg/1)
Coliform
Bacteria
(Nunfoer/lOOml)
Pathogenic
Viruses
Influent
250 500
250 1000
5 3
20 40
2-20xl05
Not measured,
but known to
be present in
sewage.
Effluent Anticipated
Removals (%)
4
4
0.5
5.0
0
98 99
98 99
90 83
75 87
100
103
Minimum Required
Removals	
85%
90%
80%
None
Reduce to
1,000
None
Notes: 1. The two figures under Influent and Anticipated Removals
represent the Muskegon-Mona Lake and the Whitehall-Montague
Subsystems, respectively.
2. "Minimum Required Removals" are to satisfy Michigan Intrastate
Water Quality Standards. They were supplied via informal
communication with Mr. Ralph Prudy, Executive Secretary of
the Michigan Water Resources Commission.
(5) The Muskegon County Wastewater Management System, Bauer Engineering,
Inc., Chicago, Illinois, 1971, p. 11.
D6

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A second advantage of the land disposal method is that crop
yields are usually stimulated by irrigation with nutrient-rich sewage
treatment plant effluents. The productivity increase is related to
the amount of rainfall at the irrigation site and the crop selected
for cultivation. During periods of subnormal precipitation, yields
increase dramatically, while only slight increases are recorded during
periods of above average precipitation. Crop selection is thought to
be particularly important if forested areas are irrigated. The
Pennsylvania State University study found that spruce and oak stands
did well, while irrigation actually retarded the growth of red pine.
Another advantage cited by advocates of spray irrigation systems
is that this treatment method is less susceptible to shock loading
than conventional treatment systems. Proponents of the spray
irrigation method have also pointed out that a larger part of the
capital cost involves land acquisition and that land values can be expected
to appreciate rather than depreciate over time.
Finally, one further advantage of the spray irrigation method
natural removal processes. The principle of disposing sewage over the
land has been practiced for several thousand years. Unlike conventional
sewage treatment methods, the fundamentals of this process are easily
grasped and spray irrigation disposal methods can be expected to have
widespread popular support among those who advocate "a return to nature."
D7

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Disadvantages of Spray Irrigation Methods
The most obvious disadvantage of the spray irrigation method is
the enormous acreage required. At the irrigation site, land would
be required to satisfy three demands — irrigation, effluent storage,
and border zones. The land required for irrigation is a function of
the application rate. At two inches par week, the land demand is
129 acres per million gallons of effluent.
Effluent storage capacity is usually required to contain the
wastewater flow during periods of rainy and freezing weather. The
area required for effluent storage is a function of the climate and
the depth of the storage lagoon. An area as large as fifteen percent
of the irrigation area may have to be reserved for effluent storage.
Border zones and fences are required along the perimeter of the
irrigation site to protect pjblic health. Some tentative spray
irrigation criteria have established sixty feet as the buffer zone
width and six feet as the fence height. The amount of land required
for border zones cannot be determined until the number of sites are
established. If individual siting is employed, more acreage is required
for buffer zoning. An area as large as one percent of the irrigation
area may have to be reserved for this purpose.
D8

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Accepting the above discussion, the amount of land required to
dispose of the flow generated in an average four-person home is provided
by:
(129 acres) (1.15)(1.01)(.000400 mg) = 0.059933 acres
mg
or, 2,610.7 square feet
or, a 51-foot square.
Thus, an area approximately the size of a small backyard would be
required to serve every home connected to a spray irrigation type waste-
water treatment system.
Also, considerable attention must be given to the soil composition
at the proposed irrigation site. The soil should be permeable, yet not
permeable enough to allow the wastewater to pass quickly through. The
soil should consist of grains that are not likely to swell with repeated
water applications. It should contain some clay quantities because the
naturally-charged clay particles tend to act as ion exchangers with
certain ionic pollutants in the wastewater. The thickness of the various
soil strata must be considered along with the nature and composition of
the underlying bedrock. All of the factors described above serve to
limit areas that can be considered as potential spray irrigation sites.
Groundwater characteristics at the spray irrigation site must also be
investigated prior to final selection. If the local water table is high, an
extensive underdrain or well system will be required to eliminate the
possibility of soil saturation. An elaborate groundwater monitoring
program must be initiated to guard against the possibility of contaminating
D9

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groundwater supplies by sewage from leaking lagoons and by pollutants
in the percolate. Finally, consideration must be given to the effects
of supplemental flow on local streams. For example, possible flooding
of downstream communities must be explored as a result of introducing
additional flows to adjacent watercourses.
Land would be required not only for the disposal site, but also
for the transmission system right-of-way. In some areas existing
transportation line rights-of-way could be used, but at other places
it would be necessary to displace homes and their occupants. The large
pressure pipeline that would be required could not be built without some
adverse environmental impacts.
A further disadvantage is that the transmission system pumps would
consume large amounts of electrical power. Unless present power generation
practices are improved, power requirements would have to be satisfied at
the expense of non-renewable natural resources.
Also, while it may be ecologically sound to renovate wastewater
naturally, it certainly is not hydrologically sound to transfer large
blocks of fresh water from their point of origin to another watershed
some distance away. Natural balances could easily be upset at both the
source and the receiving watersheds.
Finally, it should be noted that, to date, there has been no large-
scale demonstration of the long-range feasibility of spray irrigation
systems. The Muskegon County Department of Public Works has been
awarded an EPA Research and Development Grant to monitor water quality
and soil chemistry during the initial five years of their system's
D10

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operation. If this project reports favorable results, additional
prototype spray irrigation systems could be constructed. However,
the question of large-scale spray irrigation systems at this time
would be premature. Additional research must be undertaken prior
to implementing spray irrigation disposal techniques on a regional
basis to ensure that land productivity will not be jeopardized by
such systems.
Attached is a copy of "Tentative Design Criteria For Spray
Irrigation For the Disposal of Sewage Effluents Which Have Received
Secondary Treatment," which were prepared after a study of results
obtained from prototype operation of these techniques at Pennsylvania
State University.
Dll

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March 1, 1967
TENTATIVE DESIGN CRITERIA FOR
SPRAY IRRIGATION FOR THE DISPOSAL OF SEWAGE EFFLUENTS
WHICH HAVE RECEIVED SECONDARY TREATMENT*
Note: These design criteria were drawn up after a study of results
obtained from experimental work on a full plant scale with spray
irrigation for disposal of sewage effluent by the Pennsylvania State
University. The results of the Pennsylvania State University studies
and conclusions reached and certain limits established are covered
in the publications and letter listed at the end of these criteria.
Spray irrigation as covered under this design criteria is not to be
considered as a treatment process, but only a means of disposing of
sewage effluent which has received secondary treatment. For public
health reasons, this method of disposal of effluent that has received
primary treatment only will not be acceptable. Spray irrigation may
be considered where adequate area of suitable land is available on
watersheds of streams into which no sewage effluents can be dis-
charged or where treatment by conventional methods is not adequate.
Special precautions will be necessary in critical areas where no
discharge, overflow, or runoff of sewage effluent is permitted on
the watershed.
Area Requirements:
L. The maximum application rates in terms of depth of effluent are
as follows:
(a)	1/4 inch per hour
(b)	1/2 inch per day or
(c)	2 inches per week
It should be understood that these are maximum rates and lower
application rates may be necessary in some areas, due to soil
characteristics.
!. Using a maximum of 2 inches per week, approximately 128 acres
of spray area, plus the area to account for any storage, is
required per MGD of effluent. For example, if there are 30
days of storage, the area required per MGD would be 128 x 365 =
335
139.5 or approximately 140 acres.
I. The consulting engineer will be required to present a statement
by a qualified soils consultant indicating the soil is adequate
for a discharge rate in accordance with the requirements of A, 1
above. It will be the owner's responsibility to expand the spray
* Not less than 80% removal of BOD and suspended solids.
NUU< t 0 ^ L

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Page - 2 -
area or cease operation completely if ponding or runoff is
experienced after the system has been put in operation.
4. Where it is necessary to provide several separate zones for
spraying, then each zone will be dosed in sequence to prevent
overloading any individual zone.
B.	Location:
1.	The irrigated area will be adequately enclosed with a suitable
fence to keep out children and small domestic animals. The
fence will be placed at least 60 feet beyond the normal pro-
jected spray area. It will be at least six (6) feet high,
consisting of four feet of woven wire at the bottom, plus at
least two strands of barbed wire at the top, spaced at one (1)
foot intervals.
2.	A distance of 400 - 600 feet from the fence of the enclosed
irrigated area to the property lines of sxisting or proposed
residences and highways is recommended. The best infortn&£;lem
available indicates the spray droplets will carry up to 180
feet in high winds. The responsibility will rest with the
owners of the treatment facilities if there are any objections
from adjacent property owners concerning the effluent spray.
C.	Holding Requirements:
1.	The owner will provide sufficient holding time to store all
flow during periods when the ground is froxen or during rainy
weather or when covered with snow or when the irrigation field
cannot otherwise be operated. A minimum of 30 days holding
time will be required. It is reconunended that all storage
provided above a fixed water level to prevent complete draining
of the holding pond. A 1% to 2 foot residual water depth is
considered necessary to prevent excessive growth of emergent
weed vegetation.
2.	Natural runoff from the drainage areas around or above will be
excluded from the pond by adequate drainage ditches or bypasses.
A pond similar to the approved stabilization pond will be satis-
factory, but somewhat deeper depths will be permitted.
D.	Chlorination;
1. Chlorination will be required with application between the holdj
pond and the spray irrigation pump station. The required retent

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Page - 3 -
time will be 30 minutes, with a chlorine residual of 2 mg/1 in the
effluent spray. The chlorinator will have capacity to apply 35 ppm
to flow to be treated. Detention period will be based on rate of
pumping to spray field, since this will represent maximum rate of
flow through the tank.
E.	Spray System Design:
J.. The piping for the spray system will be permanent or built-in-place
type.
2.	The height of spray nozzles, pressure at spray nozzles, and spacing
of laterals will be adequate to provide uniform distribution of
the effluent over the area to be covered.
3.	Automatic drain valves will be provided to prevent freezing of
spray nozzles and distribution lines when the system or section
of the system is not in operation.
F.	Miscellaneous:
Miscellaneous equipment to be provided and conditions to be na-ac.,
1.	Duplicate pumps will be provided for delivery to spray field, wicfe
the capacity of each pump sized to handle maximum rate of flow,
plus an allowance to deplete stored volumes.
2.	An approved metering device will be provided at the pump station,
which will show the total flow and rates to the irrigation field,
3.	The top of the chlorine contact tank and the wet well of the
pumping station will be at least as high as the maximum holding,
pond surface elevation, to prevent flooding these units whert the
spray irrigation equipment is not in operation.
4.	A control valve between the holding pond and the spray itiriga
pump station will be required.
5.	If the spray area does not contain trees and undergrowth, then
grass sod will be necessary on the irrigation area.
*6. Spray irrigation area should be as flat as possible; however,
* when it is necessary to locate the irrigation field on a slight
slope in areas where discharge of sewage effluent is prohibited
to the streams, special precautions should be taken to prevent
seepage or runoff of sewage effluents to the stream. Dikes or
terraces may be necessary, together with collection and return
pumping equipment.

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Page - k -
Source of Data Used: P
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APPENDIX E
SUMMARY AND CONCLUSIONS
OF TECHNICAL REPORT #35,
WATER RESOURCES - WATER SUPPLY
STUDY OF THE POTOMAC ESTUARY

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SUMMAJRY AND CONCLUSIONS
FROM
A WATER RESOURCE-WATER SUPPLY STUDY
OF THE
POTOMAC RIVER ESTUARY
Prepared for the Progress Meeting of April 29, 1971
of the
Potomac Metropolitan Area Enforcement Conference
Chesapeake Technical Support Laboratory
Water Quality Office, Environmental Protection Agency
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CHARTER II
SUMMARY AND CONCLUSIONS
A detailed study of the interrelationships among wastewater
discharges, water supply withdrawals, freshwater inflow, and water
quality in the Potomac Estuaiy was undertaken in November 1969. This
study had two purposes: (l) to refine the allowable oxygen demanding
and nutrient loadings previously established for Zones I, II, and III
of the upper Potomac Estuaiy and (2) to determine the feasibility of
vising the estuary as a municipal water supply source. The latter
study was conducted in cooperation with the U. S. Army Corps of
Engineers. The study findings as related to wastewater management
are presented below:
1.	The Potomac River Basin has a drainage area of 14,670 square
miles. The average discharge rate of the Potomac River at Great Palls
is 10,780 cubic feet per second (cfs) with a minimum of 610 cfs and a
maximum of over 484,000 cfs.
2.	Of the present 3.3 million population in the Potcmac River
Basin, 2.8 million live within the study area which encompasses the
entire Washington metropolitan region.
3.	The present municipal water use within the study area is
370 mgd with 72 percent (265 mgd) supplied from the Potomac River
above Washington. The industrial water use is 2,750 mgd with cooling
water for electric power production accounting for 99 percent.
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4„ Recreational facilities on or near the Potomac Estuary include
a national park, three state paries, seven fish and game areas and 226
coijzity recreational sites „ A recent study "by the Bureau of Outdoor
Recreation indicated that the recreational potential of the 637 miles
cf shoreline has barely been developed.
5. In 1969, approximately 17-million pounds of fish, crabs, clams,
and oyster? were tnken from the Potomac tidal system with a dockside
value of some $4„7 million, A study in'196l indicated that about $0,6
million was spent during 6 months of sport fishing in the Potomac
5sWiry. There are approximately 95 marina facilities in the tidal
Potomac which accommodate over 5,200 recreational watercrafto
60 Effluents from the 18 major wastewater treatment facilities
d.nd combined sewer overflows, with a total flow of 325 mgd, contribute
450,000, 24,000, and 60,000 lbs/day of ultimate oxygen demand (UQ.D*),
phr-i pharos , and nitrogen respectively to the waters of the upper
Potomac Estuary „
7„ "Jnder low-flow conditions, the ultimate oxygen demand, phos-
phorus, and nitrogen, loadings from the upper basin and local runoff
were estimated as 66,000, 1,000, and 2,300 lbs/day, respectively,,
80 Ihe major sources of nutrients and ultimate oxygen demand in
the Potomac Estuary are the local wastewater discharges. Under low-
flow conditions approximately 88, 90, and 96 percent of the ultimate
oxygen demand, nitrogen, and phosphorus are from treated waste effluents.
* TJ0D - Ultimate Oxygen Demand is defined as the sum of 1.45 times the
5-dsy biochemical oxygen demand and 4.57 times the unoxidized nitrogen.
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At median freshwater inflows, approximately 62, 60, and 82 percent
respectively are from these wastewater discharges.
9. Since the first sanitary surveys in 1913, the water quality of
the upper Potomac Estuary has generally deteriorated. This is attributable
to the increased pollution originating in the Washington area.
10.	Fecal coliform densities have recently proved an exception to
the general degradation as shown by the water quality indicators. Since
the sujraner of 1969, the high fecal colifonn densities previously found
near the waste discharge points have been significantly reduced by con-
tinuous wastewater effluent chlorination. At present, the largest
sources of bacterial pollution in the upper estuary are from sanitaiy
and combined sewer overflows, where at times about 10 to 20 mgd of
untreated sewage enters the estuary because of inadequate sewer and
treatment capacities„
To achieve the adopted fecal coliform water quality standards,
there must be both continuous disinfection of wastewater effluents
and elimination or drastic reduction in overflows from sanitary and
combined sewers.
11.	The most pronounced effect of thermal discharges is in the
Anacostia tidal river where a five-degree rise above ambient/water
f.fr
temperature frequently occurs and readings as high as 33°C have been
recorded during the summer months.
12.	Since 1938, dissolved oxygen levels in the upper estuary had
been decreasing. A slight upward trend occurred in the early 1960's
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due to the provision of a higher degree of wastewater treatment. However,
with increasing population, the amount of organic matter discharged has
increased to a record high in 1970 resulting in a critical dissolved
oxygen stress in the receiving water. In recent years, dissolved oxy-
gen concentrations of less than 1„0 mg/l have occurred during low-flow,
high-temperature periods,
13,	Mathematical model simulation of the dissolved oxygen budget
including carbonaceous, nitrogenous, benthic, and algal demands indicate
that the nitrogenous demand is the greatest cause of dissolved oxygen
deficit- in the critical reach near the wastewater discharges and that
algal growths have the greatest effect on DO from Piscataway to Indian
Head, at times depressing it below 5,0 mg/l„
14,	On the average, approximately 3-billion pounds per year of
sediments enter the Potomac Estuary of which 2.2-billion pounds per
year originate in the upper Potomac River Basin, The sediment yield
from the Washington area on a lbs/sq. mi/yr basis is about seven times
greater than that from the upper basin,
15 o Since 1913., the wastewater discharge quantities have increased
over sevenfold from 42 to 325 mgd, the phosphorus load increased 22-fold
from 1,100 to 24,000 lbs/day; nitrogen ninefold, from 6,400 to 60,000
lbs/day; and carbon approximately twofold, from 40,000 to 100,000
lbs/day* When ecological plant successions from a balanced toward
an unbalanced system (primarily one dominated by blue-green algae) are
related to wastewater loading trends, it can be concluded that the
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ecological successions are the result of increases in nutrients.
Moreover, it appears that the ecological changes are due primarily
to the large increases in phosphorus and nitrogen.
16.	In recent years, large populations of blue-green algae, often
forming thick mats, have been observed in the Potomac Estuary from the
Potomac River Bridge (Route 301) to the Woodrow Wilson Bridge during
the months of June through October. In September of 1970, after a
period of low-stream flow and high temperatures, the algal mats
extended upstream beyond Hains Point and included the first nuisance
growth within the Tidal Basin. The effects of the massive blue-green
algal blooms in the middle and upper portions of the Potomac Estuary
are (l) large increases of over 490,000 lbs/day in total oxygen demand,
(2) an overall decrease in dissolved oxygen due to algal respiration in
waters 12 feet and greater in depth, (3) creation of nuisance and
aesthetically objectionable conditions, and (4) reduction in the feasi-
bility of using the upper estuary as a potable water supply source
because of potential toxin, taste, and odor problems.
17.	To reduce the effects of excessive algal blooms on water
quality and designated beneficial uses, it has been determined that
during the summer months, the standing crop should be reduced to a
minimum of 75 to 90 percent of the current level or to a chlorophyll a
concentration at or below 25 ug/l.
18.	Prom six independent methods of analysis, it appears that if
the upper concentration limit of inorganic nitrogen is maintained bet-
ween 0.3 and 0.5 mg/l as N and the upper limit of total phosphorus at
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0.03 to 0.1 mg/l as P, the algal standing crop can be maintained below
nuisance levels under summer conditions. The lower limits of nutrient
concentration apply to the embayments and middle portion of the estuary
where growing conditions are more favorable, whereas the higher concen-
trations are applicable to the upper portion of the estuary where lack
of light penetration limits algal growth.
19.	Significant accumulations of various heavy metals in sediments
have been detected near the major wastewater discharges,, A study of the
possible long-term toxic effects of these heavy metals on the biota of
the Potomac Estuary, especially shellfish, is essential„
20.	Population and water supply needs have been projected as
follows:
Year
1969
1980
2000
2020
Population
2,700,000
4,000,000
6,700,000
9,300,000
Water Supply Needs
Yearly avg. Maximum Month
(mgd)
(mgd)
370
570
1010
1570
470
720
1310
2040
Maximum Daily
(mgd)
660
1000
1820
2820
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21. Even with the seven proposed upper Potomac River Basin reser-
voirs operational, the following withdrawals will be required frcm the
estuary or from direct wastewater reuse to meet the water supply
requirements:
Low-flow Characteristics Before Withdrawal from the Potomac Estuary
	Water Supply Diversion	 	or from Direct Reuse*	
Recurrence
Interval
Minimum Monthly
Fresh Inflow
1980
For a 720
med Need
2000
For a 1310
med Need
2020
For a 2040
med Need
(years)
(mgd)
(mgd)
(mgd)
(mgd)
5
1300
none
210
940
20
1170
none
34-0
1070'
50
910
none
600
1330
* Withdrawal based on minimum 30-day low flow concurrently with a
maximum 30-day water supply withdrawal and a 200 mgd minimum base
flow over Great Falls into the estuary.
22. The projected wastewater volumes and loading characteristics
before treatment are as follows:
Year
Flpff
BOD
Nitrogen
Phosphorus

(mgd)
(lbs/day)
(lbs/day)
(lbs/day)
1969
325
483,500
63,500
27,300
1980
475
823,500
95,600
43,100
2000
860
1,463,500
155,700
70,300
2020
1,340
2,195,000
215,600
97,400
23. To aid in determining the allowable pollutant loadings frcm
wastewater discharges, mathematical models have been developed and
verified for predicting (l) phosphorus transport, (2) nitrogen trans-
port and assimilation, (3) effects of benthic, carbonaceous, and
nitrogenous oxygen demand, including the effects of algal photosynthesis
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and respiration on the dissolved oxygen budget, and (4) chloride and
total dissolved solid intrusions from the Chesapeake Bay, and their
buildup as a result of water supply withdrawals from the estuary.
240 Based upon the study of projected wastewater quantities and the
recently adopted metropolitan Washington wastewater treatment implemen-
tation schedule, the following can be concluded:
(1)	Between the years 1980 and 2000, the Potomac (Dulles) Interceptor,
with its current capacity of 65 mgd# will be overloaded.
(2)	To provide for futura wastewater collection and treatment-
facilities in areas currently projected to be served by the Potomac
Interceptor, either the capacity of the interceptor would have to be
significantly increased or additional wastewater treatment facilities
constructed on the Potomac River above Washington.
(3)	With the Blue Plains wastewater treatment capacity limited
to 309 mgd, a need exists not only for one or more facilities to
serve the Anacostia Valley but also to serve a portion of the upper
Potomac area currently served by Blue Plains via the Dulles Interceptor,,
(4)	Large wastewater volumes are projected in the Geeoq.uan and
Pohick watersheds in the Virginia counties downstream from Washington,
indicating a need for long-range water resources planning in this area.
25. Three basic alternative wastewater treatment systems were
investigated to determine the effects of the discbarge locations on
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receiving water quality including chloride and total dissolved solid
intrusions, as follows:
(1)	Alternative I consisted of the following plants: Pentagon,
Arlington, Blue Plains, Alexandria, Piscataway (also serving Andrews
Air Force Base), Lower Potomac (serving Pohick, Accotink, Dogue, and
Little Hunting Creek watersheds including Fort Belvoir), Mattawaman,
Neabsco (serving the Occoquan watershed), and Port Tobacco.
(2)	Alternative II consisted of the nine treatment plants as in
Alternative I plus a facility serving the Anacostia Valley and located
just above the Maryland-D» C. Line, and
(3)	Alternative III consisted of the same facilities as Alternative
II plus an upper Potomac plant discharging near Chain Bridge and serving
the upper Potomac region.
Two other systems designated as Alternatives IV and V were also
investigated. These were identical to III, except that for Alternative
IV, all effluents were assumed to be discharged into the main channel
of the Potomac; while for Alternative V, all effluents were assumed to
be conveyed downstream to a common discharge point below Indian Head,
Maryland.
26. Data from the chloride, total dissolved solids, and other
simulations where the estuary was used as a potable water supply source
indicate the following:
(1) The position of the salt wedge with respect to intrusion
from the Chesapeake Bay is a function of (a) duration and magnitude
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of any selected flow, (b) location of the wastewater treatment facility
discharges, and (c) consumptive losses in the water distribution system.
(2)	Even with no water supply withdrawals from the estuary, for
comparable flow conditions, intrusion of chlorides and total dissolved
solids frcm the Chesapeake Bay will occur farther upstream in the future
as a result of the greater percentages of wastewater discharged down-
stream into the salt wedge and the projected increases in consumptive
loss, with the latter having the most pronounced effect.
(3)	The number of days during which the estuary can be used for
water supply depends upon (a) the position of the wedge prior to the
withdrawal, (b) magnitude of the withdrawal, (c) freshwater inflow
during withdrawal, (d) location of the wastewater discharges, and
(e) the increase in chlorides and total dissolved solids as a result
of water use.
(4)	The maximum possible number of days that the estuary could
be used for a water supply source was determined by using a total
dissolved solids concentration in the blended water of 500 mg/l maxi-
mum as a criterion since this parameter was determined to be more
critical than chlorides. TPS water use increments* of 40 and 240 mg/l
* Water use increment is the amount that the concentration of TBS or
any other parameter is increased frcm the point of water intake to
the point of discharge as a result of water supply treatment,
municipal use, and wastewater treatment.
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were applied at both the upstream and downstream location extremes of
the saltwater wedge to give the results in the table below:
Alternative I
Maximum Days of Use of Estuary
Upper Position	Lower Position
Water Withdrawal of Wedge	of Wedge
Year From Estuary Water Use Increment	Water Use Increment
(cfs) 40 mg/l 240 mg/l	40 mg/l 240 mg/l
1980
500
> 166
> 166
>166
> 166
2000
1250
90
35
140
45
2020
2000
45
15
95
20
(5) For the year 2020 and using the upper position of the wedge
(as observed in early September 1966—the lowest flow on record), the
number of days that the estuary can be used as a water supply and yet
maintain a maximum 500 mg/l total dissolved solids standard in the
blended water is given below as a function of freshwater flow before
water supply diversions:
Maximum Days of Use of Estuary
Alternative I	Alternative V
Freshwater Flow	Water Use Increment Water Use Increment
(cfs)
40 me/1
240 pig/1
40 nr/1
(days
(days)
(days)
45
15
18
>166
42
> 166
>166
> 166
>166
(days)
400	45	15	18	18
1100	>166	42 >166	41
1800	>166	>166	>166	>166
(6) Since the projected water supply needs for the year 2020
cannot be met completely either by withdrawals frcm the estuary or
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from the seven proposed upper basin reservoirs for drought periods
extending over a month, Loth sources will eventually be needed to
meet the future water requirements for the Washington metropolitan
area0 It appears that an increase of approximately 860 cfs (from 940
to 1800 cfs) in the Potomac River discharge at Washington will be
required to maintain an acceptable blended water with respect to
total dissolved solids for a 240 mg/l water reuse increase. If the
increase is less than 2^0 mg/l, the flow regulation requirements will
decrease„
(7) While other aspects of water supply requirements such as
viruses and carbon chloriform extractables need to be considered in
more detail, it appears that the estuary can be used as a supplementary
water supply source if wastewater discharges and water supply withdrawals
are subjected to adequate treatment.
27. Direct reuse of the renovated wastewater is another solution
to meet water supply needs. This alternative has numerous advantages
over withdrawals from the estuary because:
(1)	Any need for consideration of salt intrusion from the
Chesapeake Bay for water supply purposes is eliminated,
(2)	Localized runoff and combined sewer overflows will not
degrade the high quality renovated water,
(3)	The need for flow regulation from upstream reservoirs to meet
the projected Washington area water supply requirements is reduced to
a total flow of approximately 1100 cfs (before v/ater supply diversion)
or an increase of about 150 cfs above unregulated conditions„
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Excluding the psychological objections to treated wastewater reuse
and the problems of physical transport of the wastewater to the water
intake, the major disadvantage, especially from the technical viewpoint,
would be the need to maintain the present maximum total dissolved solids
buildup of 140 mg/l through the water supply treatment, water use, and
wastewater renovation processes whenever more than 80 percent of the
water supply is taken directly from renovated wastewater.
28.	When the water resource needs of the entire basin are considered,
the long-range solution to the water supply-wastewater disposal problem
may initially be a combination of water supply withdrawals from the
estuary and flow regulation, with direct reuse becoming increasingly
feasible by early in the 21st Century.
29.	The maximum allowable ultimate oxygen demand loadings have
been determined as given below for various zones and subzones of the
upper estuary for a 29°C temperature, a freshwater inflow after water
supply diversion of 300 cfs, a DO of 6 mg/l in the treated effluent,
and based upon maintaining 5 mg/l DO in the receiving waters„
MAXIMUM UOD LOADINGS FOR POTOMAC ESTUARY
Zone	Allowable UOD*
(lbs/day)
I-a	(Upstream from Hains Point)	4,000
I-b	(Anacostia River)	3,000
I-c	(Hains Point to Broad Creek)	75,000
II	(Broad Creek to Indian Head)	190,000
III	(Indian Head to Smith Point)	380,000
* These loadings are the maximum allowable loadings for each zone assuming
adjacent zones are loaded to their maximum capacities.
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30. For the three freshwater inflows (before' water supply with-
drawal) investigated, i.e., 1800, 1100, and 400 cfs, the maximum UOD
loadings were not affected significantly except for Alternative III
which included a treated waste discharge in Zone I-a near Chain Bridge.
When the DO in the effluents in mathematical model simulations was
decreased from 6.0 to 2o0 mg/l, the most pronounced effect was in Zone I-c
in which the UOD loading decreased from 75,000 to 56,000 lbs/day.
31 „ Allowable UOD loadings for the Piscataway and C-unston Cove
embayments have been developed for the projected wastewater volumes
and conditions specified in Number 29 and are given below:
MAXIMUM UOD LOADINGS FOR PISCATAWAY CREEK AND C-UNSTON COVE
Piscataway Creek	Gunston Cove
Wastewater	Maximum	Wastewater	Maximum
Flow	UOD Load	Flow	UOD Load
(mgd)	(lbs/day)	(mgd)	(lbs/day)
24 10,000	50	7,000
49 11,000	103	11,000
79 12,000	170	16,000
32„ Since nitrification (the conversion of ammonia nitrogen to
nitrate nitrogen) has little effect on the oxygen resources of the
estuary at temperatures below 15CC, nitrogen removal from the waste-
water effluents to meet DO standards will be required whenever the
water temperature is above 15°C, usually during the months of April
through October„
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In order to prevent formation of sludge deposits, to eliminate
objectionable floating matter, and to prevent low DO concentrations
during periods of ice cover, a minimum of 70-percent UOD removal and an
effluent concentration of less than 15 mg/l suspended solids are required
year-around for all discharges.
33. Using an average freshwater inflow of 300 cfs to the Potomac
Estuaiy after water supply diversions, the allowable loadings of phos-
phorus by zones were determined based on maintaining an average maximum
of 0.067 mg/l as P in Zones I and II, and 0.03 mg/l as P in Zone III for
algal control. The allowable loadings are presented below:
MAXIMUM PHOSPHORUS LOADINGS FOR POTOMAC ESTUARY
Zone
Allowable Phosphorus
(lbs/day)
I-a (Upstream from Hains Point)
I-b (Anacostia River)
200
I-c (Hains Point to Broad Creek)
II (Broad Creek to Indian Head)
1500
900
III (Indian Head to Smith Point)
2000
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34. Allowable phosphorus loadings for the Piscataway and Gunston
Cove embayments for phosphorus concentration in the receiving waters of
0.03 mg/l as P are shown below as a function of wastewater flow:
PHOSPHORUS LOADINGS TO EMBAYMENTS
Piscataway Creek	Gunston Cove
Wastewater	Maximum	Wastewater	Maximum
Flow	Phosphorus Load	Flow	Phosphorus Load
(mgd)	(lbs/day)	(mgd)	(lbs/day)
24	35	50	35
49	50	103	60
79	65	170	140
35. To prevent excessive algal growth and to enhance the water
quality in the upper and middle reaches of the estuary, it appears that
it will be necessary to remove phosphorus on a continuous or a year-
around basis for discharges into the upper estuary. Moreover, the
control of at least 50 percent of the phosphorus load originating in
the upper Potomac River Basin appears necessary if the aforementioned
phosphorus criteria are to be achieved. To accomplish this reduction,
the current phosphorus loading from all wastewater discharges in the
upper Potomac River Basin must be decreased from 6100 to 700 lbs/day.
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36. Using a freshwater inflow of 300 cfs and average maximum
inorganic nitrogen concentrations of 0.5, 0.4, and 0.3 fflg/l in Zones I,
II, and III, respectively, for algal control, the maximum nitrogen
loadings for warm temperature conditions were determined as follows:
NITROGEN LOADINGS FOR POTOMAC ESTUARY
Zaae	Allowable TtfaJ, Nitres
(lbs/day)
I-a	(Upstream from Hains Point)	1000
I-b	(Anacostia River)	300
I-c	(Hains Point to Broad Creek)	3400
II	(Broad Creek to Indian Head)	5800
III	(Indian Head to Smith Point)	9000
37. Allowable total nitrogen loadings far the Piscataway and
Gunston Cove embayments based upon maintaining 0.3 mg/l of inorganic
nitrogen under warm temperature conditions and for varying wastewater
flows follow:
NITROGEN LOADINGS TO EMBAYMENTS
Piscataway Creek	Gunston Cove
Wastewater	Maximum	Wastewater	Maximum
Flow	Nitrogen Load	Flow	Nitrogen Load
(mgd)	(lbs/day)	(mgd)	(lbs/day)
24	120	50	130
49	170	103	270
79	270	170	460
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38. Considering the present difficulty in controlling nitrogen in
the upper basin and its transport characteristics in the estuary, it
appears that the need for nitrogen removal for algal control at waste-
water treatment plants will be limited to those periods when the water
temperature exceeds 15°C, normally from April through October. With
the large projected increases in nitrogen from wastewater discharges,
there may be a need for year-around nitrogen control by the year 2000.
39o Because of the lack of transport and assimilative capacity in
the upper portions of small tidal embayments and also because of ideal
algal growing conditions, maximum concentrations of UOD, phosphorus and
nitrogen in effluents discharged to these areas should be less than 10.0,
0.2, and 1.0 mg/l, respectively. A detailed analysis for each embayment
is required to determine the minimum cost of either extending the dis-
charge outfall to the main channel of the Potomac or discharging within
the embayment and providing a very high degree of wastewater treatment,
approaching ultimate wastewater renovation. Unless this high degree of
removal is provided, effluents from Alexandria, Arlington, Piscataway,
and the Lower Potomac facilities should be discharged into the main
channel of the Potomac Estuary.
40. The present worth cost of additional wastewater treatment
from the year 1970 to 2020, including operation, maintenance, and
amortization costs, has been estimated to be $1.34 billion with a
total average annual cost of $64.8 million. The unit treatment pro-
cesses assumed include activated sludge, biological nitrification-
denitrification, lime clarification, filtration, effluent aeration,
and chlorination.
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41. The cost of wastewater treatment on a per capita basis is
as follows:
Item	1970-1980	1980-2000	2000-2020
Average Population	3,350,000	5,350,000	8,000,000
Initial Capital
Cost/Person/lear	$17.0	$ 4.90	$ 7.30
Operation and Maintenance
Cost/Person/Year	$ 7.50	$ 8.60	$ 9.10
Total Cost/Person/Year	$24.50	$13.50	$16.40
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APPENDIX F
PRIOR DISTRICT OF COLUMBIA SEWERAGE
SYSTEMS AND EXISTING WATER
POLLUTION CONTROL FACILITIES

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APPENDIX F
PRIOR DISTRICT OF COLUMBIA SEWERAGE SYSTEMS AND
EXISTING WATER POLLUTION CONTROL FACILITIES
1. Prior Systems
The following is a chronology of major events in the development of
the District of Columbia's sewerage system from its beginning to present.
1810	- Sewers and culverts built to drain streets,
with discharges to the nearest convenient water
courses.
184.01 s	- First sanitary connections made to the storm
system, probably about the time the first
interior piping of water in houses occurred.
1858	- Corporation permitted connections to sewers
but required strainers to keep solids from
passing into the sewers.
Civil War - Epidemics of smallpox and malaria which took
the lives of thousands of persons in the
District.
1871 - 7A - Approximately 80 miles of sewers built to
convey wastes to the marshes along the Potomac
and Anacostia Rivers.
1889	- The Potomac River was so obnoxious that
President Harrison appointed a Board of Engineers
to study the situation and recommend steps to be
taken to provide the City with an adequate
sewerage system.
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1890	- Engineers report issued recommending
system of interceptors be constructed
to convey the sanitary flows and that of
light rains to a point of discharge on
the Potomac just upstream from the southern
end of Boiling AFB. They also recommended
that no further areas be served by combined
sewers.
1919	- The District acquired the present treatment
plant site at Blue Plains in anticipation of
the need for a treatment plant.
Early 1930's - The situation became similar to that existing
in the 1890's and a second Board of Engineers
was hired to report on sewerage and sewage
disposal for the District.
-	Report completed which recommended construction
of a 130 mgd primary type treatment plant.
-	Construction of the plant began.
-	Plant completed and placed into operation with
units consisting of grit removal, grease
separation (now eliminated), and plain
sedimentation. Sludge removed by these processes
was treated by digestion, elutriation, and
dewatering and then used as a soil conditioner
by various parties.
mi
1935
1218
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19A9	- Plant expanded to 175 mgd.
1953 - 55 - Chlorination facilities and a drying and
incineration plant constructed for the disposal
of sludge.
1954.	- Comprehensive agreement executed with WSSC
to provide for capacity in the plant to treat
their flows.
1954-	- Third Board of Engineers engaged to recommend
a construction program to provide an adequate
sewerage system to handle flows to the year 2000,
1957	- Construction of initial secondary units at the
treatment plant.
1957	- Replacement and additional screens installed at
main pumping station.
1958	- Additional secondary units added at the treatment
plant.
1959	- Intercepting sewer constructed from Main Pumping
Station to Poplar Pumping Station.
1960	- Intercepting sewer and additional pumping capacity
constructed adjacent to existing Main Pumping Station.
1961	- Potomac River System "Project C" under construction.
1961 - Secondary treatment capacity increased to 240 mgd rate.
F 3

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1962	- Joint East Side Relief Sewer, Anacostia River Force
Main and Gravity Sewer constructed.
1963	- Additional sludge thickening tanks constructed.
1963	- Miscellaneous improvements at treatment plant.
1964	- Section 4 of Upper Potomac Relief Sewer constructed.
1964 - "Project C" intercepting sewer extended to Northwest D.C.
Projects initiated since 1964 are discussed in detail in the text
of this report which follows.
F 4

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2. Existing D.C. Water Pollution Control Facilities
The facilities at the WPCP include Raw Sewage Pumping, Grit
Removal, Prechlorination, Primary Sedimentation Tanks, Aeration Tanks
and Final Sedimentation Tanks. Sludge removed through these processes
is treated by Prethickening, Anaerobic Digestion, Elutriation and
Dewatering before stockpiling on the plant site. A more detailed
description of these project features is given later in this Appendix.
Three incinerator systems were installed in 1952 which have a total
capacity of 579 tons per day of filter cake with 70% moisture content.
Operation of these have not been required because it has been possible
to dispose of the sludge cake by mixing it with soil at the plant site
and allowing it to be removed for use as loam. In January 1972, the
stockpiled sludge totaled approximately 176,000 cubic yards.
The Raw Sewage Pumping Facilities were expanded from 320 to 817 mgd
in 1969 - 71 by the construction of a new Raw Sewage Pumping Station under
EPA Construction Grants Project WPC-DC-20. The facility will possess
adequate capacity to accommodate flows for the 309 mgd plant plus excess
flow from the District's combined sewer system.
The treatment facilities are designed to handle an average daily
flow of 240 mgd. Peak rates of flow are limited to 300 mgd due to hydraulic
restrictions within the plant. Flows in excess of this rate are bypassed
to the Potomac River after receiving primary sedimentation. The units
are designed so that a negligible loss in efficiency occurs when they are
F 5

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hydraulically overloaded for a short period time (1-2 hours).
However, flows of 300 mgd are sustained through the plant for periods of
18 hours or more which considerably reduce the treatment received by the
wastes. Flows to the plant are tabulated in Table F 1 of this Appendix.
The existing wastewater treatment units are generally in good
condition and can be included in the expanded plant provided their
average and peak flow rates are reduced to within recommended values.
Many of the sludge processing units are generally in poor condition
(with the exception of the gravity thickeners) and will not be utilized in
upgrading and expanding the plant.
Table F 2 presents a summary of prior EPA construction grants
projects within the District of Columbia.
F 6

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3. Existing Facilities
Presented below is a synopsis of the major treatment elements that
constitute the existing D.C. Water Pollution Control Plant. A general
layout of existing water pollution control facilities is presented in
Figure F 1.
A. Aerated Grit Chambers
Number of Chambers
Year Constructed (year converted)
Chamber width, ft.
Chamber length, ft.
Total Volume, cu. ft.
Detention time @ 300 mgd
B. Primary Sedimentation Tanks
Number of Tanks
Year Constructed
Diameter, ft.
Average water depth, ft.
Total surface area, sq. ft.
Total volume, cubic ft.
Detention time, hrs @ 300 mgd
Surface settling rate gpd/sf @ 300 mgd
1935 (1958)
20.5
75
50,500
2.5 min.
16
12 in 1935
4 in 1946
106
14
141,200
1,978,000
1.18
2125
The capacity of the tanks are hydraulically limited to 300 mgd since the
effluent weirs become flooded beyond this flow. This limitation is caused
by restricted capacity of the line between these tanks and the aeration
basins. When flow rates do exceed 300 mgd, primary settled sewage is
bypassed directly to the Potomac River.
F 7

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C. Aeration Basins
Number of tanks	4.
Year Constructed	2 in 1956
1 in 1957
1 in 1962
Number of channels each tank	4
Channel length, ft.	460
Channel width, ft.	29
Average liquid depth, ft.	15
Total effective volume, cubic feet	3,080,000
Detention time, hrs. @300 mgd	1.84
D. Secondary Sedimentation Tanks
Number of tanks	12
Year Constructed	6 in 1956
U in 1957
2 in 1962
Number of channels each tank	U
Length of tank, ft.	250
Width of tank, ft.	80
Liquid depth, ft.	12
Total Surface area, sq. ft.	237,000
Total volume, cubic feet	2,772,000
Settling Rate, gpd/sq. ft. @300 mgd	1266
Detention period, hrs @300 mgd	1.66
F 8

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E.	Aeration Blower Equipment
Numbers of Blowers	U
Year Constructed	1956
Capacity each blower, cfm	40,000
F.	Sludge Thickening Tanks
Number of Tanks	6
Year Constructed	U in 1958
2 in 1963
Diameter, ft.	65
Sidewall liquid depth, ft.	10
Total surface area, sq. ft.	19,900
Total volume, cu. ft.	199,000
These units are operating at more than double accepted loadings which
cause serious loss of BOD and SS into the thickness overflow resulting
in excessively high recycled loads to the primary and secondary units.
G. Sludge Digestion Tanks
Number of tanks	12
Year Constructed	8 in 1935
A in 194.6
Diameter, ft.	84
Operating Sidewall water depth,	ft. 22
Total tank volume, cu. ft.	1,761,000
The tanks are in satisfactory condition and could be used in the future,
however, the mixing systems in several should be replaced with more
reliable ones.
F 9

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H. Elutriation Tanks
Number of batteries	2
Year Constructed	1 in 1935
1 in 1958
Number of tanks/battery	2
Length of tank, ft.	70
Width of tank, ft.	32
Depth of tank, ft.	11.75
Total volume, cu. ft.	100,000
Total surface area, sq.	ft. 8,900
In 1968, these units were operated at more than three times normally
accepted loadings, resulting in overflow of excessive quantities of BOD
and suspended solids in the plant effluent,
I. Sludge Dewatering Facility
Year Constructed	1935
Number of vacuum filters	4
Total filtration capacity, sq. ft.	2,000
The filters were renovated about 1959, but are becoming a continual
maintenance problem due to the difficulty of obtaining replacement parts.
J. Sludge Drying and Incineration Facility
Year	1952
No. flash drying and incinerator units	3
Total Drying capacity, tons per day, wet	549
Total incinerator capacity, tons per day, wet 570
F 10

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These facilities have not been operated except for a few months
immediately after installation since it has been possible to dispose of
the sludge cake by mixing it with soil on the plant site and allowing
it to be removed for use as a loam which has resulted in substantial
savings.
F 11

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•n
H-1
ro

¦ j—n
MIQRIT REMOVAL J
.x HSCREEN
\V CHAMBER
sS
1,791,000 POPULATION
290 M.G.D. MAXIMUM SUMMER MONTH
PUMPING
STAT 10 N
too soo
WATER POLLUTION CONTROL PLANT
Figure F1
FLOW DIAGRAM
a »
V
4

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ss
78
81
72
57
72
78
77
72
76
78
71
80
86
78
76
79
76
72
78
73
71
74
73
TABLE F-l
Avg. Plant Performance
D. C. Water Pollution Control Plant
Effluent to River lb/day
BOD	SS
211
63,000
65,000
220
66,000
58,000
232
89,000
107,000
248
128,000
153,000
253
103,000
102,000
270
104,000
81,000
265
95,000
95,000
259
100,000
107,000
245
108,000
95,000
252
116,000
92,000
248
115,000
119,000
255
102,000
80,000
269
105,000
72,000
262
153,000
89,000
252
130,000
88,000
264
126,000
85,000
273
114,000
95,000
279
130,000
88,000
287
138,000
94,000
284
140,000
99,000
291
161,000
96,000
279
168,000
91,000
272
137,000
88,000

F-L3

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TABLE ( F 2)
PRIOR EPA CONSTRUCTION GRANTS PROJECTS IN THE DISTRICT OF COLUMBIA
Project
Description
Total Eligible
Project Cost
Federal
Grant
Projects Completed
WPC-DC-1
Blue Plains
WPC-DC-2
District of Columbia
WPC-DC-3
District of Columbia
WPC-DC-4
District of Columbia
WPC-DC-5
District of Columbia
WPC-DC-6
Lorton Reformatory
WPC-DC-7
Glen Dale
WPC-DC-8
District of Columbia
WPC-DC-9
District of Columbia
WPC-DC-10
District of Columbia
WPC-DC-11
District of Columbia
WPC-DC-13
District of Columbia
WPC-DC-14
District of Columbia
WPC-DC-15
District of Columbia
Blue Plains plant (1st stage) $6,080,778
Secondary Treatment
Main Pumping Station	304,596
Intercepting sewer and	2,399,308
Pumping Station
Blue Plains plant (2nd stage)	1,107,616
Blue Plains plant (3rd stage)	2,229,415
Pumping Station with force	635,64.8
main, interceptors, and a
secondary type sewage treatment
plant
Intercepting sewer, syphon,	86,119
and appurtenances
An intercepting sewer,	826,823
including a syphon across
Anacostia River between
Main Pumping Station and
Poplar Point Pumping Station
Pumping station and intercepting 1,597,871
sewer
Additions to Blue Plains plant 1,412,128
Force main and interceptor	2,251,826
relief sewer
Additions to D.C. treatment	44-8,066
plant
Additions to D.C. treatment	346,508
plant
Intercepting sewer	217,754
F-14
$ 250,000
91,378
250,000
250,000
250,000
190,694
25,146
248,047
250,000
423,638
600,000
134,419
103,952
65,326

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TABLE F 2 (CON'T)
PRIOR EPA CONSTRUCTION GRANTS PROJECTS IN THE DISTRICT OF COLUMBIA
Project
Description
Total Eligible
Project Cost
Federal
Grant
WPC-DC-16
.District of Columbia
WPC-DC-17
District of Columbia
Upper Potomac Relief Sewer
Intercepting Sewer and
Pumping Station
TOTAL
$ 2,^69,982
1,748,800
124,163,238
$ 600,000
517,590
$4,250,190
Construction Completed But Not Clo sed Out
WPC-DC-19	Outfall Relief Sewer
District of Columbia
3,508,000
758,740
Pro.jects Under Construction
WPC-DC-12
District of Columbia
WPC-DC-18
District of Columbia
Potomac Force Mains
Relief Sewer
Upper Potomac Interceptor
Relief Georgetown Area
8,265,787
3,086,000
TOTAL $11,351,787
TOTAL ALL PROJECTS $39,023,025
600,000
760,700
L,360,700
3,369,630
F- 15

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APPENDIX G
PERTINENT CONTRACTS CONCERNING
WASTEWATER TREATMENT IN
THE METROPOLITAN WASHINGTON AREA
1.	Memorandum of Understanding
2.	October 1971 Agreement Concerning
Interim Wastewater Treatment
3.	The 1954 Agreement with WSSC
4.	The 1967 Agreement with WSSC for
Use of the Potomac Interceptor

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MEMORANDUM OF UNDERSTANDING
THE ATTACHED COPY OF THE ORIGINAL
MEMORANDUM OF UNDERSTANDING WAS
PREPARED BY THE MIDDLE ATLANTIC
REGION OF THE FWQA, 918 EMMET STREET,
CHARLOTTESVILLE, VIRGINIA 22901
OCTOBER 10, 1970
G1

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MEMORANDUM OF UNDERSTANDING
ON
WASHINGTON METROPOLITAN REGIONAL
WATER POLLUTION CONTROL PLAN
The District of Columbia has determined that the requirement for a high
quality effluent to comply with the water quality standards established pursuant
to Public Law 89-234 (Federal Water Quality Act of 1965), and site limitations due
to the objection of the Department of the Interior to the reclamation of submerged
lands adjacent to the Blue Plains plant, imposes a limitation on capacity for
treatment at that site of 309 million gallons per day. In addition, the limitatioi
at Blue Plains is determined by flows in the Potomac River and their relationship
to current levels of waste treatment technology. However, as construction of the
additional and improved treatment facilities proceeds, as further technological
advances become known and available, and as experience is acquired in the enlarged
plant it may be that additional capacity can be provided. Studies in that con-
nection will be continued. The District of Columbia agrees, subject to the avail-
ability of funds, to develop the plant to the 309 mgd level now and make part of
the capacity available to Maryland and Virginia jurisdictions now served by the
facility in accordance with the following terms:
1. Work will proceed on the following schedule:
A. Primary and sludge processing facilities:
1.	Preliminary plans completed
2.	Final plans completed
2/1/69
(a)	Primary
(b)	Sludge Processing
8/1/70
1/1/71
10/21/70
2/14/71
5/19/73
3.	Financing arranged
4.	Start construction
5.	Finish construction
B. Secondary facilities, including equipment for chemical
feed to the biological secondary process to achieve at
least 90% BOD removal and about 90% phosphorous removal.
3.	Financing arranged
4.	Start construction
5.	Finish construction
1.	Preliminary plans completed
2.	Final plans completed
2/1/69
7/1/71
7/1/71
10/11/71
11/1/74
C. Advanced waste treatment facilities capable of limiting BOD max-
imum loading to 12,700 lb./day, phosphorous maximum loading to
560 lbs./day, and nitrogen maximum 6,130 lbs./day in the treatment
plant effluent.
G2

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BOD and P	N
1.	Preliminary pLans completed	Mar. 1972 Aug. 1974
2.	Final plans completed	Mar. 1973 Aug. 1974
3.	Financing arranged	Mar. 1973 Aug. 1974
4.	Start construction	July 1973 Dec. 1974
5.	Finish construction	July 1976 Dec. 1977
2. The allocation of the 309 mgd capacity of the Blue Plains treatment
plant when completed is initially as	follows:
District of Columbia	135 mgd
Potomac Interceptor	18 mgd
Washington Suburban
Sanitary Commission	148 mgd
Virginia (Pimmit Run
Interceptor)	8 mgd
309 mgd
It is recognized that the population projections of the Maryland National
Capital Park and Planning Commission for the WSSC service area indicate a WSSC
need for 175 mgd of capacity in 1980. Every effort will be made to provide for
these flows, but in the event that this is not feasible, an initial capacity of
148 mgd, (in addition to Washington Suburban Sanitary Commission's share of the
Potomac Interceptor flow) which is expected to be adequate until 1977, will be
provided.
3.	Capital costs for the Blue Plains treatment facility, after deducting
federal grants, will be shared by the District, WSSC, and Virginia (Pimmit Run
only) in proportion to the initial allocations in the plant as set forth in para-
graph 2 above.
4.	Plans will proceed on the basis that federal funds, in the maximum
amount provided by applicable legislation (currently amounting to 55% of the
estimated cost of each portion of the work described in paragraph 1 above), will
be awarded upon certification by the District of Columbia that all local contri-
butions determined in accordance with paragraph 3 above are committed and avail-
able on request. The intent of this provision is that the District of Columbia
will not finance the WSSC and Virginia (Pimmit Run only) shares. The Washington
Suburban Sanitary Commission and Fairfax County (Pimmit Run only) will obligate
their share of each project prior to the award of contracts. Funds will not be
transferred, however, until required to make progress payments.
5.	It is recognized by all parties that the proposed Blue Plains expansion
will not be adequate to serve all future flows from the areas presently tributary
to the Blue Plains facility and that all jurisdictions must plan immediately to
provide adequate treatment for flows in excess of those that can be accepted in
the Blue Plains regional treatment facility. Therefore, the appropriate parties
G3

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will.provide another regional plant or plants in which one or more of the parties
may participate. The District shall be entitled to purchase capacity in such plant
or plants on the same basis as provided for herein. Upon agreement of the parties
involved at such time, the District's required capacity at the additional regional
plant pr plants may be provided by the payment therefor, and an exchange of such
paid for capacity f6r such other party's capacity at Blue Plains.
6.	The District of Columbia recognizes that to meet its ultimate require-
ments, it must provide treatment for District of Columbia sewage in excess of the
135 mgd cited in paragraph 2 above, at at least 65 mgd* of Potomac Interceptor
sewage. WSSC has retained consultants to advise it as to an overall sewerage plan
including sewage treatment plant sites and capacities. This report is to be com-
pleted by February 1971, but in recognition of the extant problem and its projected
needs, the WSSC has already formulated a projected schedule for site selection,
design, and construction of an additional regional plant and will pursue its com-
pletion subject to the availability of funds and the operation of the applicable
provisions of Maryland law. The District of Columbia and Virginia will be invited
to participate in financing a portion of the cost of the additional regional plant
in proportion to their allocated flow to the total plant capacity in the same
manner as provided in paragraph 3 above. Each participant will be entitled to use,
upon completion of the construction and placing of the plant into service, that
capacity allocated and paid for. The maintenance and operating costs as well as
the cost of all pipelines, pumping stations, etc. shall be shared by all parti-
cipants in the same manner as Blue Plains. Should t^he District of Columbia or
Virginia undertake to construct additional regional sewage treatment facilities,
the same conditions as described above will apply,
7.	All parties will make an annual evaluation and five-year projection of
sewage flows. In the event projected flows exceed the available capacity, the co-
operating parties agree to plan and construct the facilities necessary to accom-
modate the anticipated flows.
*Based upon design projection as follows:
Jurisdiction
Virginia - Fairfax Co,
- Loudoun Co,
Dulles Intern.
Airport
Maryland - WSSC
Total
Equivalent
Population
176,250
143,100
20,000
172.500
511,850
Average Daily Flow
Plus Infiltration Allow,
22.05 mgd
17.93 mgd
3.75 mgd
21.57 mgd
65.30 mgd
G4

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8. The proposed schedule for the regional plant mentioned in paragraph
6 above follows:
Preliminary report completed	February 1971
Site selection	March 1971
Participants' capacities allocated	June 1971
Preliminary plans completed	June 1972
Site purchase completed	March 1973
Final plans completed	January 1974
Start construction	September 1974
Complete construction	June 1977
9. There extant agreements between and among the parties hereto and
others with respt "> the transmission and treatment of sewage at D. C. facilities
and payment therei Nothing herein contained shall in any way abrogate or modify
such agreements.
10. The foregt. provisions of this Memorandum of Understanding reflect
the parties' firm desi * and intention to upgrade the Blue Plains Plant, establish
another regional plant, and to take other measures directed toward early achieve-
ment of the water quality standards as established under the Federal Water Quality
Act of 1965. Interim actions with respect to treatment and collection will be
taken by the parties responsible to prevent further degradation of water quality
during the upgrading and expansion of Blue Plains, enabling normal incremental
increase in flows to be accommodated and system reinforcements to proceed. Com-
mencing immediately, the following actions will be investigated, tested and then
applied as ascertained to be advantageous to the goal.
1.	Use of polyelectrolytes or other precipitating chemicals.
2.	Installation of selected advanced processes at an earlier date.
3.	Use of micro-strainers.
4.	Use of special polymer to increase flow capacity at flow bottlenecks.
5.	Selected construction to diminish hydraulic bottlenecks.
6.	Chlorination at pumping facilities and other up-sewer locations.
7.	Oxygenation or other treatment in-sewer.
8.	In stream aeration.
9.	Minimize peak discharges through use of storage facilities or by other
means.
10.	Use of additional treatment processes during critical flow season.
11.	Use of separate small treatment plants on an interim basis.
12.	Reduction of storm water flows in sanitary sewers.
13.	Control infiltration.
14.	Diversion of sewage flows from Blue Plains to other treatment facilities,
15.	Improve sewage collection facilities to prevent raw sewage overflows.
Such interim actions which are listed above are not exclusive of any other measure
which may also be found advantageous, nor is the list intended to reflect a sequen-
tial basis of test and application, but rather one or more actions may be under-
taken concurrently. The costs of any such interim measure which is not part
G5

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of or does not have permanent utility in the completed, upgraded plant construction
or operation thereof, shall be paid for by the party or parties whose interim flow
increase is accommodated thereby. The parties to this Memorandum of Understanding
are District of Columbia, Washington Suburban Sanitary Commission and Fairfax County«
Executed for the parties as follows:
District of Columbia
By: /S/ Norman E. Jackson	Date: 9/23/70	____
Washington Suburban Sanitary Commission
By: /S/ Salvatore Barranca	Date: 9/23/70	___
Fairfax County, Virginia
By: /S/ G. J. Kelley	 Date: 10/1/70	
The United States Department of the Interior, District of Columbia and the
States of Maryland and Virginia by their representatives have also participated
in the discussions which preceded and led to the formulation of this Memorandum
of Understanding, and they execute the same to indicate that fact.
United States Department of the Interior
By: /S/ Fred J. Russell	Date: 10/7/70		
Under Secretary
District of Columbia
By: /S/ Malcolm C. Hope	Date: 9/24/70
State of Maryland
By: /S/ Thomas D. McKewen	Date: 9/24/70
State of Virginia
By: /S/ Noman M. Cole, Jr.	Date: 10/7/70	_____
Virginia's concurrence is subject to the reservations
and clarifications in the letter from N. M. Cole to Norman
Jackson dated October 7, 1970, which is attached.
G6

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COPY OF A LETTER FROM Noman M. Cole, Jr. to Norman £• Jackson
ON VIRGINIA STATt WATER CONTROL BOARD LETTERHEAD
Mr. Nornian E. Jackson, Director
Department of Sanitary Engineering
Government of the District of Columbia
415 - 12th Street, N. W«,
Washington, D. C.
Subject: Memorandum of Understanding on Washington
Metropolitan Regional Water Pollution Control Plan
Dear Mr. Jackson:
The State of Virginia signs the Memorandum of Understanding
concerning the Blue Plains Treatment Plant subject to the following clarifi-
cations and reservations;
1.	The construction effort described in the schedules given in paragraphs
1A and IB of the subject memorandum should not result in a monthly dis-
charge of BOD to the Potomac River from the Blue Plains Plant of more
limn shown on the attached curve. This curve was provided by Mr. Paul
Frcosc of your office as a clarification of the plant performance which
will have to be achieved during this portion of the construction effort.
2,	Willi regard to the schedules (see paragraphs IB and 1C) for installation
and completion of secondary and advanced waste treatment (AWT) facili-
ties for very high degrees of BOD and phosphorous removal, our signa-
ture does not mean we concur with such a schedule. In our opinion, rt
i^presents unnecessary delays in the start of construction and completion
of facilities which are vital to clean up tlie algae problem in the Potomac.
As presentlv proposed, construction of vital A.WT facilities would not be-
tun for another 3 years, and would not be completed for approximately
(~> years. In this regard, we note that modifications of Virginia treatment
plants Are proceeding on schedules which will complete such AWT facili-
ties by 1973.
Wo have listened to the rationale for such delays at the Blue Plains Plant;
and when we compared your proposal to what other technologies in this
country are able to accomplish, we can only conclude that unimaginative
approaches and inadequate funds have been used. In a country which can
start and complete construction of large^ aircraft carriers, large trans-
port aircraft, and missile projects in an^4 year period and which has
gone from the earth to the moon in 9 years, we see no reason why the
G7

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advanced waste treatment facilities for very high degrees of BOD and
phosphorous removal at the Blue Plains Plant should take 6 years.
In this regard, Virginia communities have, on a comparative economic
basis, shouldered their responsibility for cleaning up the river of our
Nation's Capital by the end of 1973 and we are disturbed to see that the
District of Columbia has not seen fit to do likewise. Accordingly, we
suggest that more imaginative and accelerated approaches be taken to
accomplish the design and construction so that such facilities are com-
pleted no later than March 1974 (e. g., 3-1/2 years from now) and that
the necessary funds be requested to accomplish this goal.
3.	We do not understand why Virginia treatment plants have to install AWT
facilities to remove nitrogen by 1973 and the Blue Plains Plant not until
the very end of 1977. This is of particular concern since (a) the techno-
logy of nitrogen removal developed to date is such that the performance
and reliability of such removal systems have had limited success and
are very dependent on such things as seasonal weather conditions, etc.,
and (b) data from the Tahoe Plant and Lake Washington indicate that very
high degrees of BOD and phosphorous removals in their areas are suffi-
cient to solve the algae problem. Accordingly, it would appear more
reasonable if everyone had to remove nitrogen by the same date as Blue
Plains and possibly by then the technology for its removal would be better
defined from information generated by the EViQA research program and
may even show that its removal is not essential.
4.	The meaning of the second sentence of paragraph 10 is not clear and can
be read several different ways. In discussions with Mr. Freese and
Mr. W. L. Rogers of Interior, it is understood to mean the following:
Normal incremental increase in flow to plant shall only be
allowed if the interim actions with respect to treatment and
collection are such that there is no further degradation of
water quality in the Potomac (i.e., no more than 100,000 lbs.
of BOD per day as measured on a monthly average) between
now and January 1, 1973. After that date, the BOD load to
the river shall be as shown on the attached figure.
Subject to the above reservations and clarifications, Virginia
concurs with the subject Memorandum of Understanding.
Sincerely yours,
/S/ Noman M. Cole, Jr.
Noman M. Cole, Jr.
Chairman
Virginia State Water Control Board
G8

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PROJECTED BOD LOADING TO POTOMAC RIVER FROM BLUE PLAINS TREATMENT FACILITY
00,000

75,000
a
Unknown load from raw
storm overflows.
50,000
25,000
--Mineral addition to existing facilities
^Expansion of primary facilities
¦'	""'Expansion of secondary facilities
AWT (BOD & P)
X
AWT
1/71
JL
1/72
1/ 73
1/74
1/75
1/76
1/77
1/78
TIME
Presented to Virginia SWCB
at 10/2/70 by P. V. Freese

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UCTOBER 1971 AGREEMENT CONCERNING
INTERIM WASTEWATER TREATMENT
AGREEMENT
BLUE PLAINS INTERIM TREATMENT PROGRAM
IMPLEMENTATION OF PARAGRAPH # 10
OF THE OCTOBER 1970 MEMORANDUM OF UNDERSTANDING
BY THE D. C. , FAIRFAX COUNTY AND WSSC
October 18, 1971
PROBLEM
The present pollutant load to the Potomac River from the Blue
Plains Plant varies from 95,000 to 153, 000 pounds per day on the basis
of monthly average figures. Overflows of sewage from the sewer system
contribute an additional loading of up to 25,000 pounds per day. At the time
of drafting the Memorandum of Understanding, it was anticipated that the
average BOD loading to the river would not exceed 100, 000 pounds per day.
This understanding was stated in a conditional statement appended to the
Memorandum by the State of Virginia. It is evident, therefore, that during
months of high flow present pollutant loads are exceeding those anticipated.
SUMMARY OF AGREEMENT TO SOLVE PROBLEM .
Basic agreement on an interim treatment program and on the
temporary closing of the Georgetown Gap has been reached by the District
of Columbia, WSSC, and Fairfax County.
The temporary closing of the Georgetown Gap and the interim
treatment program at uie Blue Plains PLant are expected to reduce the
L.otal pollutant load to the river to approximately 100, 000 lbs per day of
G10

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BOD^ or even less, hopefully. It is expected that this program will be
accomplished within the next 7 to 9 months. In essence, this should start
the Potomac River back on the long road to recovery and reclamation and,
thus, prevent further degradation of the river -- ie, , the objective set
forth in paragraph #10 of the October 1970 Memorandum of Understanding.
It is expected that the overall interim program will allow some
nominal additional flows to the plant between now and 197 5 when the major
upgrading of treatment and expansion of plant capacity to 309 MGD is
expected to be completed. At that time, the pollutant discharge to the
Potomac phnnlrtj-.^ on the order of 12, 000 lbs per day of BOD5 and 600
lbs per day of phosphorous. These latter pollutant loads from Blue Plains
are the loads EPA has determined as necessary to upgrade, protect, and
preserve the Potomac River.
Thus interim treatment will provide for continued reduction in the
BOD load to the Potomac River from the Blue Plains Plant from a peak
of 1 55,000 pounds per day in fiscal year 1956 to approximately 100,000
pounds per day in fiscal year 1973.
If for some unforeseen or unexpected reason the planned interim
program is not as successful in reducing the pollutant loads, then either
(a)	additional interim treatment steps must be taken at the plant or
(b)	additional flows restricted until the expanded and upgraded modifications
are completed at the plant.
Gil

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The interim treatment will involve the use of chemical additives
to supplement the present biological treatment process and therefore
improve the treatment plant's ability to remove pollutants from sewage
before the treated effluent is discharged into the river. This interim
program should also have the additional side benefit of removing over half
of the phosphorus since the chemical additives to be used will not only
improve removal of the BOD^ pollutant but also help remove the
phosphorus pollutants. The additional sludge generated by the interim
treatment program is to be removed and disposed of by the State of
Maryland.
The estimated annual cost for the interim treatment program is
approximately $5 million. The approximate share of this cost for D. C. ,
WSSC, and Fairfax County is $1,950 million, $2. 880 million, and $0,17 0
million respectively, which is proportional to incremental increases in
flows above the design capacity of the plant.
Specific details of the agreements are attached herein.
G12

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POINT OF AGREEMENT # 1
Agreement on an interim treatment program at the Blue Plains Plant
and on a plan for temporary closing of the Georgetown Gap has been reached
by the D. C. , WSSC, and Fairfax County- The interim treatment program
at the Blue Plains Plant and the temporary closing of the Georgetown Gap
are expected to reduce the total BOD pollutant load to the Potomac River from
the D. C. sewage system to approximately 100, 000 lbs per day of BOD or
even less, hopefully. Thus, this program should meet the objectives set
forth in paragraph #10 of the October, 1970 Memorandum of Understanding.
The estimated cost for the interim treatment program is approximately
$5 million annually. The users of the Blue Plains Plant have agreed to pay
the expenses for such interim treatment on the basis of projected incremental
increases in flows between January 1969 (when total flow to the plant was
240 mgd) and December 1974 (when the advanced waste treatment plant is
planned to be completed). The flows and percentages to be used are as follows:
DC+PI	WSSC	VA	TOTAL
Jan 69 Flow, mgd 129	105 6	240
Jan 75 Flow, mgd 152	139 8	29 9
Increase, mgd 23	34 2	59
Percentage 39.	57.6 3.4	100.0
(PI - Potomac Interceptor)
G13

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The intent of this provision is that the District of Columbia will not
finance the WSSC and Virginia (Pimmit Run only) shares. The Washington
Suburban Sanitary Commission and Fairfax County (Pimmit Run only) will
obligate their share of the cost prior to award of annual contracts. Funds will
be transferred monthly as required to pay for supplies, materials and services.
Costs attributable to Potomac Interceptor users, determined by the above
method, will be recovered by upward adjustment of sewer charges. All charges
for interim chemical treatment are separated and in addition to present charges.
In the event that the pollutional load to the Potomac River is reduced
to less than 100, 000 pounds of BOD per day during the period of interim
chemical treatment, the method for determining payment by the participating
jurisdictions will be renegotiated (to be formalized in a supplemental agreement)
to reflect the upgrading of the total flow.
It is expected that this program will allow some nominal increases in
flows to the Blue Plains Plant between now and January 1975. These increases
are specifically defined elsewhere in this agreement and are subject to the
interim treatment program reducing the pollutant load to the river to
approximately 100, 000 lbs per day of BOD.
If for some unforeseen or unexpected reason the planned interim
treatment program is not as successful in reducing the pollutant loads, then
either (a) additional interim treatment steps must be taken at the plant or
(b) additional flows restricted until the expanded and upgraded modifications
of the Blue Plains Plant are completed. If such a situation should arise, the
parties will meet at that time to decide on the specific course of action to
n nrl 1 c ^urh a problem.	q]_4

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POINT OF AGREEMENT 2.
The Washington Suburban Sanitary Commission will be permitted to
make three additional connections to the D. C. System.
1.	A connection to the Rock Creek sewer will be permitted.
Sewage from fhe City of Rockville now being pumped to
Cabin John valley will be transferred to Rock Creek, thus
alleviating overflows into Cabin John Creek. Flows at this
connection will be restricted to a peak rate of two (2) mgd.
2.	A temporary connection of WSSC's proposed Anacostia force
main to the District of Columbia's Anacostia force main and
gravity sewer approximately 500 feet below the Penn- Central
railroad crossing of the Anacostia River will be permitted.
Flows at this connection will be restricted to a peak rate of
thirty (30) mgd. Upon completion of the advanced waste
treatment plant at Blue Plains or the WSSC force main to
that plant, whichever occurs first, this connection shall be
removed at WSSC's expense.
3.	A temporary connection of WSSC's proposed Cabin John
relief sewer to the Potomac Interceptor will be permitted.
Flow through this connection will be limited to a peak rate
of one (1) mgd either by the physical size of connection or
by a control device. This increase in Potomac Interceptor
flow is chargeable to the WSSC increase of 34.0 mgd as
G15

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shown in Points of Agreement #1 and #3. Upon completion
by the District of Columbia of the Upper Potomac Interceptor
Relief Sewer through Georgetown and the advanced waste
treatment plant at Blue Plains, a larger flow may be negotiate*
Connection 2 above will not be permitted prior to completion of the additional
primary facilities now under construction at the Blue Plains Plant. WSSC
will install and maintain on each of these connections a meter approved by
the District of Columbia. Monthly meter readings will be furnished to the
District of Columbia and to the Maryland Department of Health and Mental
Hygiene. The meters will be available to the District for inspection. In the
case of a malfunction WSSC shall repair the meter within thirty (30) days.
Flow estimates during such period may be made by WSSC, subject to the
District's approval.
G16

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POINT OF AGREEMENT ff 3
Incremental increases in flow shall not exceed the following until the
major modifications at the Blue Plains Plant are completed by January, 1975.
D. C.
WSSC
VA*
PI
Annual increase, mgd 1. 5
5. 66
0. 33
2. 33
Total increase between



1/69 and 1/75 9. 0
34. 0
2. 0
I4. 0**
* Pimmit Run Only
** A separate agreement among WSSC, D. C. and the Virginia
localities must be made for this for the breakdown of this
flow allotment.
The primary responsibility for ensuring that the above flow increases
are not exceeded rest with the governing bodies of the WSSC, Fairfax
County and the Loudoun County Sanitation Authority. To assist in the monitoring
of these flows so as to ensure that the increases from suburban areas are
within the required ^limits, the District of Columbia will submit a monthly
flow report to each of the above parties. This report will show the actual flow
(or best estimate) versus the flow limit increases established herein. In
addition, the District of Columbia will also provide the above parties with
monthly reports covering the following data on the Blue Plains Plant
performance, eg. total flow, breakdown of total flow by jurisdiction, total
pounds of BOD discharged to the river on a monthly average, etc. These
reports will also be forwarded to enforcement agencies of the states of
Maryland and Virginia who will assist D. C. to the maximum
G17

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extent of their laws to prevent jurisdictions within their states from exceeding
the allowable flow increases covered herein.
To facilitate the monitoring of flows, WSSC, Fairfax County and
the Loudoun County Sanitation Authority will provide D. C. each month with
any data it needs to compile the above flow information.
G18

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POINT OF AGREEMENT # 4
The District of Columbia agrees that it will initially bear the cost
of the capital improvements necessitated by and the result of the interim
chemical treatment program, the costs to be ultimately included in the
permanent expansion of the plant and therefore eligible for the approved
Federal Grant. Construction will be commenced as expeditiously as
possible and will be placed in operation no later than May 15, 1972. The
District of Columbia agrees to operate the interim processes at the treatment
plant and will fully comply with the requirements of this agreement and the
Memorandum of Understanding. The District further agrees to construct
a temporary pumping station and pipeline from about 36th Street, N. W. to
30th Street, N. W. to provide additional capacity of approximately two (2)
mgd until the Upper Potomac Interceptor Relief Sewer (Georgetown Gap) is
completed. The District will fund the construction and will recover the costs
by increasing user charges.
It is agreed that the D. C. will move without further delay to complete
the UPIR Sewer, thereby eliminating permanently sewage overflows in the
Georgetown waterfront area.
G19

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POINT OF AGREEMENT # 5
The Washington Suburban Sanitary Commission agrees to proceed
immediately with the designation of the site (or sites) and the preparation
of plans for the expansion of regional water pollution treatment capabilities
in accordance with the Memorandum of Understanding. Connection of the
WSSC proposed Anacostia force main to the D. C. Anacostia force main
and gravity sewer will be permitted when said site (or sites) for such a
.system has been designated and approved by the appropriate jurisdictions.
I
G20

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POINT OF AGREEMENT # 6
The State of Maryland, operating through the Maryland Environmental
Service, will provide for the disposal of all sludge resulting from interim
r-.bemical treatment of sewage at the Blue Plains Plant. * This service shall
be. furnished as a non-profit operation and shall be paid to the Maryland
)<)nvir onmental Service by the District of Columbia from monies collected
from the participating jurisdictions as provided above. Such sludge disposal
will be subject to review with local jurisdictions in which such disposal sites
are located, and such coordination and review as required by appropriate
Maryland laws and regulations.
-;See the News Release dated October 13, 1971 by James B. Coulter, Maryland's
Secretary of Natural Resources.
G21

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POINT OF AGREEMENT # 7
This agreement is entered into for the purpose of implementing
{.he provisions of Article 10 of the October 1970 Memorandum of Under-
standing and modifies both that document and applicable extant agreements
to the extent that:
- Rate structure may be revised
Interim plant flows (that is, until 1975) are restricted as
shown herein; without implying any changes in ultimate flows
shown in extant agreements and in the Memorandum of
Understanding.
This agreement is entered to with the advice and consent of the
enforcement agencies of States of Maryland and Virginia.
Executing Parties:
district of Columbia'
/rf	j jj' , j ' /	A*'ft / /»"»/
jr** ¦>*	Date	•'

WASHINGTON SUBURBAN SANITARY COMMISSION
/
iy'' By	->/ y Date • ,/v 7
Per WSSC letter dated October 27f 1971
FAIRFAX COUNTY, VIRGINIA
By --.A/		Date	.V;/:
Concurring Enforcement Agencies: '
MARYLAND DEPT.	OF HEALTH & MENTAL HYGIENE
By	Date
MARYLAND DEPT. OF NATURAL RESOUR*
G22	/

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OMMISSIONCRS
CATOfcE t».WANCA
C tairmtn
*E W McfcOfcY, JR
Vie* Clitirfrtftft
OUISA GRAV£LU
TER C KL'MFl.JR.
IOHN J |.'.cfUftWrY
WASHINUIUIN bUDUKDHIN onmim\
4017 Hamilton Street, Hyattsville, Maryland 20781

APpleton 7-7700
STAFF
ROBERT J MclEOD
General Manager
4 Chief Engineer
JOHN 7 BONIFANT
Secretary
JAMES J LYNCH
Treasurer
JOHN 6 KENKEL
General Counsel
October 27, 1971
Government of the District of Columbia
Fairfax County, Virginia
Virginia Water Control Board
Maryland Department of Natural Resources
Maryland Department of Health and Mental Hygiene
In re: Blue Plains Interim Treatment
Program Agreement f October Iff, 1971
Gentlemen:
The Washington Suburban Sanitary Commission is pleased to advise
the other parties to the "Agreement: Blue Plains Interim Treatment
Program" bearing date of October 18, 1971, that it has formally executed
the Agreement today. The original of the Agreement was obtained from
the District of Columbia and after WSSC execution is being sent to the
Maryland Department of Health and Mental Hygiene for its endorsement
as in the Agreement provided, together with a copy of this letter.
Assuming that Department's execution, the fully signed Agreement
will then be returned to the District of Columbia, which will be the
repository of the original instrument. The original of this letter
will be appended to the Agreement but for convenience of the other
parties a separate copy is being sent to each of you now.
In authorizing the execution today, the Commission reviewed the
procedural steps, including the review and comment by the county
governing bodies of the two counties of the Washington Suburban Sanitary
District, namely, Montgomery County and Prince George's County. In
that connection, and from a desire to provide clarification and assistance
to all parties (including the Maryland regulatory agency which is called
upon to review and indicate its concurrence following the Commission's
execution), the following comments are made. For convenience, the
Washington Suburban Sanitary Commission's comments are expressed under
the Points of the Agreement to which they directly relate.
1. Point of Agreement 1. In expressing its approval of the
interim treatment proposition, the County Council of Montgomery County
stated its understanding of a premise of equitable distribution of
"Willing Water" — Symbol of Quality Service to the Suburban Maryland Area

-------
October 27, 1971
costs of the chemical treatment, with cost sharing among the participants
to be based upon total proportional flows if the load to the river is
reduced to a figure below 100,000 lbs. per day of BOD^, and a payment
by participants on the basis of incremental increases in flows, as
set forth in the Agreement, for the costs of the interim treatment
program for reducing the poll.utional load to that figure from any
higher amount. In that light, and since the Agreement itself specifies
that if the pollutional load to the Potomac River is reduced to less
than 100,000 lbs. of BOD per day the payment formula would be recast,
the Commission has prepared a formula to reflect its understanding of
cost sharing of the program. The understanding of that item is expressed
in the attachment hereto in both narative form and in mathematical
expression on the basis of a sample calculation.
2.	Point of Agreement 2. In reviewing this Point which provides
for additional connections of Washington Suburban Sanitary Commission's
system to that part of the regional system operated by the District of
Columbia, both the County Council of Montgomery County and the County
Executive expressed, as part of their approval of the whole Agreement,
an understanding that if implementation of Point 2 does not result in
relieving the sewage overflows in the Cabin John Basin the presently
expressed numerical figures concerning the connection to the Rock Creek
sewer and of the	Cabin John relief sewer to the Potomac
interceptor would be expected to be re-negotiated, so as to preclude
raw sewage overflows into the Cabin John Creek above the District of
Columbia water intake at Little Falls.
3.	Point of Agreement 5. Although this Point states that the
Commission agrees to proceed immediately with the designation of the
site or sites necessary for the expansion of regional wastewater
treatment capabilities in accordance with the October, 1970 Memorandum
of Understanding, all parties were aware both in connection with the
1970 Memorandum of Understanding and the present Agreement that the
actual selection of a site or sites for such installation(s) or
enlargement of existing capabilities in the Washington Suburban
Sanitary District must be made first by the county governing bodies
of Prince George's and Montgomery Counties. When the Maryland county,
or counties, concerned with the site location question have completed
their decisional procedures and communicated that determination to the
Commission, the Washington Suburban Sanitary Commission will then
proceed with the preparation of the plans for the expansion of the
regional water pollution control capabilities within the Sanitary
District effectuating the county designation.
4.	Point of Agreement 6. In reviewing the Agreement on
October 20, 1971, and again on October 26th, when the Prince George's
County Council expressed its approval of the interim treatment program
as recited in the Agreement, the County Council specifically stated
that insofar as the Maryland Environmental Services' implementation
of that state agency's agreement to provide for the disposition of
the additional sludge to be generated by the interim treatment program
G24

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October 27, 1971
night contemplate a place of disposal in Prince George's County, the
County recognizes the necessity for serving as the place for disposing
of its share of the sludge generated by the treatment. However, the
question of the location of a site within the county for increased
amounts of sludge assumes a premise of beneficial result to the county
and a recognition by the other .jurisdictions within the metropolitan
region that each should be willing to bear a part of the burden of
disposing of the sludge generated by the additional treatment attributable
to its area.
With the aforegoing comments and the attachment hereto, the
Commission executes and transmits the interim treatment program Agreement,
and urges all parties to provide for the expeditious implementation
of the program. The Commission has previously announced an intention
to cooperate with and assist the District of Columbia and the State of
Virginia in preventing further degradation of the Potomac River and
upgrading substantially the effluent produced by the growing population
and commercial endeavors of this important metropolitan region. With
each jurisdiction willing to bear its fair share of the cost of the
public program, the Commission is optimistic that our mutual concerns
can produce demonstrable results.
Attachment
cc: County Executive and
County Council of Montgomery County
County Executive and
County Council of Prince George's County
Sincerely yours,
G25

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ATTACHMENT TO WSSC'S LETTER OF 10-27-71
This agreement is predicated upon an anticipated reduction in
the BOD5 discharged as plant effluent from the Blue Plains Plant from
chemical treatment of the plant flow through the activated sludge basins.
For the purpose of sharing the cost of the chemicals, the labor required
for handling the chemicals and maintaining the chemical feeding equipment
and the disposal of the additional sludge which exceeds that resulting
from the previous processes at the plant, the following are adopted. It
is agreed that the "base load" shall be 100,000 pounds per day of BOD5.
Thifc is the load that was discharged to the river when the flow was 240 MGD
and the effluent BOD 5 was 50 mg per liter. Inasmuch as this condition was
approximated by the average of the flows in fiscal year 1968 and 1969, all
partj cipants "base flow" will be the average of the flow during these same
fiscal years, namely:
D.C.	P.I.	WSSC	Va.	Total
126	3	105	6	240 mgd
Each participantTs share of the "base load" will be calculated
on the preceding "base flow" at 50 mg per liter, namely:
D.C.	P.I.	WSSC	Va.	Total
52,500	1,200 43,800	2,500	100,000 lbs./day
If the chemically treated effluent has a BOD5 of less than 100,000
pounds per day, the proportionate share of the chemical treatment cost
ascribed to this improvement in accordance with the following formula shall
be shared by all parties in proportion to each party's annual flow to the
total annual flow of' all parties through the plant. The actual annual
average BOD5 in pounds per day shall be subtracted from 100,000 and divided
by the calculated BOD^ that would have occurred without chemical treatment.
This shall be the proportionate shore of the total chemical treatment cost
ascribed to improvement in the quality of the "base flow."
G26

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For the purpose of this calculation, it is agreed that the BOD5 ascribed
to the plant without the chemical treatment shall be the total plant flow
k 50 mg per liter x 8.33 and each participant's share shall be calculated
in a similar manner using each participant's annual flow. For the purpose
'of clarity a sample calculation is attached.
That portion of the total cost of chemical treatment that exceeds
the cost of improving the "base flow" shall be ascribed to treatment of the
increment of flow exceeding the "base flow". The share of each participant
shall be in the ratio of his "excess flow" to the total "excess flow."
The "excess flow" is defined as that portion of the total annual flow which
exceeds the "base flow."
If the parties' contemplation of success of the chemical treatment
to reduce pollutant loads is not brought to fruition on account of some
unforseen or unexpected reason, as referred to on page 2 of the Agreement,
and the chemically treated effluent has a BOD5 that is greater than 100,000
lbs. a day, then pending the additional steps referred to in the Agreement
the chemical treatment costs will be shared on the basis that the chemical
treatment is an improvement of each participant's portion of the "excess
flow" only and no portion of the chemical treatment cost will be shared in
the ratio of total plant flow. The Memorandum of Understanding of October
1970 contemplates and provides for the expansion and improvement of the
Blue Plains Plant on a permanent basis with construction in stages, with
additional secondary treatment being placed in service prior to completion
of the tertiary portion of the permanent plant improvement, and if the
additional secondary treatment is placed in service prior to completion
of the tertiary portion and the effluent from the plant is in the order of
magnitude projected therefor by the District of Columbia in its schedule
and graph entitled "BOD Loading to Potomac River from Blue 1 Plains Treatment
Facility" appended to the October 1970 memorandum of Understanding, then
G27

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:he cost: of chemical treatment will be shared on the basis of each
jart icipante's share of the total flow through the plant and not on an
'excess flow" basis.
The WSSC understands that each party will pay its share of the
treatment costs monthly on the basis of the cumulative monthly flows
as estimated by the District of Columbia, with the costs to be adjusted
at the end of each fiscal year on the basis of the total annual flows
for such year.
Samp.'le calculation:
Flows:

D. C.
P.I.
WSSC
Va.
Total
Year 197_
135
17
139
8
299 m<
Jan. 1969
126
3
105
6
240
Excess
9
14
34
2
59
% base I 969
52.5
1.2
43.9
2.4
100.
% excess
15.3
23.7
57.6
3.4
100.
BOD„
lbs./day
Base load	100,000
Chemically treated (year 197_J	70,000
Secondary 299 x 50 x 8.33=	124,000
Reduction due to interim treatment 124,000 -70,000= 54,000
Reduction below "base load" 100,000 -70,000=	30,000
Reduction of "excess load" 124,000-100,000=
24,000
Percent & cost Cost share below "base flow" 30,000/54,000=
$5,000,000 X 55.5%=
Cost share of "excess flow" 24,000/54,000=
$5,000,000 x 44.5%=
55.5%
$2,800,000
44.5%
$2,200,000
G28

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?e of costs:
D. C.	PI	WSSC Va^	Total
se j-low" $1,470,000	$33,000	$1,230,000 $67,000	$2,800,000
cess flow" 340,000	520,000	1,265,000 75,000	2,200,000
* Total $1,810,000	$553,000	$2,495,000 $142,000	$5,000,000
te: Above calculations are approximate slide rule results.
G 29

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THE 1954 AGREEMENT WITH WSSC
50. '£>Z1-L-
li-'ili	made in quir.tupiica.te this / U.	day o~
' : j'3 ^	, Siaefcson Hummed and Fifty-Jour, "by and between th
¦'I
C0S£jd$I0SERS Of 2iE DISTRICT 0? CCLoM3IA and the WftSHEfGOOH' SUSUaBAS
SAXI'jllRY G0VMISSX05, a body corporate created under the laws of the Sta
of Maryland,
V/1 i ITij £> SZ.I'1-i i
WKL23AS, the Congress of the United States, by an Act approved
September 1, 191c (39 Stat* 7-7)» authorized the connection of Maryland
sew or s and sewerage sj'stems with the sev/erage systems of the District
of Columbia, for the protection of streams flowing through United State
government parks and reservations in the District of Columbia from pol-
lution "by sewage, and authorised the said Commissioners of the District
of Columbia to enter into agreements, under certain terms and condi-
tions, v/ith the proper authorities of the State of Maryland in relation
thereto; and
WHERilAS, the General Assembly of the State of Maryland "by an Act
known as Chapter 122 of the Acts of 1918, as amended, created the Wash-
ington Suburban Sanitary Commission, a body corporate, and by viruua of
said Act and of other laws in force in the State of Maryland said Com-
mission was and is authorized to take over existing sewerage systems
G30

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. —-J......	oG_"vior.L^.g ^jvjOSi ^he Dxstrict oij Oc*j."Lull01.a S.ZLC. oper-
«-iw u^»>iv y a^.*w ,j	UiO \j	OjPw^caO^ c».CvCi.i w ^.Oiiciu. &yste«ilS anCi go
enter into contract:: anti agre&.'-ents wit?i the C o&ai s s i oner a of tiie Dis-
*£' —C u GX Co.l ul;0 j-C. ^.0**	OX Oil G- SaiC. systems With tne Sewerage
cysteas of the District of Columbia and concerning any other matter nec-
essary s advisable or uicpsdient for the proper construction, in.aintvariance
ar.d operation of the v,^.ter supply, sev/erags, drainage or refuse disposal
systems under its control or those under the control of the Commissioners
of the District of Columbia, which said contracts and agreements have the
full force and effect of contracts, between the District of Columbia and
the State of Maryland; ar.d
^hiiw-S, the said Commissioners of the District of Columbia and the
said v.'ashington Suburban Sanitary Cordis si on did enter into certain agree-
ments dated June 3? 1S24> and July 27» 192&, under the authority^ of the
aforesaid Acts of the Congress of the United States and of the General
u
1-.sseably of the State of i-'Iaryland, pursuant to which agreements the said
Washington Suburban Sanitary Commission constructed and provided con-
necting sewers, as necessary, to discharge sewage from the aforementioned
areas into certain of the sewerage systems of the District of Coluiabia
in such nanner as to free certain of the streams entering the District
of Coluabia from pollution "by sanitary sewage; and
V.'PESEA.S, the great increase in population of the areas of Maryland
which normally do or would discharge sewage into streams which flow
through United States government parks and reservations in the District-
of Columbia, and the corresponding actual and potential increase in the
G31

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— 4.' — j v —	ClOv> .-> ci.i^v!L	O.^.oC^ZrXj. ^© >bXiCO u 110 O^jv/O^cvqU ^ v ~>***
03. g—'-j £)j.'*j\jj?j.c?& o« oo-LwwiiiO^.a &nd «:i^u m&xcl s	, reou^.ros
jij.0	Gn.o XjcSi? C-L0'3 n^reuO OG revised and Superseded Oy
UGW, ZEii-iTOliJ, in consideration of the premisos, and of the m\i-
y iial D^nol^tb vO Oe dCjTJ. V^C. tnereX rom , and Of wiT.0 respective *Unu.Or—
talcing-3» promisee,, and ccvenants of the parties hereto as hereinafter
contained, the Commisoioner;j of the District of Columbia, hereinafter
cbiiled ''District11 , hereby agree to permit the connection of sewers and
sewerage system;* in Maryland and under or subject to the jurisdiction
af the Washington Suburban Sanitary Commission, hereinafter called
¦'Commission", with the leverage systems of the District, and to handle,
pump and treat all sewage delivered to the District of Columbia sew-
erage systems through each connection therewith of a sewer or sewerage
system from Maryland properties or Commission sewers or sewerage sys-
tems, and the Commission agrees to permit the connection of sewers and
sewerage systems in the District of Columbia and under or subject to
the jurisdiction of the District with sewers and sewerage systems of
the Commission, under the following terms and conditions;
Section 1. (A) Every connection of a sewer of either party
hereto to a sewerage system of the other party shall be made az or
near the District line at such points as the natural drainage of the
areas to be sewered require, each such connection to be made upon the
basis of prior agreement between the Director of Sanitary Engineering,
D. C., and the Chief Engineer of the Commission.
G32

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(£) J_ny proper«y lying in Maryland and abutting a
District ox CoiuiiVbia sanitary service sewer, shall "be pernio ted to con-
nect with the said District service sewer upon written application to*
and written consent from, the Department of Sanitary Engineering, D. C.,
provided such, connection is roade in accordance with District of Coluvfoia
regulations and that payment be LB.de by the Commission to the Collector
of Taxes, D. C., of an amount cGlial to the charge or assessment which.,
if the property to "be connected were located in the District of Columbia,
would "be made "by the District of Columbia pursuant to laws or regulations
in force in the District of Columbia at the time permission to make such
connection is given, without regard to the amount of any assessment or
charge the Commission £sy collect for itself from the owner of such
property for said connection.
(C) Any property lying within the District of Columbia
shall be permitted to connect with, a Commission sanitary service sewer
upon written application 'oo, and written consent from, the Cora?/! 5 si on,
provided such connection is made in accordance v/ith Coruraission regula-
tions and that payment is Eade to the Coiunission by the person applying
for such permission of an amount calculated on the same basis as the
amomit which would "be paid "oy the Commission to the District of Columbia
on behalf of a similar Maryland property making a connection to tho sew-
erage oysters of she District of Columbia at such time.
Section 2. The Co^-iission, as to its sewers draining into the sew-
erage systems of the District, and the District, as to its sewers drain-
ing into the sewerage systems of the Comi'iission, shall prevent insofar
as possible the passage of any drainage other than sanitary sewage or
G33

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s.g'c d^;rimontal ;c the coverage systems or treatment processes,
-.jLall use every practicable precaution in construction and in regu-
lations governing uho u^e of sewers and sewerage systems to exclude
therefrom surface water or rain wa'cer except from areaways and depressed
driveways which may be drained in accordance with the plumbing regula-
G-i*0_.Jj jJiUiC-jlt_*	o Clw.b- 0.i. i.C~Xe u a*on.
section K~"j	O— Gom^iX s s—on wnicn discnarge in^o one
sewerage systems of -she Liis-orict shall be provided with sewage flow
meters whenever the use of such meters is practicable. The practica-
bility of neteringj and ths size and type of meter and the location
thereof, shall, in each ins "canoe, "oe determined "by agreement of the
Ihgineers of the parties hereto* The entire cost of each meter in-
stallation shall "be borne by the Commission.
(B)	Each sewage flow meter shall be operated and
maintained "by the party hereto within whose jurisdiction such meter
i3 located, "but all costs of such operation and maintenance shall be
paid by tho Commission, and both parties may participate from time to
time in joint readings of all sewage meters and in joint inspections
of such meters.
(C)	hi ease a sewage flow meter fails to function
from any cause, the sewage flow for the period of such failure shall
bo considered as equal to the flow as determined during the most re-
cent corresponding period the meter was in satisfactory operation,
and if there is no such corresponding period the flow shall be de-
termined or estimated in such manner as shall be agreeable to the
G34

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Engineers of the parties hereto.
Section 4-. (A) The Commission shall pay annually to the District
the actual costs to the District of handling, pumping and. treating all
sewage delivered to the District sewerage systems through each connec-
tion therewith of a sewer or sewerage system of the Commission or of a
Maryland property. Such payments, denominated "sewage flow charges",
shall consist of the following amounts:
(1)	An amount (herein called "Number 1 Sewage Flow Charge
Amount") equal to such portion of the total operation, repair and
maintenance costs, including overhead, of each District facility
which handles sewage from Maryland as the total annual flow of
Maryland sewage in the particular facility bears to the total an-
nual flow of all sewage in such facility. The annual costs of op-
eration, repair and maintenance shall be determined from the records
of actual costs of operation and maintenance which are kept by the
District with respect to each facility. Said records shall be sub-
ject to Inspection by the Commission or its duly authorized agent.
To the total of these costs for each facility shall be added four
per cent (1$) thereof as overhead.
(2)	An amount (herein called "Number 2 Sewage Flow Charge
Amount") with respect to each District facility, exclusive of
lateral branches conveying sewage to interceptors, constructed or
for the construction of which funds were obligated prior to
li 195^» which handles sewage from Maryland, such payment to be
a sum equal in the case of
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Ir.io--cio'ioz,s3 to one per cent (1$)
Go buildings, to one and one-half per cent (1-1f2f>)
c. I^uipiuent, to four per cent (*$)
of the Ooiiiux^cion* s proportionate share of the value of each such
facility* As used herein tho Commissi on1 s proportionate share of
tha value of each District facility shall "be such portion of the
total cost to thi District of each such facility as the total an-
nual flew of Maryland sewage in the particular facility "bears to
thi total annual flow of ail sewage in such facility#
At such tii_5 as any facility as to which, the N'^uoer 2 Sewage
'j1 low Charge Amount is "being paid shall "be abandoned, or replaced
'oy ano"uncir facility toward the cost of whose construction th«3
Coirriission shall have paid its proportional share as hereinafter
provided, the further payment of the Huiabsr 2 Sev/age Plow Charge
Aiaount with respect to such original facility shall cease.
(B)	The Coi^icsion shall pay to the District the Coa-
nission's share of the cos'o of restoring or replacing each District fa-
cility, exclusive of lateral branches conveying sewage to interceptors,
which handles sewage from Maryland® Upon the restoration or replace-
ment of any such facility, or part thereof3 the District will charge
the OoEi.ussiorJ s share cf the actual cost of such restoration or re-
placement to a !:Hsceivacloi1! account as described in Section 6.
(C)	She Cc;n^ission!s share of the cost of restora-
tion or roplaceincnt, as used in subsection (b) hereof, shall be so
rvach of the actual cost to the District of restoring or replacing
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~ aC ~ v y -j Or	v viiCi^Of y ^'iw» w±10 *;ikX^£>uIuUlll deS«.gn C*~p istO J» Gy c^SoJbgaCu.
to the Oozr-i^jion "bears to «hs :'^-^in:"JC:i design capacity assigned to both
parties with respect to cuoii facilitys or part thereof, as restored or
replaced. The rju>:i£-'usn design capacity assigned to each party shall be
such raariniLffli capacity at peak flow as each such party notifies the other
party it desires incorporated in the restored or replaced facility and
which shall be actually incorporated in she design thereof., In the e-
vent the District shall notify the Commission that restoration or re-
placement of a facility or part thereof is intended and the Ccissission
fails to notify the Die trice of the aa^i&ua design capacity which the
Gosmissior. desires to have incorporated in such facility, or part thereof,
the Coir^iisGion shall bo deeded to have requested a rcaviaroEi design capa-
city s-ufficieat only to accomodate -che greatest actual peak flow of
i-Iaryland sewage through such facility, or part thereof» prior -co -:ho
date restoration or replacement work is commenced,
(D) i"le cognizing that through parts of its length the
0::on Hun Interceptor Sower is situated in the District and through other
parte of its length this sar.e sewer is situated in Marylands and recog-
nising that 3ewage originating in the District is conveyed thresh the
portions of this sewer situated in Maryland and sewage originating in
¦•iaryland is conveyed through the other portions of this sewer situated
in the District, it is hereby agreed* any provision in Section U(A) to
the contrary notwithstanding, that the charges payable "by the Ccu.vission
for Maryland sewage flows therein shall "be as follows;
(1) The Nunber 1 Sewage Flow Charge Amounts shall "bo based on
G37

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the flows measured by sewage raeter, the flows so metered to be al-
located "between, the District and the Commission in proportion to
the ntunber of sewage unius as defined in Section S hereof as are
served in the respective jurisdictions upstream frora the said sew-
age ^eter„
(2) K'o FainDir 2 Sewage Flow Charge Amounts shall be paid with
respect to the existing Oxon Run Interceptor Sewer.
The Ccicr.iicsion shall pay its proportional pari: of the
cost of replacement of those portions of the said sev/er situated in the
District and carrying sewage originating in Maryland,, The District
shall pay its proportional part of the cost of replacement of those
•portions of the said sewer situated in Maryland and carrying sewage
originating in the District,.
Section	V.'lienever it may becoine necessary for either party
to plan an extension of its sev.erage system which would result in the
delivery of materially increased sewage flows into existing sewers of
the other party, the party contemplating such extension shall submit to
the other party general information as to said contemplated work, in-
cluding estimates of the increased flows resulting therefrom, for corti-
fication as to the availability of the other party's system to handle
the increased flow„
It is understood that the effect of routine service
sewer extensions will not be construed as resulting in the delivery of
materially increased flows, in the sense of this subsection; however,
not less often than once each year the Engineer of each party hereto
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Oxii^	oi otner par'cy his best 6j't/iz^vc as to tnG
ciVo^a^y iiiiQ. 21^iji^.iLlsAlu OJXUi0j.ci3S 0- ^Ci^.1 *b X C ci/u G U. CL'uTIjQ^ 'Ciie nOisw'C
sue citing year to "be delivered through each, of the major connections
to the several's cy stein of the other*
(jj) Whenever it shall "become necessary to add any
facilities to the sewerage systems of either party to this Agreement
in,, order to receive, handle, pump or treat sewage received from. the
other party, such facilities shall he constructed or installed as
promptly as practicable,, rj?he cost of such work (exclusive of lateral
branches conveying t;e^age to interceptors) shall be shared by the parties
hereto as provided in subsection (B) hereof. In the event of shortage
of funds, the parties agree to attempt to obtain funds as quickly as
possible for the purpose of constructing or installing such facilities#
Neither party shall be obligated to commence construction or installa-
tion of any additional facilities until (l) the other party has made
its share of the cost available to the constructing party or has other-
wise satisfied the constructing party that funds will be available on
demand, as may be mutually agreed at the time, and (2) the constructing
party has available sufficient funds (including funds which the other
party has already made available or will make available on demand) to
pay all estimated costs of such facility. All money paid to the Dis-
trict by the Commission as its share of construction costs under this
Section 5 shall be credited to an appropriate "Receivable" account as
described in Section 6, and all construction costs properly chargeable
to the Commission shall be charged to an appropriate "Receivable" account*
G39

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^s/} ±l. "tvjj	osc*s *uo coM^or'uCu
0_- install a nev; facility (a:;clusivc of lateral branches conveying sew-
age to interceptors) v;hich will or may handle sewage from Maryland, the
District will advise the Commission of ail pertinent facts concerning
such proposed const ruction or installation. The Commission shall
promptly advise the District whether it desires the District to in-
corporate in such facility any capacity for ths handling of Maryland
, and if so, state what maximum capacity at pealc flow it desires,
and furnish therewith all necessary design data, The District will con-
struct any each proposed facility of such capacity to make available to
the Comj.'.isszon for '„he handling of Maryland sewage the requested ma:ci-
mum capacity a'c peal: flow in accordance with tins elements as specified
"oy the Coja.'.iission in its design. data furnished to the District. Prior
to construction the District will notify the Commission of the maximum
capacity, at peak flow in accordance with tine elements specified "by
the District for which the facility has been designed for handling Dis-
trict sewage (without making provision for any capacity for the handling
of Maryland sewage, whether Maryland sewage will actually flow in the
same or in another facility), which shall "be deemed the "maximum design
capacity assigned" to the District with respect thereto.
(1) In the event S&aryland sewage will actually flow through
the nev/ facility, the requested maximum capacity, at peak flow
in accordance with time elements as specified "by the Commission
in its design data furnished to the District, shall be deemed the
::maximum design capacity assigned11 to the Commission with respect
un^reto.
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\ J *-• *1 —1 W O V 1 1/ J J J.CU-lC. t/	W « ^ j^iO w ^ ^ L*.'—j»	J* _ 0\'f W MM ^
t.u.3: liuW 'i.3.Cl_Li.'0y a„'_Ci Viii CoZ:i'i--SOi: i'iCU.6C'iS ohe District) wO CGil—
-li U 0— LlJ. 1. ~~ o'-l jT*S^ O C-*A G	^.uOXx*
iiiotlicir fae-lity for the eaiTi&go of karylaxd sevens, the ^aiirua
c^j^ci'oy., a'-; peak fiov; in accordance with tine elements specified
by the Co^Ttii3io;i in its design da-oa furnished to the District> by
which the availability of the other facility for actual carriage
of Maryland s&v;ago is increased, shall "be deeded the "maximum de-
sign capacity assigned" to the Commission with respect -co the new
~i aei li ty»
i'hs costs of construction shall be shared by the parties as provided in
Sub sect i o.i (jj) hereof.
In the event the Commission pays its proportionate share
of the cost of a new facility through which Maryland sewage will not
actually flow, brat whose construction will increase the availability of
another facility for the carriage of Maryland sewage, as described above,
then the District vail credit the amount cf such payment to the appro-
priate "Receivable" account for the restoration or replacement of the
facility whose availability for the carryirug of Maryland sewage has thu3
been increased but such credit shall never be available for application
to any other facility.
(D) Tae cost of each facility constructed or installed
under this section shall be paid by the parties hereto in the same pro-
portions as the maximum design capacity assigned to each party with re-
spect to such facility bears to the total maximum design capacity
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to "00Si	v/iwh rcsrowO'fc "to such facility,, Except ai piro-
v — G-w-- 'o^oww jxOu ^ j I-lC^T'^u—5 bl..G> ^ —C.lCii:l"UiIl CLOCi^^l C£.J)iiC —	x^"!lXCCL
^0 0 G - -• u>_j. \j"^j i'/.u u-- i Jvjwv v j 'w	^ c*-Oim X J* tsjy CO J3. £ yi7"u.C c/ 0 CL 01* iIau i/J^.L.i.o'i
sviSoc:-ion (£) hereof thai! be determined "07 lautual agreeaent prior
0 ^	u OX (JJTuuI1 lio u j-On 0r j.nw ualldtXOil*
(i) lit is understood that wherever used in this Sec-
tion 'chu orprec^cn ,Jc03'; of tho work11 shall raean the cost of the work
paid or payable from jhe fands or revenues of the parties hereto exclu-
sive of any construction costs paid or payable frora the proceeds of any
grant of Inderal fvinds made to either of the parties hereto pursuant to
S3'i3£, in-reduced in the Senate of the United States on March 15a 195^»
cr ouher similar special legislation, to aid in the construction of the
particular work whose cost is being divided between the parties hereto
under the ter:.;s 01 this Section.
Section 6,, -he District shall establish such number of accounts,
referred to in Sections 4(E), 5(2) and 5(C) and hereinafter in this
Agreement as "P.eceivable1* accounts, as may be necessary and appropriate,
to which, shall be charged all costs of restoration and replacement as
provided by Section ^-(ii), and ail construction costs as provided by
Section 5(3), and to which shall be credited all payments of such costs
by the Coi/Uiiis3ion and other credits authorized by Section 5(C)» k
separate account shall be established for all charges made within each
fiscal year with respect tco each separate facility or part thereof.
'i\ot later than JO days after a charge is roads to any "Receivable" ac-
count the District shall render to the Coivunission a statement of such
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V ±	Wm t/J.* C*«i (ye.'.,vj w^IXvL V ^e Cj.^ G^lOiL 00i- # Ql^
-------
i	^ — o v —Cr C >> «L t* 0 L>Cp 0—G & uho uppfcjr n/Ovo^^C
v""'./¦	^ ^ j^^ ^5 j w-iO j,0*i icay5 Upon aTi v Ow^l
—v • - ^ •/ ^	,_/s/>^'.' ^ Q« *0 — G^«0 ^G inuerO£}G ac 0 j? i' *!¦ 'i i ^ Gho ii'wby ^ ey *¦*
v'—	_yLi.. v v_i. —. j. u .. G«*.c» i* o O G!l GiiO v/0e*C OX SUl*i* COn-*
ulcn v^nt-l 1'37G °- 'i'-'iil such earlier year in which the annual av-
ura^e xla.'c o-'-v-criii^ _cl~£f Upper Potomac Interceptor fro:s Maryland exceed
ten (IGy i'.i.lliOii ^ailoas per day„
Section 7- (-'-) fi;ho District agrees that with respect to every
yiotriet facility, or par'; thereof, of which the Commission has paid
aii} or « ^/ui' j; ^>i. w..ij co^/ g ox cons oriJi.CGj.oii or replacement, Gne Conuiij.s~
Oo	v^	e ox so luucn of ifiiu Cdpc*Cxoy oi sucn
;-.ov; or replacement; facility, or part thereof, as does not exceed the
dc^i^n capacity chereof upon which was "based the Coi.iiiission: e
proportionate share of such cost of construction or replacement,
(B)	Hxeept to the extent set forth in subsection (A)
of this Section, the Cor^viosion recognizes that the District is pri-
nariiy entitled to the entire and exclusive use of all District fa-
cilities, and that if the District at any time in order to provide for
District sewage requires use of a theretofore jointly used District fa-
cility, cr par'o thereof> to an extent which will reduce its availability
to carry Maryland eewa^e the Commission is obligated to pay for any new
construction or replacement which thereby may becone necessary to meet
the Corurdssion® s current or future requirements for carriage of Maryland
sewage.
(C)	xhe parties recognize that, by the teras of other
G44

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section:: of th.iv;; Agreoiiisntj v&e Cooaission is not obligated to contrib-
ute toward the coot of any new construction unless it so elects, "but
that the Coirurlbsion r.ay not lav/fully discharge sewage frora Maryland into
a:"iy district facility or part thereof except to the extent of the capa-
city which has he in ;;:ade available in such District facility or part
thereof to the Co-uiaission by reason of the Gomnission's payment of its
proportionate share of the cost of such facility or part thereof or to
the extent that the District pernios use by the Commission of capacity
tenporarily excess to the requirements of the District®
Section 8'» (il) Until sewage flow rasters shall have been installed,
the total annual flew of sewage in each facility shall be either (1) es-
timated or agreed upon by the Engineers of the parties hereto, or (2)
determined on the basis of the number of sewerage units connected to,
or discharging into, such facility, or (3) based upon a combination of
estimated flows and sewage units,,
(B)	Until changed by mutual agreement of the parties
hereto, a "sewage unit" shall be considered to represent an annual flow
or discharge of one hundred seventy-five thousand (175»000) gallons.
(C)	For the purposes of this Agreement it is under-
stood and agreed that each service connection to a sewer or sewerage
system shall be counted as one, or more than one, "sewage unit" de-
pendent upon the use of the premises served through such connection,
as follows:
(l) For single-family dwelling purposes, each single-family
dwelling unit shall constitute one sewage unit. Such single-
G45

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family dwelling units ;;iay "be detached or attached single-family
dwellings, or may "be contained in flats or apartment houses. If
uhe dwelling unit is in a "building or structure other than a de-
tached binglt"-xix.viily dwelling, each space in such "building or
struct "ore which is occupied "by, or intended for the occupancy of,
a single-family for dwelling purposes, shall constitute a separate
-u-iio''' except that each apartment unit shall constitute
one-half of a :i sewage unit!!»
(2) It is further understood that units for commercial, in-
dustrial, office, institutional or business establishments of any
kind, including country clu'os, motels, hotels, trailer camps,
restaurants, public places, night clubs, government buildings,
filling stations, public schools, churches, fire houses, and
municipal buildings should be determined by doubling the annual
water consumption in gallons and dividing the same by the number
of gallons specified in Section 3(B).
Section 9. (A) The District will deduct from the total annual
flow of Maryland sewage in District facilities such volume as equals
the number of sewage units located in the District of Columbia which
discharge into sewers or sewerage systems of the Commission which sew-
ers or systems connect with such District facilities#
(3) The District will credit the Commission with
the number of gallons per sewage unit, specified in Section 2(3),
located in the District of Columbia which discharge into sewers or
sewerage systems of the Commission without being returned to a
G46

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District se-.vor or aswsrc.ge system.
(0) Ko deductions or credits will be made or allowed
for sewage originating in the District, which discharges into sewers or
sewerage systems ox the Coi^Tiission and is thereafter delivered to a Dis-
trict sewer or sewerage system, if the Commission does not pay flow
charges to the District with respect to such sewage.
Section 10. The anoints equal to assessments provided for in
subsection 1(3), the cost of operation and maintenance of sewage flow
meters provided for in subsection 3(B)» sewage flow charges provided
for in section 1+, charges against "Receivable" accounts provided for
in section 6, and all other amounts and charges payable "by the Commis-
sion under this Agreement shall "be "billed "by the District to the Com-
mission annually for the year ending June 30th, and each such "billing
shall show all deductions and credits as provided for in section 9.
2he Commission agrees to pay each such bill within thirty (30) days
after receipt thereof by check drawn payable to the order of the Col-
lector of Taxes of the District of Columbia.
It is e:xpressly covenanted and agreed by and between
the parties hereto that either party hereto may include in any subse-
quent bill any charge omitted from any previous bill, and that the
right of each party to be paid any sum, which by any provision' of
this Agreement the other party has agreed to pay, shall not be barred
by any statute of limitations or any other bar.
All accounts and other records maintained by'either
party hereto under or in connection with this Agreement shall be open
G47

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for inspection "by the other party or its authorized representatives at
i'6— iitt;	X"v^tUvVi CMS ioliii SiS
iicov-on li„ u£^i in this Agrseaent:
(1; vl'u word !;faciii'cy1' shall mean interceptor sewer,
truni: siov.ur, latiril "branch convoying sewage to an interceptor, pimping
station, savage trtati:ont plant, any equipment used or useful in con-
nection with any o? the foregoing, or any other construction, structure
or personal property of any description through which sewage flows or
•oz.^zzz or Uiich is necessarily related to the handling, pumping or treat-
i-.3:it of sewage, hut excluding movable personal property, such as trucks,
tools, etcB> actually used in connection with several other facilities.
(3) She phrase "lateral "branch conveying sewage to an
interceptor" shall ueen a sewer which is not an interceptor and to
which house connections are permitted*
(C)	The phrases "facilities which handle sewage from
Maryland" and "facilities which will or may handle sewage from Maryland",
as applied to District facilities, shall include not only facilities
through which Maryland sewage will actually flow "but also facilities
which increase the availability of other facilities for the carriage
of sewage from I-Iaryland even though Maryland sewage does not flow through
such facilities.
(D)	'-'Maryland sewage" and H sewage fron Maryland" shall
nean sewage which, has originated within the present area of the Wash-
ington Suburban Sanitary District or any extensions thereof* which may
"be hereafter authorised "by law and including territory within the state
G48

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fro:£ which sewage enters, into any system owned or controlled "by -che
Commission and has sr/cered District sewers or sewage systems through
connections thereto of either (1) such Maryland properties under
authorization fro.?, the Commission, or (2) Commission sewers or sewer-
£ Cy £;11 S o
(E) "Agreement11 or "mutual agreement11 of the parties
hereto, shall mean an agreement in writing signed "by the 3oara of Com-
missioners on "behalf of the District of Columbia and "by the members
of the Commission on "behalf of the Washington o^'jurban Sanitary Com-
mission.
(P) ihe phrases "Engineer of each party" or "Engi-
neers of the parties11, and similar phrases referring to "Engineer",
shall mean the Director of Sanitary Engineering, D. C., in the case
of the District, and the Chief Engineer of the Commission in the case
of the Commission.
(G) All references to actions to "be taken "by "the
parties11 or by "the District" or "by "the Commission" shall mean
actions to "be taken "by the 3oard of Commissioners of the District of
Columbia on "behalf of the District and "by the members of the Washing-
ton Suburban Sanitary Commission on behalf of the Commission.
Section 12. 'Ihis Agreement may be amended or terminated at an
time by mutual agreement of the parties hereto.
Section 13® This Agreement shall be effective as of July 1,
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iS'5u-'v	P-i^r Agreements betv/een the parties hereto shall termi-
nate as of said effective date*
II-,'	VJI-iLiiiOI', zh& Ooiaraissioners of the District of Columbia,
sppointid under an Act of Congress entitled "An Act providing a perma-
nent for a of government for the District of Columbia3" approved June 11,
iSJo, sitting as a Board, have considered and approved the foregoing
Agre^iuOnt, and have hereunto set their hands and caused the seal of the
District of Columbia to "ce hereto affixed, and the Washington Suburban
Sanitary Corsmiision has caused these presents to "be signed with its name
by IL\Y'AC]>]D t/„ BELLCiY, Chairmana and L0 3. RAY and J. NOSMAN AGiftl, Cora-
missioners, at boated by JA>BS B„ PASKHILL, its Secretary, and its corp-
orate seal to be hereunto affixed, the day and year first hereinbefore
written,
COMMISSIOHERS 01 SHE DISTRICT OP COLUMBIA
(SilA'L)
Attests
Secy., Board of Coirunissioners of
the District of Columbia
WASHINGTON SUBURBAN SANICARY COMMISSION,
a corporation,
Bys
(SEAL)
Attests
Secretary, Washington Suburban
Sanitary Coamissioa.
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THE r967'AGREEMENT WITH WSSC
FOR USE OF THE POTOMAC INTERCEPTOR

THIS AGREEMENT, uade in quintuplicate this 0 ¦¦ day of
the COMMISSIONERS 07 THE DISTRICT OF COLUMBIA and the
WASHINGTON SUBURBAN SANITARY COMMISSION, a body corporate
created under the laws of the State of Maryland,
WITNESSETH:
WHEREAS, the Congress of'the United States, by an Act
approved September 1, 1916 (39 Stat. 717), authorized the
connection of Maryland sewers and sewerage systems with the
sewerage systems of the District of Columbia, for the pro-
tection of streams flowing through United States Government
parks and reservations in the District of Columbia from pol-
lution by sewage, and authorized the said Commissioners of
the District of Columbia to enter into agreements, under
certain terms and conditions, with the proper authorities
of the State of Maryland in relation thereto; and
WHEREAS, the Congress of the United States, by Public
Law 86-515, 86th Congress, approved June 12, 1960, (74 Stat.
210) authorized the Commissioners of the District of
Columbia to plan and construct the Potomac Interceptor from
the Dulles International Airport to the District of Columbia
to provide service, among other things, 'for the expected
community growth and development in the adjacent areas in
Nineteen >Hundred and Sixty-Seven by and between
WSSC
282&r
\ . v .
V*.
\v-
G51

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liC' O L- "w C	V
:jj'Lz.:.C and Virginia, 'and fur th
c::' the District ox Columbia to operate
i/iiti ^Li~c i/w.i»ac — aufcrco^>Lor 'as a pare of a
regional	wev/wr systexa in cooperation with the
proper au-jhorxtie^ of the State and local jurisdictions con-
cerned uncior such regulations as may be 1 prescribed by the
WEiiriSAS, zhc General Assembly of the State of Maryland
by an Act knovm as Chapter 122 of the Acts of 1918, as
amended, created the YJashington Suburban Sanitary Commission,
a body corporate, and by virtue of said Act and of other lav/s
in force in the State- of Maryland said Commission was and is
authorized to take over existing sewerage systems within des-
ignated areas bordering upon the District of Columbia and
operate the same, and to construct and operate additional
systems and to enter into contracts and agreements with the
Commissioners of the District of Columbia for the connection
of said systems with the sewerage systems of the District of
Columbia and concerning any other matter necessary, advisable
or expedient for the proper construction, maintenance and
operation of the water supply, sewerage, drainage or refuse
disposal systems under its control or those under the control
of the Commissioners of the District of Columbia, which said
contracts and agreements have the full force and effect of
CvXsnissi oners; and
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contracts between tl:a District of Columbia and the State
il i'Vi 
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ers or sewerage systems, under the
uOC'Ci-OTi A. a
to the Interceptor shall be made upon the basis of prior
..etter agreement in each case between the representatives
Section 2. (A) The Commission shall prevent the pas-
sage from its sewers into the Interceptor of any drainage
other than sanitary sev/age or wastes not detrimental to the
Interceptor or to the District's sewerage systems or treat-
ment processes, and shall use every precaution in construc-
tion, and in regulations governing the use, of its sewers
and sewerage systems to exclude therefrom surface water,
rain water or ground water and in all other respects shall
conform with and enforce within those portions of the
Commission sewerage systems tributary to the Interceptor,
where applicable, such regulations of the Commissioners of
the District of Columbia governing the use of said Inter-
ceptor as may be prescribed pursuant to the authority vested
in said Commissioners of the District of Columbia under P.L.
86-515. "It shall be the policy of the District to inform
all user agencies, with which it has agreements in force for
use of the Interceptor, a reasonable time in advance of any
proposed modifications of said regulations governing the use
of the parties hereto
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of the Interceptor and to receive and consider, prior to
adoption of said modifications, any timely comments submitted
by said agencies."
the Potomac Interceptor System a sewer of the Commission
which receives sewage flows from any political jurisdiction
or other sanitary agency, district or authority not also a
party to an agreement with the District covering that
jurisdiction's, agency's, district's or authority's use of
the Interceptor, the Commission shall, as a condition pre-
cedent to the acceptance of such other sewage flows, stipu-
late and require of the said political jurisdictions, sani-
tary agency, district or authority, as the case may be,
the full observance and enforcement of the provisions of
Section 2(A) hereof, including the regulations of the Com-
missioners of the District of Columbia governing the use
of said Interceptor.
any political jurisdiction, or other sanitary agency, dis-
trict or authority not also a party to an agreement with
the District covering that jurisdiction's, agency's, dis-
trict's or authority's use of the Interceptor, undertake
jointly to construct and/or operate a sewerage system con-
necting to the Interceptor, then the Commission shall as a
condition precedent to such arrangement stipulate and require
(B) In the event there is connected to
(C) Should the Commission together with
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the participants i_i the said joint sewer facility their
fall observance and enforcement of the provisions of
Section 2(A) hereof, including the regulations of the
Co-iv.nissionerS of the district of Columbia governing the
use of said Interceptor.
Section 3. (A) Sewers of the Commission which dis-
charge into the Potomac- Interceptor System shall be pro-
vided with sewage flow meters whenever the use of such
meters is practicable. The practicability of metering, and
the size and type of meter and the location thereof, shall,
in each instance, be determined by the agreement of the
representatives of the parties hereto. The entire cost of
each meter installation shall be borne by the Commission.
operated, maintained a.nd read, and all costs of such
operation, maintenance and reading shall be paid by the
Commission, provided, however, that if agreed by the repre-
sentatives of the parties hereto the District at the sole
expense of the Commission may operate, maintain and read
any meter recording flows from a sewer of the Commission
at its point of connection with the Interceptor.
to function from any cause, the sewage flow for the period
of such failure shall be considered as equal to the flow
as determined during the most recent corresponding
(3) Each sewage flow meter shall be
(C) In case a sewage flow meter fails
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during which the meter v/as in satisfactory operation, and
if there is no such cox-responding period the flow shall
be determined or estimated in such manner as shall be
agreeable to the representatives of the parties hereto.
no direct cost to the Commission examine or test for accuracy
any sewage :,ieter of the - C'oniiTiission whose purpose it is to
record the flows of sewage to the Potomac Interceptor System.
to the Commission provide as part of the initial construction
of the Potomac Interceptor System manholes, connection struc-
tures or stubs for the connection thereto of sewers by the
Commission; however, similar accommodations not included as
part of the Original construction, if subsequently required
by the Commission3 will be provided by the District at the
direct expense of the Commission or, upon prior agreement of
the parties, by the Commission at its expense at the time of
their installation.
to the Potomac Interceptor System a sewer of the Commission
which receives sewage flows from any other political juris-
diction or sanitary agency, district or authority, as well
as from the Commission, the flows therefrom reaching the
Interceptor, the metering thereof, the charges therefor,
and all installations therefor will be sole responsibilities
(D) The District may at any time and at
(S) The District will at no direct expense
(F) In the event that there is connected
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(G) Siiould the Commission together with
;..\y political jurisdiction or sanitary agency, district or
authority wiadortaiie jointly to construct and/or operate a
sewerage system connecting to the Interceptor, .then for
the purposes of this agreement the District will deal with
but a single participant in such joint undertaking, as may
be selected and designated in writing for the purpose by
the saici Coiiimis^ion and others, and the terras of Section
3(F) hereof will apply if the Commission is the designee.
Section 4. (A) Pursuant to the provisions of P.L.
S6-515 it is the intent of the parties hereto that the
Coratnission shall. pay
(1)	the actual costs to the District for
handling, pumping and treating all sewage
discharged from Commission sewerage systems
into the Potomac Interceptor System and
thence into the sewerage systems of the
District of Columbia other than the Potomac
Interceptor;
(2)	the proportionate costs of operation,
maintenance and amortization of the cost
ox all planning and construction,
(including acquisition of rights-of-way)
/O
of the Potomac Interceptor System,
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excluding any Federal Grants made for
theu»e purposes j
(3) in proportion to its usage of the Potomac
Interceptor System, the construction and
amortisation costs incurred by the District,
excluding any federal Grants applicable
thereto, for the provision of facilities
other than vhe Potomac Inxerceptor for
handling, pumping and treating sewage
discharged or to be discharged by the
Commission through connections to the
Potomac Interceptor System;
all as hereinafter more particularly set forth.
(B) All of iphe elements of cost recited
above shall be reflected in a, single charge or service rate
which when multiplied by the total volume of sewage, ex-
pressed in millions of gallons, delivered tn t.^e Interceptor
from Commission sewerage systems will constitute the total
cost to the Commission for the sewage services provided
			—' ~ "" ——				 — -¦ •>
hereunder for the period during which such sewage flows
were recorded, or estimated, such charge or service rate
to be uniformly applicable to all jurisdictions, agencies
and authorities (except the Federal Aviation Agency) which
may be simultaneously served by the Interceptor during the
~ Cj
same period of service or billing interval, provided, how-
ever, that the amount of the charge or service rate shallqv ^
C?" ' A C:-X
^	,r..
aW
-\
. s ^
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adj^stsu zrozi ti'.r.e to time to cover fully the actual
costs "jo the District ci providing the services and amor-
tizing, as required by law, or otherwise reflecting the
capital costs of facilities devoted to such services. At
a^y time the charge or service rate per million gallons
shall consist of the aggregate of the following amounts:
(1)	An amount equal to the actual cost per
million gallons of the total flow in the
Interceptor, as recorded or estimated
from all users thereof, for the total
operation, repair and maintenance costs
of the Interceptor including the rights-
of-v/ay and access roads therefor, the
testing of meters and the services of
engineers and others engaged to direct
and perform these operations, administer
the regulations and provide the services
called for under this and similar agree-
ments between the District and other .users
of the Interceptor, including overhead
where applicable.
(2)	An amount which shall be the actual cost
to the District per million gallons for
the operation, repair, maintenance and	C)
replacement, including overhead, of each	r\
>'
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Dio^riCo facility which handles, pumps
or treats sewage or wastes conveyed by
t^e I.iterceptor to "che sewerage systems
of the District. (Major replacements
normally financed from capital funds shall
be considered as.improvements and financed
and reimbursed accordingly.)
An amount, expressed as a unit cost per
million gallons, which reflects the pro-
portionate annual share of the historical
cost of the District's sewage treatment
plant, up to the date of connection of
the Interceptor to the District's sewerage
systems, devoted to the treatment of
sewage and wastes received/from the Inter-
ceptor. As used herein the proportionate
annual share of the historical cost of the
plant shall be such portion of the cost
as the total annual flow of sewage received
from the Interceptor bears to the total
annual flow of all sewage received at the
plant, computed on the historical costs of:
a.	Conduits and piping at one percent
(1%)
b.	Buildings and tanks at one and one
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half percent (l£%), and
c. ^quipizent at four percent (4%)
At such tine as any facility as to which
the amount under this Section 4(3) (3) is
being paid shall be replaced, supplemented
or augmented by another facility toward
the cost of whose construction the
Commission shall be making payments
pursuant to Section 4(B)(6) hereof, then
the amounts payable under this Section
4(B) (3) shall be reduced in proportion .
to the resulting reduction in the use
of the initial facilities for the treat-
ment of sewage from the Interceptor.
An amount which shall be the charge per
million gallons necessary to amortize over
a period of forty years the loans from the
United States to the Metropolitan Area
Sewage Works Fund for the planning., design
construction and initial operation, if
necessary, of the Interceptor; such charges
to be graduated over the life of the loans
from zero, if warranted, to such maximum
as may ultimately be necessary to fulfill
the requirements of law; however, should the
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resulting rates thereby become unduly
burdensome to the user agencies, the
District agrees to participate in efforts
to secure modification of the law, or of
its interpretations as may be appropriate.
An amount which shall fce the charge per
million gallons necessary to amortize,
over a period of thirty years, the loans
from the United States to the District of
Columbia Sewage Works Fund for the planning,
design and construction of those portions
of the pipe lines and pumping facilities
which are provided for the transport
of flows,from the Interceptor to the
District of Columbia Water Pollution
Control Plant (P.L. 86-711); such charges
to be graduated over the life of the loans
from zero, if warranted, to such maximum as
may ultimately be necessary to fulfill the
requirements of law. The portion of the
cost of the pipe lines and pumping facili-
ties provided for the transport of flows
from the Interceptor shall be so much of
the total cost of each such facility to
the District as the maximum design capacity
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£S3i2,"riec! therein for Interceptor flows
bears to the ttaxiinum design capacity
assigned therein for all flows.
The application of the charges pro-
vided for under this Section 4(B)(5) to
flows from the Commission received by way
of the interceptor shall be in addition
to any other sums toward whose payment
the Commission may become liable to the
District under the provisions pf the
Agreement of August 12, 3.95^ (J3C?A-7S6)
ithe pcriStructio^ q£ pip© iine^mi
pumping facilities for the accommodation
of flows from the Commission which are or
may be delivered to the District's sewerage
systems through Commission sewer connections
to lines other than the Interceptor.
(6) An amount expressed as a charge per million
gallons which shall be sufficient to cover
th© cost to the District o£ Columbia,
exclusive q£ Federal Grants, if any, tox
planning, designing and constructing addi-
tional treatment facilities at the District
of Columbia Water Pollution Control Plant
as may become necessary from time to time to
accommodate flows received from the Inter-
ceptor , or to enhance the degree of treat-
ment provided such flows. The cost to the
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District a-3 used in this subsection shall
be taken tp include long and short term
loans taken by the District, if used for
such purpose, all of which shall be
amortized as to principal and interest
over a period of not less than thirty
years exclusively from the charges
provided for in this Section 4(B)(6),
The application of the charges provided
for under this Section 4(B)(6) to flows
from the Commission received by way of
the Interceptor shall be in addition to
any other sums toward whose payment the
Commission may become liable to the
District under the provisions of the
Agreement of August 12, 1954 (DCFA-766)
for the construction of sewage and waste
treatment facilities for the accommodation
of flows from the Commission which are or
may be delivered to the District's*sewerage
systems through' Commission sewer connections
to lines other, than the Interceptor.
When applicable, the total charge, as computed
in accordance with the foregoing subsections
for any jurisdiction which, under other
r
agreements, has provided financing for	v
capacity in any District facilities vised for
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handling or treating flows from the Inter-
ceptor j shall be adjusted annually or more
oftsn at the option of the District to reflect
credit, as determined by the District, for
proportionate use by any other agency of such
"purchased" capacity.
(C) The annual costs of operation, repair,
maintenance and replacement shall be determined from the
records of actual costs which are kept by the District with
respect to the Interceptor and each District facility handling
or treating flows from the Interceptor, Said records shall
be subject to inspection by the Commission or its duly
authorized agent.
Notwithstanding the provisions of subsection (B) of this
Section requiring that actual costs shall be the bases of the
various 'amounts' which make up the rate charged per million
gallons, the said rate shall not be changed more frequently
than each three years. Payments received from the Commission
will be credited first to the operating accounts in amounts
equal to the actual costs of operations, repairs, maintenance
and replacement as provided and the balance, when available,
shall then be credited to the capital accounts toward whose
ultimate liquidation the users of the Interceptor become
liable through this and other similar agreements.
The District shall furnish to the Commission annually?^
r
or more often at the option of the District, itemized data a
S
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showing costs of operations, repairs, maintenance and replace-
ments and amounts credited to the capital accounts for each,
year „
(£) The Commission will be billed on the
basis of metered, or estimated flows at three month intervals
ending on August 31, November 30-, February 28, and May 31
each year. Payments shall be made by or before the 30th day
next succeeding each bill rendition date.
Should the District perform at the request of the Com-
mission any services not covered by the rates charged per
million gallons the Commission shall pay to the District
the costs of such services within thirty days after such
payment is requested by the District.
Section 5. Inasmuch as the land area within the Cabin
John Watershed under Commission plans is connected directly
to the District of Columbia Sewerage System by a trunk sewer
of the Commission and is thus provided with sewerage service
under the terms of the Agreement of August 12, 1954 (DCFA-766),
but by subsequent request of the Commission may also connect
to the Interceptor, for the interception of part of the flows
therefrom for so long as capacity is available in the Inter-
ceptor for such service, the charges for flows delivered to
said Interceptor from the said Cabin John drainage area shall
be payable only in part under the provisions herein The
C)
charge or service rate per million gallons for sewage and A/
£ ^
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vasuvis delivered to the Interceptor from the Cabin John
drainage area shall consist of the aggregate of the amounts
set forth in -Sections -1(3) (1), 4(B)(2), 4(B)(3) and 4(B)(4)
hereof only. Such charges shall be in lieu of payment of the
"Number 1 Sewage Flow Charge Amount" and the "Number 2 Sewage
Flow Charge Amount" as described in Section 4(A)(1) and Section
4(a)(2) of Agreement BCFA-766. In all other respects the re-
maining provisions of Agreement DCFA-766 relating to the payraen
by the Commission to the District for the construction by the
District of facilities to handle, pump and treat sewage and
wastes originating in the Cabin John drainage area shall apply.
Section 6. (A) The District agrees that with respect
to the main line of the Interceptor the Commission shall be
entitled to the use of so much of the maximum capacity thereof
at any section as was shown in the "Report to the District
of Columbia Upon Planning Studies for the Potomac Interceptor
Sewer" prepared by the Burns and McDonnell Engineering Company
in 1961, to be required as of the year 2000 for the provision
of sewerage service to the various drainage areas, or parts
thereof, situated in the Sanitary District under the control
of the Commission.
It is understood that as to the portions of the Inter-
ceptor System extended into the tributary watersheds of the
Sanitary District by the District the same will have been
constructed in accordance with the maximum flow requirements
of the Commission and other iurisdictions as anticipated ixi/
,Q	*
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the said Planning Studies for the year 2000 as modified
prior to construction and shall be available for the use
of the Commission only to the extent assumed therein,.
Should any drainage area, or part thereof, for which flow
allocation is herein made to the Commission, cease at any
time to remain under such Commission control or -.in its
Sanitary District, the capacity of the Interceptor and its
parts to which the Commission is entitled hereunder shall
be reduced in proportion to be determined by agreement
between the Commission and the party assuming control of
said drainage area or part thereof.
(B)	The District agrees that with respect
to every District facility, or part thereof, as to the cost
of whose construction the Commission is paying the amounts
herein described in Sections 4(B)(5) and 4(B)(6), the
Commission shall be entitled to the use of so much of the
capacity of such facility, or part thereof, as does not
exceed the naxiziun design capacity provided therein for
the handling and treatment of sewage and wastes of the
Commission delivered to the Interceptor, excluding however,
such, sewage and wastes originating in the Cabin John
'Watershed "as "to -which -payments under 'Section "5 are pro-
vided herein.
(C)	Except to the extent set forth in
subsection (B) of this Section, the Commission recognizes Q
Hp .
\
e,
y m
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tha"c 'die District is primarily entitled to the entire and
exclusive use of ail District facilities, and that by
virtae of an a.gxzs:ueat between the District and the
V/asiiii'.^ton Suburban. Sanitary Commission, No. DCFA-766,
dated August 12) 195-1, the said Commission has certain
rights to use District facilities jointly with the District
which rights are superior to any rights granted in this
Agreement by the District to the Commission, and that by
virtue of an agreement between the District and the County
of Fairfax, No. DCFA-1357, dated April 28, 1959, the said
County has certain rights to use District facilities jointly
with the District which rights' are superior to any rights
granted herein by the District to the Commission, and that
if the District at. any time, in order to provide for
District sev/age or in order to accord the said Commission
its rights under the said Agreement DCFA-766, or the said
County its rights under the said Agreement DCFA-1357,
requires use of a theretofore jointly used District
facility, or part thereof, to an extent which will reduce
its availability to carry Commission sewage flowing from
the Interceptor the Commission is obligated to pay in rates
which the District periodically will establish for any new
construction which thereby may become necessary to meet the
current or future requirements for the handling and treatment
of sewage from the Interceptor. The payment by the CommissiorjS
c<£ #
^ *
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ox the amounts herein described in. Sections 4(3) (5) ar*d
4(B)(3) shall be considered to satisfy the requirements of
this Section 6(C) as to payments by the Commission,
and agrees that if it fails to pay to the District the
amount of any bill within the time specified in Section 4,
and such failure continues for a period of time determined
by the Commissioners of the District of Columbia, in their
discretion, to be unreasonable, it, the said Commission, will
become liable for payment of interest at the going District
rate on such delinquent bill until the same is paid and will
be subject to appropriate action by the District and/or other
interested parties to secure payment or other suitable per-
formance in any court of competent jurisdiction.
Section 7. (A) Until sewage flow meters shall have
been installed, the total annual flow of sewage in each
Commission sewer or sewer system shall be either (1)
estimated or agreed upon by the representatives of the
parties hereto, (2) determined on the basis of the number
of sewage units connected to, or discharging into, such
sewer or system or (3) based upon a combination of estimated
or agreed flows and sewage units.
of the parties hereto, a "sewage unit" shall be considered
to represent an annual flow or discharge of one hundred
(D) The Commission expressly covenants
(B) Until changed by mutual agreement
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thousand (100,000) gallons.
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(C) For the purposes of this Agreement
it is understood and agreed that each service connection
to a sever or sewerage system shall be counted as one,
or more than one, "sewage unit" dependent upon the use
of the premises served through such connection, as
follows:
(1)	For single-family dwelling purposes, each
single-family dwelling unit shall consti-
tute one sewage unit. Such single-family
dwelling units may be detached or attached
single-family dwellings, or may be con-
tained in flats or apartment houses. If
the dwelling unit is in a building or
structure other than a detached single-
family dwelling, each space in such
building or structure which is occupied
by, or intended for the occupancy of, a
single-family for dwelling purposes, shall
constitute a separate "sewage unit" .except
that each apartment unit shall constitute
one-half of a "sewage unit".
(2)	It is further understood that units for
commercial, industrial, office, institu-
tional or business establishments of any
kind, including country clubs/ motels,
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hotels, trailer camps, restaurants,
public places, night clubs, government
buildings, filling stations, public schools,
churches, fire houses, municipal buildings
and parks shall be determined by dividing
the annual water consumption therefor by
the number of gallons specified in Section
7(B) to constitute one "sewage unit".
Section 8. All amounts and charges payable by the
Commission under this Agreement shall be billed by the Dis-
trict to the Commission as elsewhere herein provided. -The
Commission agrees to pay each such bill by or before the
30th day next succeeding the bill, rendition date by check
drawn payable to the order of the D. C. Treasurer.
It is expressly covenanted and agreed by and between
the parties hereto that erroneous billings may be cor-
rected at any time and that any rights secured to each
party to be paid any sum of money pursuant to the terms
of this Agreement shall not be barred by any statute of
limitations or by any other bar.
All accounts and other records maintained by either
party hereto under or in connection with this Agreement
shall be open for inspection by the other party or its
authorized representatives at any time during regular
business hours.	,0
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Section S. As used in this Agreement;
(A)	The word "facility" shall mean the
Pooor.iac Interceptor or any other interceptor sewer, trunk
sewer, pumping station, sewage treatment plant, any equip-
ment used or useful in connection with any of the fore-
going, or any other construction, structure or personal
property of any description through which sewage flows or
passes or which is necessarily related to the handling,
pulping or treatment of sewage, but excluding movable
personal property, such as trucks, tools, etc., actually
used in connection with several other facilities.
(B)	"Commission sewage" and "sewage from
the Commission" shall mean sewage which has originated with-
in the Washington Suburban Sanitary District, or within any
county, town, city, district or territory within the State
of Maryland from which sewage enters into any system owned
or controlled by the Commission, and has entered the Inter-
ceptor through connections thereto of Commission sewers or
sewerage systems.
(C)	"Agreement" or "mutual agreement"
of the parties hereto, shall mean an agreement in writing
signed by the Board of Commissioners on behalf of the
District of Columbia and by the members of the Commission
on behalf of the Washington Suburban Sanitary Commission.
(D)	The phrase "representatives of th^
parties" shall mean the Director .of Sanitary Engineering,
O Q> V*
A' A 
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D. C. , in the case of "Che District, and the Chief Engineer
of the Corliss ion, in the case of the Commission.
(2) All references to actions to be
taken by "the parties7' or by "the District" or by "the
Commission" shall mean actions to be taken by the Board of
Commissioners of the District of Columbia on behalf of the
District and by the members of the Washington Suburban
Sanitary Commission on behalf of the Commission.
Section 10. This Agreement may be amended or termi-
nated at any time by mutual agreement of the parties hereto.
Section 11. This Agreement shall be effective as of
the date first hereinabove written.
IN WITNESS WHEREOF, the Coinmissioners of the District
of Columbia, appointed under an Act of Congress entitled
"An Act providing a permanent form of government for the
District of Columbia," approved June 11, 1878, sitting
as a Board, have considered and approved the foregoing
Agreement, and have hereunto set their hands and caused
the seal of the District of Columbia to be hereto affixed,
and the Washington Suburban Sanitary Commission has caused
these presents to be signed' with its name by Louis A. Gravelle ,
Chairman, and	and	and
, Commissioners, attested by John T. Bonifant,
Lts Secretary, and its corporate seal to be hereunto affixed,
the day and year first hereinbefore written.	^ c??
£ ^
* #
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CGXI£I SSI ONERS OF THE DISTRICT OF COLUMBIA
(SEAL])
Attest:
U'
? /C*, !)
--— ' '""So 7T	^	~
becretary, Bo^arci o i~Cornm i s sTo ner s
of the District of Co^iL-nbia
(SEAL)
WASHINGTON SUBURBAN SANITARY COMMISSION,
a corporation
Ti
By: jA /// rUl'&'ti/
• » 7 Ai ^ A \ Pv* AkrA 11a	n % v*r
^ Louis A.\j3ravelle, Chairman
Secretary, Washington/Suburoan .
&•
titary Commission
Approved as to form:
/ J, - ( /
Assistant" Cox'porati. on/Counsel 4 JJ.C.

1957
/-
Av
 /
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APPENDIX H
RECOMMENDATIONS TO SPEED ACTION
ON POTOMAC CLEANUP
PREPARED BY
VINCENT W. BACON
PROFESSOR OF CIVIL ENGINEERING
THE UNIVERSITY OF WISCONSIN - MILWAUKEE

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The University of Wisconsin — Milwaukee
MILWAUKEE, WISCONSIN 63201
COLLEGE OF APPLIED SCIENCE AND ENGINEERING
May 19, 1970
RECOMMENDATION S TO SPEED ACTION ON POTOMAC CLEANUP
Dear Mr. Klein:
1) The Blue Plains Sewage Treatment Plant is overloaded. Further,
it cannot be expanded to treat the waste load which will be
generated in the metropolitan area by the year 2000 (420 MGD*
estimated) simply because the Potomac Estuary does not have the
receiving capacity even if the degree of treatment exceeds 99%
removal. The logical solution is to remove much of the load
from suburban Maryland, requiring that area to provide waste
treatment plant capacity over and above its capacity rights at
Blue Plains. Thus, both land and treatment capacity at Blue
Plains will be reserved for the core area, the Potomac (frulles)
Interceptor area, and the capacity to which Jteryland and
Virginia are entitled. Of greatest importance, the Potonac
will be cleaned up in less time ard, in my opinion, at less cost,
^Million Gallons per Day
The capacity at Blue Plains should be leveled off at present at
2U0 MGD with new primary additions to be placed under con-
struction immediately with completion by December 31, 1971,
with new secondary additions to achieve 90% removals by
December 31, 1972, and with advanced waste treatment by December
31, 1975, to achieve nutrient and organic removals. Such a
program is practical. It should meet the standards of 96%
removal of BOD*, 96% removal of phosphorus, and 85% removal of
nitrogen. At 2U0 MGD, Blue Plains should have adequate capacity
into the mid !80's.
* Biochemical Oxygen Demand
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2)	The degree of treatment proposed for the 30 MGD Piscataviay
Sewage Treatment Plant by past enforcement conferences is not
adequate to protect Piscatavay Embayment from eutrophication.
Newly completed FWQA scientific studies, including mathemati-
cal models and dye dispersion studies, show that the present
enforcement conference removal requirements of 96% BOD, 96%
phosphorus, and 85% nitrogen are adequate only to 15 MGD.
Respectively, these removal requirements should be increased
to 98%, 98%, and 95% for a 30 MGD plant. The timetable for
accomplishment should not be changed.
3)	Beyond the 67 MGD capacity rights which Maryland has established
at Blue Plains, no further connections to the WSSC system dis-
charging to Blue Plains should be allowed. This need not
inhibit development in the WSSC area. So-called package waste
treatment plants can be installed as temporary treatment while
regional facilities are being desiyne<\ and constructed. They
should be operated by WSSC, and stream standards must be met.
The same applies to Virginia installations.
Solids disposal does not impinge directly upon the Potomac
River and Estuary. But it can be a source of air pollution,
and it can be costly, thus diverting monies from the basic
treatment process. Disposal of digested sludge onto crop
lands on a crop rotation basis should be given consideration
now. Land should be purchased now for this purpose, and held
until needed, A loading factor of 20 dry tons per acre per
year is a conservation design criterion. Land disposal and
utilization should prove less costly, should free some of the
acreage at Blue Plains and other plants, and will close the
organic cycle making beneficial use of the solids.
5) All agencies should attempt to envision their ultimate
treatment plant site requirements, and sufficient land for
this purpose should be purchased now.
In arriving at the above conclusions, I worked very closely with
your staff, with the experts from FWQA's Technical Support Labora-
tory at Annapolis and the Charlottesville Regional Office, and
with Eugene Jensen, FWQA Assistant Commissioner for Operations.
Field trips were made to Blue Plains and to potential sites for
regional treatment plants.
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Attached are more detailed findings and recommendations for action
to abate water pollution in the Washington Metropolitan area reach
of the Potomac and tributaries. They are under the headings:
The Blue Plains Problem> The Piscataway Problem, and Advanced Waste
Treatment Package Plants.
It has been a pleasure working with you and your cooperative and
competent staff.
Honorable Carl L. Klein
Assistant Secretary for
Water Quality and Research
Department of the Interior
Washington, D. C. 20240
Enclosures
Sincerely yours,
Vinton W. Bacon
Professor of Civil Engineering

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FINDINGS AND RECOMMENDATIONS FOR ACTION TO ABATE WATER POLLUTION .
IN THE WASHINGTON METROPOLITAN AREA REACH OF THE POTumaC AND TRIBUTARIES
FINDINGS:	I* 8LUE	pK03LEM
1.	The Blue Plains Plant of the District of Columbia, which handles nearly 80%
of the.jnejtropolitan area sewage load, is overloaded. Its design capacity is 240 mijd;
iti> present load is about 250 mgd, with one-half of the sewage originating outside
D.C.. (Md-114 mgd; Va.-ll mgd; D.C.-124 mgd)
*
2.	No reading of existing agreements under which D.C. accepts sewage from other
jurisdictions can yield an interpretation to the end^that D.C. is obligated to over-
load its plant. Likewise, such agreements cannot be interpreted to hold that juris-
dictions outside D.C. are relieved from the obligation to manage the .sewage problems
created within their own boundaries. In either case, the Potomac Is the victim.
3.	The Maryland counties represented by the Washington Suburban Sanitary Commis-
sion (WSSC) have established certain "capacity rights" to treatment of a portion of
their sewage at Blue Plains through WSSC's contributions to that plant's constructioi
SucIa "rights" are calculated at about 45 mgd, and should remain so reserved. *
4.	Other "rights" to Blue Plains capacity arise from legislation authorizing the
Potomac Interceptor, amounting to 22 mgd for WSSC and 42 mgd for Virginia areas when
the loads reach full design capacity. These should also remain intact.
5.	Beyond these outside "capacity rights", no obligation arises for D.C. to
accept sewage flows from outside its boundaries -- to the detriment of the River.
Beyond this point, too, the credibility of continuing adherence to the singlr-large-
plant-approach as the best regional solution is in serious doubt.
6.	On the basis of scientific studies and approved water quality standards for
the metro segment of the Potomac Estuary, it is apparent that the sewage load from
populations connected to Blue Plains will have to be reduced, or virtually 100%
treatment will have to be achieved. As of 1 year ago, an excess load equivalent to
the sewage from 230,000 people was imposed on Blue Plains and the 4 other smaller
plants in the metropolitan area.
RECOMMENDATIONS:
1.	The present site at Blue Plains should be reserved first and foremosi for
D.C. sewage, including adequate treatment for excess flows.
2.	The design flows allotted to WSSC in the Potomac Interceptor (22 mgd) should
continue to remain reserved, and the flows from all other WSSC sources to Blue Plain
should be limited to 45 mgd, for a total of 67 mgd thus to be treated at Bluo Plains
3.	The Blue Plains plant capacity should be retained at 240 mgd for the present;
with all plant components brought up to that capacity, and with installation of
tertiary facilities, Blue Plains should thus have sufficient capacity to beyind the
Year 1900 and meet water quality standards. (See Table A)
4.	WSSC should immediately commence design and construction of facilities for
tertiary treatment in excess of 67 mgd, as required to meet water quality stmdords
No further connections to WSSC system discharging to Blue Plains should be allowed.
5.	Any Advanced Waste Treatment Package Plants utilized shall be considered
l.ompornry solutions and shall be opov: so as to meet water quajiiy si '"ds,

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RECOMMENDATIONS - Continued
6. The Design and Construction effort leading to tertiary treatment at
the 240 mgd Blue Plains facilities should proceed on the following schedule:
(1)	Primary Facilities — put to contract immediately for the 240
mgd capacity, includi n;i excess flows.
(2)	Secondary Facilities -- Begin Design immediately and complete
within 1 year; Complete Construction by 12/31/1972
(3)	Tertiary Facilities — Within 1 year, begin Design; complete
Design within 1 year; complete Construction by 12/31/1975.
Note: If these recommendations are followed, the capacity at B]ue Plains
can be leveled out at 240 mgd for secondary treatment; with the addition
of tertiary facilities, this capacity will be adequate to some date beyond
1980, will meet water quality standards, and will allow Uor orderly plan-
ning to accommodate future needs anticipated beyond 1980.
Table A
Design Flows at Blue Plains with WSSC Inflows Restricted
Actual Present
Flows from:	Inflows (1970)	1980	2000
(mgd)	(mgd)	(mgd)
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
Total to be
treated at Blue
Plains Plant	 249	210	297
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^Formula by which 45 MGD capacity rights of WSSC at Blue Plains was determined.
$5.5M invested by WSSC at Blue Plains x 240 MGD *45% MGD.
$29M total investment in Blue Plains from all sources.
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II. TIE PISCATAWAY PROBLEM
Findings and
Recommendations:
1.	Newly completed F.\'QA scientific studies, including mathematical
model prediction and dye dispersion results, have produced findings to
show that the present Enforcement Conference removal requirements of 96%
of Phosphorus "and 85% of Nitrogen are not adequate to prevent accelerated
eutrophication conditions with the 30 sngd Piscataway Treatment Plant bein
planned by WSSC.
2.	These removal requirements would have been adequate for a 15 mgd
plant, and would have affordsd sufficient protection for Piscataway Embay^ ont.
3.	Thus, the Enforcement Conference will need to impose more stringe t
removal requirements. For the 30 mgd plant size, these will have to be n i;
less than 93% B0D5, 90% Phosphorus, and 95% Nitrogen.
4.	There is no reason to change the time frame for accomplishment of
these levels of treatment, and the timing requirements specified by the
Enforcement Conference should be adhered to and met.
5.	Because of the very high degree of sensitivity of Piscataway Emba;
ment waters to the adverse impacts of waste and nutrient inputs, adequate
fail-safe mechanisms, including but not limited to standby power facilities
multiple treatment trains, absence of bypasses, sampling, analysis, warnii \
systems, etc., should be provided for.
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III. ADVANCED WASTE TREATMENT.PACKAGE PLANTS
FINDINGS AND RECOMMENDATIONS
1.	Many Washington Metropolitan Area sewage treatment plants arc preseni ;.y
overloaded and thus aggravate an already difficult pollution problem in the Po .oma'c
and tributaries. In this setting of explosive population growth, local govcrnn ;nts
must utilize the full range of technological tools —• including interim soluti ins —
to minimize damage to the River until permanent, adequately-sized facilities c in be
put in place and eliminate such overloads.
2.	Package Treatment Plants can be an effective interim solution to relj :ve
overloading situations without calling a total halt to all further growth. Mo.' i. such
plants are designed to produce effluents equivalent to secondary treatment, i, ). up
to 95% removal of BOD5 and Suspended Solids. They can be augmented, however, 1 > yiel
a tertiary-equivalent type of effluent by adding sand/vaccuum filter processor >,
lagoons, chemical precipitators for nutrient removal, etc. For the effluents lis-
charqed in the Washington Metropolitan Area to the Potomac and tributariessi ;h
tertiary-equivalent (advanced waste) treatment is a must.
3.	Size and Performance: Package Treatment Plants can range in size up 10
million gallons per day (mgd), and can be used in parallel to serve nmre pe< ,>le.
...A 50,000 gpd unit can treat wastes equivalent to the sewaoe from 500 peopll^,
or 143 families (3.5 people per family)	 A 1 mgd unit can treat sewage foi
10,000 people, or 2,857 families.
4.	Other characteristics: Package plants are portable and can be moved 10 ncx'
location when permanent facilities are completed....The space thus vacated (u.< ually
concrete slab) reverts back to the builder and original intended use (house, 
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APPENDIX I
ENVIRONMENTAL STATEMENT AND SUPPLEMENTS
PREPARED BY THE DISTRICT OF COLUMBIA
DEPARTME OTP OP ENVIRONMENTAL SERVICES

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Environmental statement
d. c. wat^.^©|l^vtion control plant expansion
1971 - 1974
NOV 15 1971
I.	Purpose	FWQA
This statement is intended to provide the information required by the
National Environmental Policy Act of 19&9, Public Law 91-190, January 1,
1970; the Environmental Quality Improvement Act of 1970, Public Law
91-224, April 3, 1970; Executive Order 11507, Prevention, Control, and
Abatement of Air and Water Pollution at Federal Facilities, February 4,
1970; Executive Order 11514, Protection and Enhancement of Environmental
Quality, March 5, 1970; and Interim Guidelines of the Council on Environ-
mental Quality, April 30, 1970 as revised and amended on January 28, 1971.
The purpose of the D. C. Water Pollution Control Plant expansion and
modernization program is to improve the aquatic environment by providing
ultratreatment of wastewater. Other environmental benefits will accrue as
detailed herein.
II.	Background
From the northwestern corner of the District at Chain Bridge, to its
mouth at Chesapeake Bay (about 115 miles), the Potomac River is an estuary -
it ebbs and floods in response to the mechanical action of the ocean tides.
Although the ocean tides reach to Chain Bridge, salt water does not, and the
water in the estuary at Washington is always fregh. The estuarine character
of the Potomac and Anacostia Rivers intensifies water quality problems and
complicates water quality management.
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THE PROBLEM
The main cause of water pollution in the Washington area is municipal
wastewater. This includes raw sewage released from overloaded sewer
systems, sewage treatment plant effluents, combined sewer overflows, and
storm water. Combined sewers are a remnant of the past and are found in
the older sections of some cities, including the District and Alexandria.
During dry weather, they convey sanitary sewage to the treatment plant
but when it rains, they also function as storm drains. During a heavy
rainstorm, it is not possible to accommodate the entire combined sewer
flow at the treatment plant and the excess flow, a dilute mixture of rainfall
runoff and sanitary sewage, must be discharged into the nearest stream.
About one third of the area of the District is on a combined sewer system.
Once considered innocuous, rainfall runoff from urbanized areas has
been found to be contaminated by the washing of accumulated filth from
streets, and in areas undergoing development, runoff may carry tremendous
quantities of eroded soil.
POLLUTION CONTROL
In 1938, the District placed into operation a primary sewage treatment
plant at a location known as Blue Plains, in the southwest corner of the city.
Twenty years later, secondary type treatment was added. Other improve-
ments have been made since the secondary facilities were completed. The
facilities are officially designated the "District of Columbia Water Pollution
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Control Plant." This plant is a regional one, serving large areas in Maryland
and Virginia as a result of an Act of Congress in 1916. As a matter of fact,
the potential tributary area outside the District is ten times the size of the
District itself.
The present treatment facilities are inadequate. Accordingly, the
Department of Sanitary Engineering plans to increase the hydraulic capacity
of the plant and greatly improve the quality of the effluent. To do this will
require the expenditure of large sums of money and the full cooperation of
the Federal Government and participating local governments.
In June 1967, pursuant to the provisions of the Water Quality Act of
1965 (P.L. 89-234), the District adopted quality standards for its interstate
waters. The water quality standards consist of (1) a set of planned water
uses, (2) quality criteria designed to protect those uses, and (3) a plan for
implementation and enforcement of the criteria. Again pursuant to law, the
District's standards were submitted to the Secretary of the Interior on
June 29» 1967. After certain adjustments to the standards were made by
the District, partial approval was granted in April 1968. Further adjust-
ments were made before the Secretary gave his full approval in January 1969.
(All the states and territories went through similar procedures during this
period.) Upon approval by the Secretary, the District of Columbia water
quality standards became federal standards also.
The District's standards are primarily intended to provide improved
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recreational opportunities as a result of water quality improvement. With
the exception of the criteria related to water contact recreation (swimming,
wading, waterskiing), the water quality objectives were to be realized by
1972. Water quality to permit contact recreation was planned for 1975 in
limited zones of the Potomac River and Rock Creek.
In April 19&9, dissatisfied with pollution control progress, the Secretary
of the Interior reconvened the Potomac River - Washington Metropolitan Area
Enforcement Conference. The conferees represented the water pollution
control agencies of Maryland, Virginia, and the District of Columbia; the
Interstate Commission on the Potomac River Basin; and the Department of
the Interior. ( The first two sessions of the conference were held in 1957
and 1958.) After three days of hearing testimony, the conferees recessed
to study the extensive data presented to them. They reassembled about one
month later to issue a set of recommendations for actions to improve water
quality. The most important recommendation was the one calling for the
construction of advanced waste treatment facilities. The effluent parameters
established by the conferees will require almost complete renovation of
wastewater and assure realization of the District's water quality goals for
the Potomac.
In accordance with the conference recommendations, the District pro-
ceeded to implement its phased development plan for the Blue Plains site.
One of the elements of the plan was the reclamation of 51 acreas of Potomac
River mud flats for plant expansion to 419 million gallons per day (MGD),

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the flow expected to occur near the year 2000. However, subsequent
Department of the Interior opposition to the reclamation proposal made
approval by the Federal Government unlikely. As a result, it was
necessary to abandon plans for full expansion of the plant to 419 MGD.
In recognition of this impasse, the conferees reached the compromise
set forth in a "Memorandum of Understanding, " the execution of which was
completed on October 7, 1970. The Memorandum calls for the development
of the Blue Plains site to provide advanced waste treatment for 309 MGD by
the end of 1977.
In accordance with the subsequent request of the Secretary of the Interior,
the parties to the Memorandum of Understanding agreed to advance the com-
pletion date of the treatment plant improvements to December 1974, provided
adequate federal assistance in the form of construction grants is made avail-
able .
Expansion of the plant will proceed in three phases, each phase increasing
the level of treatment until the required ultratreatment is reached. The three
phases are:
Phase I - additional primary tanks and sludge processing facilities
Phase II - additional secondary facilities
Phase III - advanced waste treatment
Interim measures, such as the use of special chemicals and mechanical
devices?, will be investigated and, if proven to be beneficial, instituted to
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improve the quality of all plant effluents in the area at the earliest possible
date. A list of promising interim controls is contained in the Memorandum
of Understanding. A most important feature of the Memorandum is the
provision requiring the suburban governments to immediately proceed to
acquire a plant site to accommodate flows beyond the 309 MGD level.
DESCRIPTION OF EXISTING AND PROPOSED FACILITIES
A. Existing Facilities
The D. C. Water Pollution Control Plant is located at the southern tip
of the city in an area known as Blue Plains. The plant site (159 acres) is
bounded on the north by the Naval Research Laboratory, on the east by the
Anacostia Freeway (Route 1-295), on the south by Oxon Bay and the Potomac
River, and on the west by the Potomac River.
Present facilities provide primary and secondary sewage treatment (for
a flow of approximately 253 MGD in FY 1970) through the following sequence
of treatment processes: prechlorination, aerated grit chambers, primary
settling, activated sludge (modified or short-term aeration), secondary
settling, and post chlorination. Excess sludges are anaerobically digested,
vacuum filtered, and air-dried prior to final disposal.
The number and sizes of the various treatment units are as follows:
1.	Primary sedimentation tanks: These consist of 16 circular tanks,
each 106 feet in diameter.
2.	Aeration tanks: This portion of the plant consists of four tanks,
each 460 feet long and 120 feet wide.
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3. Secondary sedimentation tanks: There are 12 of these, each
80 feet wide and 250 feet long.
These major unit processes plus a variety of smaller facilities such
as pumping stations, grit chambers, administration building, elutriation
tanks, thickening tanks, and a sludge dewatering building occupy a total of
approximately 75 acres. The sludge yards occupy an additional 40 acres.
B. Proposed Facilities
1.	Primary sedimentation: To accommodate 309 MGD, plus "excess
flow," 20 additional tanks, each 120 feet in diameter, will be added.
2.	Aeration tanks: Although the design of these units is not complete,
it is expected the additional rectangular aeration tanks will have a total water
surface area of approximately 70,000 square feet.
3.	Secondary sedimentation tanks: The design of these units is not
complete. However, it is expected the additional rectangular tanks will have
a total water surface area of approximately 350,000 square feet.
4.	Sludge processing building: This facility will be 600 feet long and
280 feet wide. A 300 foot section of the building will be 91 feet in height, with
a stack height of 114 feet above grade. Sludge will be thickened, dewatered
and incinerated. The incinerator will be equipped with a high energy venturi
scrubber and after burners to provide for particulate removal, destruction
of condensible gases, and plume attenuation. The gaseous effluent will be
invisible and odorless and will comply with applicable air quality control
17

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standards and regulations. This large building will be so sited that its major
axis will be generally parallel to the Potomac River and thus have a minimum
impact on the visual approach to the city, both from the river and 1-295.
5. Advanced waste treatment: The advanced waste treatment facilities
will consist of units for phosphorous removal, nitrogen removal, and addi-
tional removal of biochemical oxygen demand. While these units have not
been designed, they will resemble the primary and secondary treatment
units. There will be no ammonia stripping towers, as present plans contem-
plate the use of nitrification-denitrification for nitrogen removal.
Along with a chlorine contact chamber, aerated grit chambers, and other
ancillary facilities, the new plant will occupy a total of 165 acres.
As a direct result of plant expansion and improvement, two important
sources of odor will be eliminated. These are:
1.	Aerated grit chambers: The new grit chambers will be fully enclosei
and incorporate ozone generating equipment for destruction of odors.
2.	Sludge storage yard: Sludge storage yards will be eliminated and all
sludge will be incinerated in an ultramodern sludge incinerator designed to
meet the latest air pollution control standards.
III. Environmental Considerations
1. Probable impact on the environment
a. Primary consequences
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The proposed improvements are an absolute necessity if the
District is to achieve the water quality goals set forth in the water quality
standards approved by the Secretary of the Interior in January 1969. The
*oals are defined by the various water quality criteria intended to protect
Future uses of the Potomac River and its tributaries in and below the District
3f Columbia. Among these uses are "fish and wildlife propagation."
The present state of the Potomac River makes it a suitable habitat
Dnly for scavenger fishes and a few of the hardier game fishes. Although
:he upper estuary provides spawning grounds for several anadromous species,
3everal large fish kills have occurred in the fall of the year, presumably as
i result of low dissolved oxygen content during the seaward migration of the
young fry. An important influence on dissolved oxygen content of the upper
jstuary is the effluent from the District's plant. The proposed improvements
tfill effectively deal with this problem. This can be demonstrated by the fact
that the quantity of oxygen demanding substances (biochemical oxygen demand)
discharged from the plant will be reduced from approximately 100,000 lbs per
day in 1970 to less than 13.000 lbs per day in 1975. During this period, the
plant flow will increase from 253 to 309 MGD, requiring an increase in plant
efficiency from about 70% to 97%. To state it another way, the oxygen de-
manding substances in the plant effluent will be reduced from 30% to 3% of the
Incoming.
b. Secondary consequences
The proposed work is not expected to significantly affect population
19

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distribution or concentration even though land use plans in the tributary-
area were based on expansion and upgrading of the facility. Because the
D. C. plant will not be expanded to the previously assumed 419 MGD
capacity, an additional plant or plants will be constructed in suburban
Maryland by the Washington Suburban Sanitary Commission or other appro-
priate agency.
2. Adverse environmental effects which cannot be avoided
No adverse environmental conditions are envisioned. Compared to
the present facility, the improved plant will be vastly superior in its overall
impact on the environment. In addition to the primary goal of wastewater
quality improvement, the present offensive sights and odors will be elimi-
nated. Other favorable factors to be considered are:
a.	Reduction in the planned plant capacity from 419 to 309 million
gallons per day.
b.	Reduction in the planned size of the plant as a result of (a)
above from approximately 210 acres to 165 acres.
c.	The Department of Sanitary Engineering will cooperate with
the National Park Service in the latter's efforts to achieve a river front park
along the Potomac River side of the site. Except for the sludge handling
building, low profile type tank structures will be used. As a result of
research conducted by the District and the Water Quality Office of the
Environmental Protection Agency, a determination has been made that
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ammonia stripping towers will not be used in the nitrogen removal process.
Additional aesthetic considerations, as outlined in the report of the District
Public Improvements Committee of the National Capital Planning Commission
dated February 4, 1971, will be evaluated.
3.	Alternatives to the proposed action with evaluations thereof
There are no viable alternatives to the proposed improvement
program. Under the terms of the Potomac River Enforcement Conference,
the District is required to proceed with the plant expansion as outlined above.
The need for bigger and better water pollution control plants has been a sub-
ject of the Enforcement Conference since 1957. More recent discussions of
the justifications for the proposed construction is amply described in various
documents, among which are: "Water Quality Criteria, Implementation and
Enforcement Plan, District of Columbia, Potomac River and Tributaries,"
"Potomac River Water Quality, Washington, D. C. Metropolitan Area, " and
the Proceedings of the Potomac River Enforcement Conference sessions held
in May and November of 1969 and May and December of 1970. Consequently,
nothing can be added, in this statement, to the conclusions reached within
the framework of the Enforcement Conference, namely, that the District
must expand and improve the D. C. Water Pollution Control Plant.
4.	Relationship between local short-term uses of man's environment
and the maintenance and enhancement of long-term productivity
The site in question, already occupied by a sewage treatment plant,
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can only benefit from the proposed construction. While the long-term effects
of the facility on the site itself are not amenable to measurement, the long-
term beneficial effects on water quality and the usefulness of the river are
obvious and measurable. Improving the water pollution control plant now
can only provide benefits for the future.
5.	Irreversible and irretrievable commitments of resources
The only resource committed is the land upon which the facility is
located. Construction will be limited to the existing site, which is almost
completely occupied by treatment facilities and sludge storage areas. A
small amount of construction work, such as the erection of docking facilities,
will be conducted along the shore of the Potomac River. No irretrievable
commitments of resources will be involved. In fact, the huge quantities of
excavated material may be used to restore another natural resource -- Dyke
Marsh. Although not envisioned, it is conceivable that, at some time in the
distant future, if completely new sewage disposal technology makes the pro-
posed plant obsolete, the site could be restored to its natural state by the
removal of structures.
6.	Objections to the project
There now are no objections to the project other than the request for
further consideration of aesthetic values, a4 detailed in the above mentioned
report of the District Public Improvements Committee of the National Capital
Planning Commission. The previous objection of the Department of the
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Interior to the request for filling in 51 acres of Potomac River mud flats
has been resolved by reducing the proposed installed capacity of the plant
from a projected 419 MGD to 309 MGD. If anything, there has been, both
within the various federal, state, and local governmental entities and the
general public, a strong expression of desire for the proposed construction.
Conclusion
In considering (1) the environmental impact of the proposed action,
(2) any adverse environmental effects which cannot be avoided, (3) alterna-
tives to the proposed action, (4) the relationship between local short-term
uses of man's environment and the maintenance and enhancement of long-
term productivity, and (5) irreversible and irretrievable comtnitments of
resources which would be involved in the proposed action should it be
implemented, the Department of Sanitary Engineering, Government of the
District of Columbia concludes that the proposed expansion and improvement
of the D. C. Water Pollution Control Plant is in conformance with the purposes
of the National Environmental Policy Act of 1969, which are: "To declare a
national policy which will encourage productive and enjoyable harmony between
man and his environment; to promote efforts which will prevent or eliminate
damage to the environment and biosphere and stimulate the health and welfare
of man; to enrich the understanding of the ecological systems and natural
resources important to the nation. .
AS/vdm
113	P / li-> / 7 \

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\'n T*- '
l<1 }: '	SUPPLEMENT TO ENVIRONMENTAL STATEMENT
D. C. WATER POLLUTION CONTROL PLANT EXPANSION
^OVlbiiVi	1971-1^74
r:
1! Yj F1. / i : •
I. Purpose
This statement is intended to supplement Section III. Environmental
Considerations, paragraph 3. Alternatives to the proposed action with
evaluations thereof.
In selecting incineration as the disposal method for the sludge process
considerable investigation was made of other alternatives. In 1968 an ex-
tensive study on barging sludge to sea was completed and considered as a
viable method, however the trend of ecology has now precluded this as a
possibility. Such methods as pumping sludge to drying beds for which the
vast open area is needed and is not available, pumping sludge to farm land
for irrigation and fertilizing where the only farm land is far removed from
the site and in another State and permission to cross the State lines would
never be granted, were studied and abandoned as not practical. Further
the Federal requirement to remove phosphorous from the plant effluent has
necessitated drastic sewage treatment process changes which will eventually
eliminate the present sludge digestion stdge. This means that raw sludge
must be handled and disposed of and thus there is no viable method of dis-
posal other than incineration.
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EFFKC7S O.V SKCHEUNE ADJUSTMENTS AND DREDGING
OK THE ECOL,OG5f OF TIiIS POTOMAC ^STUART
I	Fgr;;cr;c
This statement is intended to supplement the environmental
statement titled, "D. C. Water Pollution Control Plant Expansion,
1971 io J 974" and dated February 16, 1971.
II	DoKc-i'lpi'icn of the Area
Fiam its traditional source on the North Branch in V.rest Virginia,
where T^orn^ s Lord Fairfdx'i surveyors set an m.«<--r ibed atone in 1776
to mark the corthwiistern corner of his holdings, to its mouth at Chesapeake
Bay, the Potomac River drains? an area of some 15,000 square miles.
Approximate)'/ 12, 000 square miles-lie abbv^the fall line, where the river
flows in a predominately natural state. Below the fall line, which approxi-
mates the northern boundary of the District of Columbia, the- river is an
estuary; it ebb a and floods in response to the mechanical action of the
ocean tides. As will be seen iii the following discussion, the transition
from a free flowing stream to a tidal estuary is an important factor in
Washington's special water quality management problems. As a matter
r
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of.fd.ct, -a cursory review of the hi3tory of the Washington area would
reveal that the navigable quality of the Potomac estuary is precisely
what attracted the early settlers. Over the years, the combination of
rapid population growth and the estuary's limited capacity for trans-
porting wastes has resulted in the present unsatisfactory condition of
the river.
out their length. The Potomac estuary is among those which are not. Iu
fact, the upper third of its 115 mile length, from about Quantico to Little
Falls, is considered to be fresh water. (While the head of tide is officially
recorded at Chain Bridge, Little Falls is by its very nature a convenient
line of demarcation of tidal influence. ) Because it is fresh water this
stretch of the estuary has an ecology unlike the middle and lov/er estuary
and Chesapeake Bay. It should also he .noted that the lower or downstream,
boundary of the fresh water zone coincides roughly with the lower boundary
of the Washington metropolitan area. It is into this zone that virtually
all of the metropolitan area's wastewaters are discharged. Also, the
roughly 2. 5 million tons per year of sediment which flushes out of the
upper 12, 000 square miles of the basin is deposited in the fresh water
zone. Along with the sediment, other undesirable components of land
Contrary to popular notion, not all estuaries are saline through-
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runoff auch as nitrogen, phosphorus, other agricultural chemicals,
and bacteria flow into the Potomac River to be transported into the
upper estuary. The interaction of these and other factors has cul-
minated in the estuary's present condition.
As noted above, the virtual absence of salt in the upper estu-
ary sets it apart, from an ecological point of view, from the saline
zones. For example, the upper estuary provides spawning grounds
for ceitain anadromous species of fishes. However, poor v/ater
quality (severe depression of dissolved o:-:ygen) has resulted in
several spectacular fish kills during the seaward migration of the
young fryf Another factor which may be involved in the destruction
of fishes is the heavy suspended silt load in the estuary. This ma-
terial is capable of causing fish, to suffocate by clogging their gills.
Ill Effects of Shoreline Adjustment and Dredging
The propbsed future water use for which the highest level of
water quality is required is water contact by humans (swimming, wading,
water skiing, etc.). If "water quality can be improved to permit this
use, all other planned uses will be protected. Thus', one of the main
justificatiens-fer construction of an improved D. C. Water Pollution
MAY 24 
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Control Plant is to improve water quality to the point where human con-
tact will be safe. If this level of quality can be achieved, fish and wild-
life productivitywill.be enhanced.
It has been competently determined that construction of a water
pollution control plant capable of meeting established water quality re-
quirements will necessitate certain alterations of the existing shoreline
and river "bottom". In making this determination, it ha6 been established
tl-at the logistics of this vast and complex construction project will be
such that the proposed construction will be feasible only if their irregular
shoreline is adjusted and barge docking facilities are provided. The
shoreli ne .adjustment and the docking facilities are needed to keep vhe
cost of the project within reasonable limits. As far as logistics are
concerned, the quantities of construction materials and excavation spoil
envisioned are so vast, thatjwithout the. ability to use water transportation,
the feasibility of the entire project is open to question.
Recognizing that any alteration of the natural environment may
have undesirable consequences, such undesirable consequences must be
viewed against the overall background of the environmental benefits
which may result from the proposed alterations. In, this case, it has
been clearly .established that the proposed construction is essential for
him
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improvement of environmental quality. Furthermore, it is recognized
that the proposed Water Pollution Control Ptant improvements will have
a profound benefical effect on the aquatic environment. It is the position
of the Department of Sanitary Engineering, Government of the District of
Columbia that the proposed dredging and shoreline adjustments are an
integral part of the development plan. Consequently, the proposed
alterations must be viewed as a trade-off in the process of overall im-
provement of the environment, with the repugnant alternatives of not con-
structing the plant or doing so at greatly increased cost. With regard to
the latter alternative, it must be emphasized that the current estimated
cost of the proposed construction ($3r 0 million), may not be within the
financial grasp of the participating vinits of government.
A brief description of the proposed dredging and shoreline adjust-
ment is in order. To permit barges to reach the plant site an entrance
channel, turning basin, and dock are proposed. Because of existing
rhsllow water, the entrance channel and turning basin must be dredged.
In the area.covered by the proposed turning basin, the existing water
depth at mean low water varies from 0 to approximately 1. 5 feet. The
overall dimensions of the turning basin are approximately 1900 feet long
by 650 feet wide. The turning basin will be connected to the navigation.
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channel "by ari»entrance channel mea Baring approximately 200Teet wide by
2200 feet long. The entrance channel and turning basin will be connected
by a transition section approximately 600 feet long by 400 feet wide.
Except for a pmall area immediately adjacent to the existing navigation
channel, the existing water depth at mean low water is generally less than
2 feet. Under this proposal, the previously described area will bfe dredged
to a uniform depth of 16 feet below mean low water. The material to be
removed may be described as fine organic mud having no apparent value
cither to aquatic organisms or man. The 'previously mentioned dock v/ill
be approximately 1200 feet long by 75 feet wide and will be adjacent to fbe
turning basin.
The adjusted shoreline will be generally coextensive with the dock.
The dock will be constructed over the*water and will not involve the
placement of fill material.
In an area of sound ecology, the proposed dredging work could
result in some temporary detrimental effects on aquatic organisms.
Howeverj the area under consideration is a normal habitat only for a few t
the hardier game fishes and certain rough or trash fitflu Also, it is felt
the already silt laden condition of the Potomac estuary will not, except
on a very short term basis, be adversely affected by the small amount
of dredging proposed. It should also be noted that dredging for_piii^poses
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of maintaining a navigation channel is periodically conducted in the
vicinity 01 the area in question. Consequently, any possible adverse
effects which might result from the proposed dredging will he transi-
tory in nature and mild in degree. The beneficial ecological effects of
the improved wastewater treatment facility will greatly outweigh the
questionable ecological detriment of filling in this small area. 'An
added benefit will be the restoration of Dyke Marsh using material
excavated during plant construction.
IV Public Opinion
At the several public sessions-of the Potomac River Enforce-
ment Conference, there was not a single objection to the proposed con-
struction. These sessions were attended by numerous conservation
minded individuals. In fact, at one such session, the Executive Director
of the Interstate Commission on the Potomac River Basin stated:
"In this particular instance, I have come to the conclusion that this
would be probably the highest use for this particular area, that this
is, in fact, a mud flat, . . . ".
AS: AM
February 26, 197]

[v^AV

121

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E NY IK O NM L<: N T A L S T ATE M E N T
FOK THE
P] I OP OS ZD SL'JDCE PROCESSING FACILITIES
I. Purpose:
This statement i.s intended Lo supplement the ,-nvironnicntal state-
ment titled, "D. C. Water Pollution Control plant Expansion, 1971 to 1974,"
dated February 16, 1971.
11. A rchiiecturpl Concept:
The architectural expression of the building defines the basic functions
of the operation in simplicity of masc and form. The basic conci'Jt- f--inor
panels surround the /unctions to encompass the whole in clean, horizontal
lines, but broken by the introduction of vertical ribs in the main entrance-
way, thereby eliminating that which might be monotonous. The entrance-
way and the vertical ribs will project shadows which will be ever-changing
as the sun spans the horizon.
The incinerator function rises out of the basic structure in a rec-
tangular shape and its color shall be blending with the base form. The
building is located far enough from the water line to be properly landscaped
with grass, shubbery and trees to blend it in naturally with the proposed
paik strip along the Potomac River. The building will be appropriately night-
lighted.
It is believed that this building, architecturally speakirg, will be in
harmony with the new architectural designs^ for this type of building in the
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V/ashinyton area and will cniunco ibis part of the coastline of the Potomac
Rive r.
III. Air Pollution Prevention:
The sludge incinerator complements the entire solids processing
building air pollution control by providing a totally integrated system of
ventilation, exhaust, combustion air and exhaust gas treatment in a manner
designed to contain all odors and uncleaned products of the combustion
jrocess within the structural enclosure.
Ventilation exhaust air from the entire building is collected in an
equalizing plenum from which the furnace combustion air is drawn in order
:hat odors, if any, entrained in the ventilation air will be destroyed in the
zombustion process. Additional combustion air which may be required will
:>e drawn into the system through a "one way" connection to a stack on the
jqualiscing plenum above the incinerator roof level. In the event that the
ventilation exhaust gas quantity exceeds the required furnace combustion
lir quantity, the excess will be diverted to one of the heat exchanger-fume
urnaccs where odors, if any, will be destroyed by direct flame contact
>urning with natural gas.
The exhaust gas from the sludge incineration process will be cooled
o
o approximately 200 F. by evaporative cooling using filtered and polished
reatment plant effluent water. Upon leaving the evaporative cooling section,
he cooled exhaust gas will be cleaned in a high energy venturi scrubber of
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upp roximately 20 inches water gage pressure drop to remove dry dust
particles and further condense gaseous cornuonnd.s in the exhaust. Th<;
cleaned exhaust gas will then pass into a sub-cooler where further con-
densing of gaseous compounds and water vapor will occur in order that
there will be a minimum quantity of water vapor and exhaust gas for
further treatment. All condensed water vapor and scrubber effluent from
the wet cleaning portion of the process is collected and routed to the head
of the waste water treatment plant for cleaning in the normal waste water
process.
The sub-cooled and scrubbed exhaust gases are normally discharged
to the atmosphere at comparable installations in this country. However,
under some conditions of temperature and humidity a white plume of water
vapor will be evidenced if no further treatment is applied. In addition, the
District of Columbia Department of Sanitary Engince ring has sponsored
\
independently performed tests on exhaust gases from similar furnaces at
another installation in the Midwest and has determined that further treatment
is required to remove a small quantity of hydrocarbons entrained in the
scrubbing and sub-cooling portion of the process. Further, the location of
the plant near the geographic boundary with the State of Maryland created a
desire to meet that state's new and restrictive air pollution standards, if
technically possible.
F.or these reasons the scrubbed and cooled gases arc passed through
a direct flame contact fume furnace designed to burn any carry-over gaseous
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:ompounds from the exhaust «i.nd reheat it to a point where no visible water
'apor will be evidenced at the point v/hcre the purified gases are emitted to
he atmosphere where they will quickly mix with the ambient air.
There has been no by-pass capability provided in the air pollution
:ontrol system so that it is impossible to operate the furnaces without having
he exhaust gases pass through the entire air pollution control equipment
irrangement. An emergency relief has been provided for the protection of
he plant personnel and equipment under extreme emergency conditions to
jrevent an in-plant catastrophy until normal shut-down procedures can be
iccomplished. It is not expected that this emergency relief will be required
my more frequently than the emergency relief valve on a normal domestic
lot water heater, but good judgment and proper design require that it ho
provided.
The system described is costly to install and will be costly to
operate because of the power and fuel requirements. It represents the
maximum limit of presently proven air pollution control technology and is
expected to meet botli the State of Maryland and the proposed District of
Columbia emission standards for the process when tested with the pro-
cedures recommended by the Air Pollution Office of the Environmental
Protection Agency.
[V. Water Pollution Prevention:
The entire quantity of evaporative cooling and scrubber water
required in the incineration of the sludge and the exhaust gas cleaning
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process described above will be directed to the head of the plant where it
will receive the same treatment as the standard plant influent. The water
discharged from the sub-cooler will bo introduced into the plant effluent
sewer at a point where it will be mixed thoroughly before the sub-cooling
process, no additional pollution load is anticipated from the mixing of the
sub-cooler effluent with the normal plant effluent.
V.	Thermal Pollution:
The volume of process water from the cleaning and sub-cooling
process associated with the sludge incineration will have a minor effect on
the overall plant effluent temperature. If the total heat input is considered
added to the normal plant effluent, it is anticipated that the total effluent
temperature will Le raised approximately 3°F. However, the dirty portion
of the process water is returned through the plant cleaning process and it
can be expected to receive some cooling. It is reasonable to expect that
only the sub-cooler discharge heat will affect the normal plant effluent
temperature. This effect is estimated to raise the effluent temperature
approximately 2°F. before it enters the river.
VI.	Noise Abatement:
There is no equipment required by the sludge incineration process
which offers any unusual noise potential and the normal equipment and
operating noise will be contained in the building. The air-conditioned and
enclosed operating room will offer protection for the plant operators from
even the normal process equipment noise within the building.
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APPENDIX J
TEMPORARY ENVIRONMENTAL CONTROLS
REQUIRED OF DISTRICT OF COLUMBIA CONTRACTORS

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SECTION IB
TEMPORARY ENVIRONMENTAL CONTROLS
I. SCOPE
A.	The Contractor shall provide and maintain
temporary measures to control erosion, dust
and water pollution. These temporary
measures shall be coordinated with permanent
project features to assure economical,
effective and continuous environmental
control.
B.	any other temporary environmental control
measures required due to Contractor
negligence, carelessness or failure to
install permanent controls as scheduled
shall be at Contractor expense
C.	should the Contractor fail to promptly pro-
vide needed control measures to the
Engineer's satisfaction, this work will be
done by others and the cost thereof plus
10 percent deducted from payment to the
Contractor
D.	prior to start of applicable work, the
Contractor shall submit an approved schedule
showing control as applicable for clearing,
excavation and grading, plus control on
haul roads and borrow pits and a plan for
disposal of waste materials
E.	the Contractor shall provide prompt temporary
measures to prevent erosion. Such work may
involve the construction of temporary berms,
dikes, dams, sediment basins, slope drains,
and use of temporary mulches, mats, seeding
or other control devices or methods as
approved. Cut slopes shall be seeded and
mulched to the extent practicable as the
excavation proceeds. The Engineer may limit
the surface area of exposed erodible material
F.	the Contractor shall remove temporary
environmental control features as needed
Jl

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and incorporate permanent control features
into the project at the earliest practicable
time
II. SITE PREPARATION
A.	grade and scarify as needed and feasible to
permit use of equipment
B.	scarify parallel to contours
C.	install diversion and desilting devices
1.	interceptor ditches
2.	berms, terraces
3.	erosion stops or basins
III. SEEDED PREPARATION
A.	apply
1.	pulverized dolomitic limestone,
2,000 lb. per acre
2.	0-20-0 superphosphate or equivalent
700 lb. per acre
3.	10-10-10 fertilizer or equivalent
1,000 lb. per acre
B.	harrow or disk lime and fertilizer into
soil parallel to contour to depth of 2 -
3 in. and till to uniform fine seedbed
IV. SEEDING
A.	Kentucky 31 tall fescue 60 lb. per acre
B.	apply uniformly
1.	with cyclone seeder, drill, cultipacker
seeder, or hydroseeder (slurry includes
seed and fertilizer)
2.	on firm moist seedbed
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3. along contour
C. compact surface following seeding
1.	with cultipacker, roller, or light drag
2.	normal soil cover 1/4 to 1/2 in.
v- MULCHING
A.	immediately after seeding
B.	uniformly with unweathered small grain straw
1.	1-1/2 to 2 tons per acre
2.	wheat straw preferred
3.	oat straw excluded
C.	asphalt mulch tie down
1.	liquid asphalt
a.	RC-250 or MC-250
b.	apply at 0.1 gallons per square yard
2.	emulsified asphalt
a.	RS-2 or MS-2
b.	apply at 0.04 gallons per square
yard
3.	apply so area has uniform appearance
VI. MAINTENANCE
A.	irrigate if required
1.	until firmly established
2.	particularly if seeding is late in
planting season, abnormally dry or hot
B.	repairs
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1.	inspect for failures
2.	reseed as required
C. mowing
1.	not required in some areas
2.	not closer than ^ in. in other areas
J4

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APPENDIX K
CONDITIONS FOR TEMPORARY USE OF
LAND AS CONTRACTOR'S STORAGE AREA
PREPARED BY THE NATIONAL PARK SERVICE

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The Contractors will be permitted to use a portion of the storage
area as designated by the Engineer. The storage area is located
between South Capitol Street, Qxon Run, and the District of Columbia
line and belongs to the National Park Service of the U. S. Department
of the Interior. The District has obtained a permit from the National
Park Service for the use of the storage area. The Contractors shall
comply with all conditions of the permit which are as follows:
"The District of Columbia hereby agrees to be fully
responsible for the management, protection, use and safety
within the park areas involved in this authorization until
the work is completed, inspected, and the park areas are
accepted, in writing. The District of Columbia hereby
agrees, subject to the availability of appropriations, to
accept responsibility and assume liability for any and all
claims arising through tort actions which result from
incidents directly or indirectly connection with the work
performed. To the extent that work is performed by non-
governmental persons or organizations, the District of
Columbia shall require such persons or organizations to
provide evidence of adequate public liability and property
damage insurance in a form to protect the interests of the
United States.
In the work described, the District Government will require
employees and contractors to exercise all normal and
reasonable safety precautions.
All reasonable precautions shall be exercised to protect
park property. The work and storage area shall be enclosed
with solid board fencing, 8 feet high, painted a neutral
shade of green, and placed 8 feet inside the property line.
The entrance gate to the area shall be at the dead end of
Southern Avenue, west of South Capitol Street. Vehicles
shall not be parked on the grass outside of the fenced
enclosure.
All disturbed areas and park facilities damaged by this
work shall be restored to the satisfaction of the
Superientendent, National Capital Parks-East, National
Park Service. Disturbed grass area shall be fine graded,
topsoiled, and seeded, with a mixture of 70 percent K-31
and 30 percent Kentucky blue-grass seed.
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Permittee shall comply with all instructions issued
by the U. S. Park Police and other official represen-
tatives of this office.
Barricades, fences, signs, flares, lanterns, and other
suitable devices necessary for employee and public
safety shall be provided and adequately maintained.
All trash, debris, and litter left at the site by
workmen shall be removed by permittee. Trash baskets
shall be maintained within the enclosure.
Vehicles shall enter and leave the work and storage area
at Southern Avenue and South Capitorl Street. Traffic
regulations shall be complied with and there shall be
no interference with traffic during the rush hour
periods of 7 to 9:30 a.m. and 4. to 6:30 p.m. daily.
A copy of this letter shall be available at the site
during occupancy of the area. An approved informational
sign shall be displayed during use indicating the
identity of the permittee responsible for the work on
parkland. The permittee shall notify the Division of
Permits and Inspections prior to commencing and when
the use is completed and the area ready for inspection."
K2

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APPENDIX L
PROPOSED POLLUTION PREVENTION REGULATIONS
FOR VESSEL AND OIL TRANSFER FACILITIES,
S. COAST GUARD, DEPARTMENT OF TRANSPORTATION

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2 IDfiO
PROPOSED RULE MAKING
DEPARTMENT OF
TRANSPORTATION
Cocsf Guard
t 33 CFR Parts 154,155,156 1
[CGFP. *71—1201
POLLUTION PREVENTION
Vessel and Oil Transfer Facilities
The Coast Guard is considering
.mending the pollution regulations by
:dding three new Parts, 154, 155, and
5G, to Subchapter O of Title 33, Code of
federal Regulations, to govern the op-
iration of facilities and vessels and the
ransfer of oil to or from certain ves-
els to prevent the discharge of oil.
Interested persons are incited to par-
icipate in the making of the proposed
ule by submitting v.Titten data, views,
>r comments regarding the proposal to
he U.S. Coast Guard (CMC), Washingt-
on, D.C. 20330. Communications should
dentify the notice mtmber, CGFR 71-
.00, any r.pecific wording recommended,
¦easons for any recommended change,
nrd the name, address, arid organiza-
,ion, if any, of the commentator.
The Coast Guard will hold a public
rearing on February 15, 1972 at 9:30
x.m. in Conference Room 2230, Depart-
ment of Transportation, Nassif Building,
100 Seventh Street SW., Washington, DC.
Interested persons are invited to attend
the hearing and present oral or written
statements on this proposal.
All communications received before
February 21, 1072, or at the hearing, will
je fully considered and evaluated before
final action is taken on this proposal.
Copies of all written communications re-
ceived will be available for examination
in Room 8234, Depai tment of Transpor-
tation, Nassif Building;. 400 Seventh
Street SV/., Washington, DC, both before
and afior the closing date for the receipt
of comments. The proposal contained in
this document may be changed in the
light of the comments received.
On April 3, 1970, the Presifle.it signed
the Water Quality Improvement Act of
1970 which amended the Federal Water
Pollution Control Act (FWPCA). Section
11 of this Act, conferring control of
pollution by oil, states in part, "The Con-
gress heieby declares that it is the policy
of the United States that there should
be no discharge of oil into or upon the
navigable waters of the United Stages,
adjoining shorelines, or into or upon the
waters of the contiguous zone."
At the NATO Committee on the Chal-
lenges to Modern Society (CCMS) meet-
ing in Brussels in November of 1070, Sec-
i-jtaiv- of Transportation John Volpe
proposed "by mid-decade (1S75) a com-
plete halt to all intentional discharges of
o:l rnd oily wastes into the oceans by
tankers and other vesjels". This goal,
modified to include "other noxious sub-
st.mcos"', has been established as the
nvjor objective of the Oil Pollution Con-
ference to be held in 1973 under the
an.-,pices of the Ir.U-rgov erhmenlal Mari-
time Consultative Organization (IMCO).
A review of pollution incident statis
tics and the progress of vountary in-
dustry programs since amending the
FWPCA indicates that regulatory action
is necessary to meet our stated goals.
Therefore, acting under the authority of
section llfj) (1) of the FWPCA, which
provides in part: •" * * the President
shall issue regulations * * * (C) estab-
lishing procedures, methods, and require-
ments for equipment to prevent dis-
charges of oil from vessels and from on-
shore facilities and offshore facilities,
and (D) governing the inspection of ves-
sels carrying caigoes of oil and the in-
spection of such cargoes in order to re-
duce the likelihood of discharges of oil
from such vessels in violation of this sec-
tion," the Coast Guard is considering
regulations in four general problem
areas. These are; tank cleaning and bal-
last; bilges, leaks, and fueling spills;
vessel casualties; and facility (terminal)
or oil transfer operations.
The tank cleaning and ballast dis-
charge problem principally occurs in in-
ternational waters p.nd, due to the rela-
tive fleet sizes, results piimarily from
vessels other than U.S. flag vessels. Tiris
problem is under active consideration by
the Intergovernmental Maritime Consul-
tative Oiganization (IMCO) and can
only be resolved by international agree-
ment. Therefore, in developing these reg-
ulations. consideration of the deliberate
discharge problem has been limited to
implementing the 1959 amendments to
the Contention for Prevention of Pollu-
tion of the Seas by Oil, 1954, as amended.
However, it should be noted that shore
reception of dirty ballast appears to be
the only feasible solution for vessels not
able to use load-on-top procedures. Com-
ments on making a mandatory require-
ment for the reception cf slops and dirty
baiiast by terminals are solicited.
Although the United States has rati-
fied the 1969 amendments, they will not
come into force internationally for some
time. Implementation of these amend-
ments on a worldwide baii:> would recluse
the deliberate discharge of oil to the seas
by nearly 90 percent. Although drafted
in regulatory form, the 19C9 amendments
cannot be promulgated until legislation
is enacted by the Congress modifying the
1961 Oil Pollution Act which imple-
mented the Oil Pollution Convention.
Tire problem of vessel casualties can
be divided into collisions (vessel to ves-
sel) , collisions (vessel to object), giound-
iugs, and otH-r items such as fire and
explosions, which are primarily safety
problems with pollution as a secondary
consideration. The problem of fire and
explosions i:; under continuous review
and analysis and, therefore, .special ef-
forts in this area for pollution preven-
tion are consideied unnecessary.
The external (to the vessel) naviga-
tional and operational control of vessels
to prevent collisions and groundings is
bein/r considered by Congress in the
Port Safety Bill H.R. S110 S. 2074 ct al.
No action in this regaid is presently pro-
posed i:i the matter of genera! maritime
safely. It is emphasized here, and v. ill be-
come further apparent in this discus-
ion. that maritime safety and pollution
prevention are intimately related and
cannot be separated. The proposed regu-
lations do consider the structural ade-
quacy of the vessel to withstand specified
limited energy operational groundings,
rammings, and collisions. If operational
conttol proves inadequate, then vessel
design will be reconsidered.
The maneuvering characteristics of
vessels aie urider study internationally.
It is not deemed possible at this time to
relate and resolve the cont'ibution to
pollution of the powering and maneuver-
ing characteristics of tugs and barges in
our inland and coastal waterways. This
potential problem will be further studied
and. should a problem be determined to
exist, appropriate action will be taken.
This notice, then, stresses efforts to re-
duce oil pollution from bilge discharges,
leaks, spills, and terminal operations
which result in the discharge of oil into
the ecologically sensitive inland and
coastal waters of this country. In de-
veloping this proposal, the existing bedy
of laws, regulations, policy, and internal
procedures were examined.
An accompanying notice of proposed
rule making revises Chapter I of Title <1G
to specify additional examination and li-
censing requirements for U.S." seamen
pnd to modify the inspection and dry-
dockrng requirements for U.S. vessels. In
addition, changes will be proposed in the
near future to revise Chapter I of Title
46 to more clearly define the require-
ments concerning the discharge of liquid
bnl'.aot required for stability.
The definition of oil used in this pro-
posal is that contained in the act and
includes the lighter fractions of the
petroleum distillation process such ps
kerosenes, gasolines, and napthas.
Part 154 would contain regulations
go\ srning large onshore and offshore
facilities engaged in the transfer of oil
to and from vessels. A large facility is
one which transfers oil to or from a ves-
sel which has a tank capacity for that
oil of 10,003 U.S. gallons or more. These
large facilities wiil remain subject to the
safety requirements of 33 CFR Pait 126.
Tires? regulations would not apply to
small vessel fueling operations such as
marinas using insert automatic fill xroz-
rles, typical cf gas station operations.
Also, they would not apply to such oper-
ations as a large vessel taking on lube
oil at a dry cargo terminal even though
the vessel may have a fuel oil capacity-
greater than 10,000 gallons.
Subpart A of Part 1P4 contains the
general applicability clauses, definitions,
and the basic lequirement tint no per-
may engage in oil transfer operation*:
to or from a vessel after April 3. 1973,
without or ia violation of an oil Uarrsfer
permit issued by the US. Coast Guard.
Although 33 CFR Pait 12(1 presently re-
quires all facilities handling hazardous
products to be a "designated waterfront
facility." there is no formal designation.
A formal permit system will result in a
cuirenl inventory of all oil hand::n;
facilities and thereby enable irspi-.-Uon
and control of such facilities to deter-
mine the adequacy cf tire physical plant,
its personnel, and procedures.
FEDERAL RHGIST:^, VOL. 36, MO. 24 8—f .^lO.'.Y, Dl ZC.V.^R 2 *,, 19/1

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PROPOSED RULE MAKING
2-1 f'Gl
Sub;>art B would contain the d. engaged
in transfer o;>erations at the fa-ci'my.
The regulations would not require a
personnel shelter for each facility. How-
ever, a shelter would be a consideration
to be covered m the operating manual
to assure the presence of personnel dur-
ing the oil transfer.
- Subpart D, facility Operations, would
contain general requirements for the op-
eration of an oil transfer facility.
Requirements would be given for the
designation and the qualification of fa-
cility personnel as person in charge of
oil transfer operations. This designation
is made by The facility permit holdei
based upon the designee's knowledge,
training, and experience. The designa-
tion is valid onl3r at specified facilities
and is not generally transferable.
Part 155 would contain regulations
governing vessel design and operation
to minimize any loss of oil from accident
or from normal operations and would
also contain regulations for vessels en-
gaged in oil transfer operations analo-
gous to Part 154 for facilities.
This part would apply to all vessels
carrying oil as cargo and to all vessels
engaged in fuelmg, oily waste disposal
or ballast discharge, and 'operating in
the navigable wafers of. the United
States. These regulations would be
applicable to foreign vessels and unin-
spected vessels. Any limitation on appli-
cability is noted in the particular
regulation
Subpart E would contain the lequire-
ments for vessel design and construction.
Section 155.305 would require that all
inland barges built after December 31,
1972, be of doable wall (sides and fore
and aft ends) construction. The purpose
of this proposal is to eliminate the myr-
iad of leaks from barges in the inland
waterways from routine operational side
and end damage. Additionally, this re-
quirement is expected to substantially
reduce the oil spills resulting from minor
vessel collisions. This type of construc-
tion has been required for some years
for vessels carrying flammable chemical
products and has not created any safety
problems such as explosions or fires
from flammable vapors in the void
spaces.
The regulation would apply to new or
"rebuilt" vessels. The term "rebuilt" is
recognized to be quite subjective and
must be considered in each individual
case. The intent is to permit plate re-
newal or hull repairs to damaged single-
skin barges m otherwise good condition,
but to prevent circumvention of the reg-
ulation applicable to new construction
by rebuilding an old vessel and signifi-
cantly extending the vessel's life. This
would then phase out existing single-
REGISTER, VOL. 36, NO. 248—FRIDAY, DECEMBER
L2
^/dn barges. The alternative to this use
of "rebuilt" is to specify a termination
date for the use of single-skin barges.
Comments on the proposed approach and
its alternatives are specifically invited
Section 155.310 requires a deck spill
containment system on all vessels ca-
pable of handling more than 10,000 gal-
lons of cargo oil. The containment may
he either fixed r.fitollmen*;, or enclosed
deck sunns. The requhed containment
volume is 1 elated to hose size as an esti •
mate of possible spill size. This system
is not intended to prevent a massive d:s-"
charge but is aimed at the frequent ac-
cidental hose drainage, air bubble m the
vent, or minor overfill type discharge.
Section 155.330 would require that all
¦vessels operating on the navigable*
waters or contiguous zone must prior to
January 1, 1975, have a means to retain
all oily bilge wastes onboard. Such con-
tainment. may in fact he the bilge itself
provided an undue fire or stability prob-
lem does not result, therefrom. For ves-
sels w'nich have laige \olunies of oily
wastes generated onboard, a holding
tank would be necessary. There would
be no requirement; to hold water such as
stern tube leakage onboard provided it
would not become contaminated with
oil.
- All vessels of 100 gross tons or more
would have positive acting valves in-
stalled in their bilge overboard dis-
charge lines which can be sealed-when
in the U.S. navigable waters. Vessels less
than 100 gross tons would be exempt
lrom the valve requirement but would
have onboard a placard concerning the
prohibition of oily waste discharge. Ad-
ditionally, all vessels of 100 gross tons
or more would have to install topside
¦fittings for the discharge of oily v.-astes
to shore reception facilities. All vessels
which ballast fuel oil tanks would have
to install ballast discharge valves and
o'eck fittings as required for bilge sys-
tems. Vessels which have a means to
process or transfer bilge wastes to a
cargo oil slop tank would be exempt
from the requirements to have a system
t.o di;-charge cily wastes to reception
facilities. - .
All vessels of 100 gross tons or more
would be required to seal their bilge
and ballast overboard valves in the
closed )X>sit:on while in the navigable
waters. Each operator wih provide the
seals and seal his own valves and main-
tain a record of valve usage. Tins record-
keeping is not considered an administra-
tive burden since tlie valve seals should
not be broken while in U.S. waters.
Section 155.470 would .specify that oil
not be carried in barge rakes nor
forward of the collision bulkhead in ves- -
seis required to have such bulkheads.
This requirement would apply to all ves-
sels m U S. waters. The rakes of barges
and bows of ships are exiwsed and sub-
ject to damage, and any oil 111 these •
forward compartments constitutes an
unnecessary hazard to the environment
These requirements are intended to pro-
hibit not only tiie bulk carnage of oil
in these forward compartments but also
to prohibit stnpping cargo tanks into
these compartments.
7,4, 1971

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24962
PROPOSED RULc MAKING
Subpart C, Part 155 is similar U
parts C and D of Part 154 in speeding
personnel, equipment, and procedures to
prevent oil pollution.
Sections 155.720 through 155.760
would require each vessel capable of
transferrin? 10,000 U.S. gallons or more
oil to have, use, and post oil transfer
procedures. These procedures would be
leviewed by the Ccast Guard during
routine inspections of vessel operations
and would be conspicuously posted on
board the vessel in a language commonly
used by the crew. This will provide a
ready reference to the crew and local
law enforcement personnel to determine
if the proper equipment and personnel
are being used to safely transfer oil
products. The procedure would be ap-
plicable to the handling of cargo and
fuel oil. The Coast Guard may require
the procedure to be revised. Section
155.810 would require that any vessel
containing oil in cargo tanks must be at-
tended. This requirement is a result of
Incidents of vandalism and malicious
mischief resulting in barges being cast
adrift or valves being opened. This Is an
extension of the watchman requirement
presently specified in 48 CFR. 35.C5-15.
Part 158 would contain the procedures
to be followed on the vessel and the
facility while transferring oil to or from
vessels with a capacity of 10,000. U.S.
gallons or more.	- ¦.
Section 156.110 would specify the con-
ditions under which "the person ,in
charge can supervise one or more ves-
sels or act as the person in charge for
both the vessel and the facility. ¦. .
Section 156.120 would specify the con-
ditions which must exist during oil
transfer operations. In general, these re-
quirements could be classed as good
operating practice. However, items of
special interest are:	—
(£) A person must be present who can
fluently speak the common languages
used on the supplying and receiving
unite.
(b) The persons in charge of the two
units must hold a conference and agree
on procedures and equipment to be used
and be aware of applicable laws and
emergency procedures.
Section 156.150 would require the per-
sons in charge to follow and complete an
extensive declaration of inspection form
prior to any oil transfer. The declara-
tion of inspection required is for items
directly related to pollution; however,
it should be combined with the present
declaration of inspection required for
safety purposes.
Under Section 11 (j) (2) of the Act, any
owner or operator of a vessel or an-on-
shore facility or an offshore facility and
any other person subject to these regu-
lations who fails to comply or refuses to
comply with the provisions of these regu-
lations, shall be liable to a civil penalty
of not more than $5,000 for each
violation.
In consideration of the foregoing, the
Coast Guard proposes to amend Chapter
I of Title 33 of the Code of Federal Regu-
lations as follows:
a. By amending Subchapter O b_
adding new Parts 154, }55, and 156 to
read as follows:
PART
Sec
154.100
154 105
154.110
154—LARGE OIL
FACILITIES
Subpart A—General -
TRANSFER
Applicability.
Definitions.
"Peim.it and operations manual re-
quired.
Subpart B—Oil Transfer Permit
154 300 Eligibility for permit and amend-
ment.
154.310 Application for Issue or ?.mendment
of permit.
154 320 Contents of permit.
154.325 Duration of permit.
154 330 Renesval of permit.
154 335 Suspension and revocation of per-
mit. "	'
154.340 Amendment of permit and opera-
tlons manual. • r
154.34.5 • Amendment, suspension and revo-
¦ -	cation procedures.
154.350 Waivers.
154 355 Operations manual: general.
154.360 Operations manual: contents.
154.355 Operations manual: copies.
154 370 Inspection authority.
Subpart- C—Equipment Requirements
154 500	Hose assemblies.
151510	Loading arms.
154 520	Closure devices.
154.530	Small discharge containment.
154 540	Discharge removal.
154.545	Discharge containment equipment.'
154 550	Emergency shutdown.
154 560	Communication-"
154.570	.Lighting.
Subpart D—Facility Operations
154.700 General.
154.710 Persons In charge: de^isnatioa.
154.720 Persons In charge: qualification.
154.730 Persons in charge: evidence of des-
ignation.		
154.710 Records.	-	. .
154.750 Compliance with operations man-
ual.
Authority: The provisions of this Part
154 Issued under sec. 11(J)(1)(C) of the
Water Pollution Control Act of 1958, added
by the Water Quality Improvement Act of
1970 (84-Stat. 91). 33 0 5.0. 1161 (J) (1) (C);
E.O 11548, 3 CFR, 1971 Supp . p. 545; 49 CFTt
1.46(m).
Subpart A—General
§ 154.100 : Applicability.
This part applies to the operation of
each onshore or offshore facility when it
transfers oil to or from any vessel that
has a-capacity of 10,000 U.S. gallons or
more for that " oil except when- it
transfers—
(a)	Lubricating oil for use onboard the
vessel; or
(b)	Nonpetroleum based oil to or from
a vessel other than a tank vessel.
§ 15-t.l0i» Definitions.
As used in this part:
(a)	"Commandant" means the Com-
mandant of the Coast Guaxd or his
authorized representative.
(b)	"Captain of the Port" means a
U.S. Coast Guard officer commanding a
.iptain of the port area described in
Part 3 of this chapter or his authorized
representative or, where there is no
captain of the port area, a district com-
mander of a Coast Guard district da-
scribed in Part 3 of this chapter or his
authorized representative.
(c)	"Discharge" includes but is not
limited to, any spilling, leaking, pump-
ing. pouring,- emitting, emptying,, or
dumping
(d)	"Officer in Charge Marine Inspec-
tion" means a U S. Coast Guard officer
commanding a marine inspection zona
described in Part 3 of this chapter or hi;;
authorized representative.
(e)	"Offshore facility" means any
• facility of any kind located, in, on, or
under, any of the navigable waters of the
United States other than a vessel or a
public vessel. ¦ ¦_ .
_ (f) "Oil" means oil of any kind or in
any form, including, but not limited to,
petroleum, fuel oil, sludge, oil refuse, and
oil mixed with wastes other than dredged
spoil.	.	- *
(g)	"Onshore facility" means anj
facility (including, but not limited tc
motor vehicles and rolling stock) of any
kind located, in, on, or under, any hind
within the United States other than sub-
merged land. -
(h)	"Vessel" means every description
of watercraft or other artificial contriv-
ance used, or capable of being used, as a
means of transportation on water other
than a public vessel. -
(i)	"Person in charge" means a per-
son designated as a person in charge
under § 154.710 or § 155.700.
§ 154-.11 0 Permit required.
After April 3, 1973, no person may
operate a facility in operations to wliieh
this part applies without, or in violation
-of-an. oil transfer permit issued under
this pan; or in violation of this part. ~
Subparf B—Oil Transfer PermiJ
§ 154.300 Eligibility for permit anil
amendment.
(a> An applicant is entitled to the
issue or amendment of an oil transfer
permit if—
fl> The captain.:of the Port finds,
after an inspection of the facility and
a review of the oil transfer procedures,
that the applicant is properly and ade-
- quately equipped and able to "transfer oil
in accordance v/ith this part and without
discharge into the navigable waters.
(2) The applicant has the certifica-
tion prescribed in section 21(b) (1) of the
.Federal Water Pollution Control Act, as
amended.
(b) At any time within 30 days aftei
receiving from the Captain of the Port
a notice of refusal to issue or amend a
permit, the applicant or permitholder
may petition the Commandant via the
Captain of the Port to reconsider the
refusal to issue or amend.
§ 154.310 Application For 3»jue or
amendment of permit.
fa) Each applicant for the issue of an
oil transfer permit under this part must
FEDERAL REGISTER, VOl. 36, NO. 248—FRIDAY, DECEM3ER 24, 1971
13

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PROPOSED RULE MAKING
24%3
submit his application in writing, acc>
pamed by a copy of toe facility's opera-
tions manual and a copy of the
certification required by section 21(b) (3)
of Uie Federal Water Pollution Control
Act, to the Captain of the Port in the
area in which the facility is or will be
located.
(b)	Each application submitted under
paragraph (a) of this section may be in
any form but must contain the name and
address of—
(1)	The facility;
(2)	The owner of-the facility; and
(3)	The operator of the facility.
(c)	Each operations manual sub-
mitted under paragraph (a) of tins sec-
tion must be prepared in accordance
with £ 154.355 and contain the informa-
tion in § 154.360.
(d)	An applicant for a permit must
submit his application at least 00 days
before the date of intended operation
under this part except that a facility
operating before (the effective date of
these regulations) must submit its ap-
plication before November 1, 1972.
, (e) An applicant for an amendment
to a permit must submit his application
at least 30 days before the proposed
effective date of that amendment unless
a shorter period is allowed by the
Captain of the Port. -
§ 154.320 Contents, of permit.
-	Each oil transfer permit issued under
this subpart contains— ;
(a)	The names of the facility and the
owner and operator of the facility;
(b)	The facility location;'
-(c) The oil transfer operations cov- .
ered by the permit;.
(d)	Limitations; .
(e)	The expiration date of the permit;
and .
(f)	Any other item that the Captain
of the Pom determines is necessary to *
cover a particular situation.
§ 154.323 Duration of permit.
An oil transfer permit issued under
this patt is elective for 5 3 ears unless
it is surrendered, suspended, revoked, or
otherwise terminated.
§ 754.330 .Renewal of permit.
-	Each permitholder -desiring to renew
its permit must apply to. the Captain:
of the Port for renewal in accordance
vath the procedures in § 154.310.
§ 154.335 Suspension and revocation of
permit. -
(a)~	The Captain of the Fort m2y sus-
pend or revoke an oil transfer permit
issued under this part at any time the
facility does not meet the requirements
of this part.
(b)	If an oil transfer permit is sus-
pended or revoked, the holder of that
permit shall return it to the Captain of
the Port.
§ 154.340 Amendment of permit «nd
operations manual.
The Captain of the Port may, on his
own initiative, amend an oil transfer
permit or require the permitholder to
amend the operations manual if, after
inspection he finds that the permit or
operations manual is not adequate to
meet the requirements of this part. '
§ 154.345 Amendment, suspension imd
revocation procedures.
(a)	When the Captain of the Port de-
termines to require an amendment of
an operations manual, or to amend, fus-
pend, or revolve an oil transfer permit,
he notifies the permitholder, m writing
of a date not less than 14 days from the
date of the notice, on or before which
the permitholder may submit written in-
formation, views, and arguments on the
amendment, suspension, or revocation.
After considering all relevant material
presented, the Captain of the Port noti-
fies the permitholder of any amendment
required or adopted or of his decision to
suspend or revoke the permit or ho re-
scinds the notice. The amendment, sus-
pension, or revocation becomes effective
not less than 30 days after the permit-
hoitier receives trie notice, unlet:, the
permitholder petitions the Commandant
to reconsider the notice, in which case
its effective date is stayed pending a de-
cision by the Commandant.
(b)	If the Captain of the Port finds
that ihere is a condition requiring im-
mediate action to prevent the discharge
of oil that makes the procedure in para-
graph (a) of this section impracticable
or contrary to the public interest, he may
issue an amendment, suspension, or revo-
cation effective, without stay, on the
date the permitholder receives notice of
it. In such a case, the Captain of the
Port includes a brief statement of the
reasons for bis finding' in the notice, and
the perrnuholaer may petition the Com-
mandant to reconsider the amendment,
suspension, or revocation.
(c)	Petitions to the Commandant must
be submitted in writing to the Captain
of the Port.
§ 154.350 \?'aivers.
. The Captain of the Port may, by an
appropriate provision in or amendment
to the permit, v. aive, in whole or in part,
compliance with any requirement in this
part if—
(a)	Application for the waiver is sub-
mitted to the Captain of the Port at
least 30 days before operations under the
waiver are proposed unless a lesser time
is authorized by the Captain of the
Port; and
(b)	The Captain of the Port finds that
an equivalent level of protection of the
navigable waters from pollution by oil
will be provided by the alternative pro-
cedures, methods, or equipment stand-
ards to be used by the applicant or
permitholder.-
§ 154.555 Operations manual: genera!.
(a) Each applicant for sin oil transfer
permit must prepare and submit with its
application an oj>erations manual that
describes—
(1) The means and procedures that
the applicant uses to meet the operating
rules and equipment requirements pre-
scribed by this part;
^^) The duties and responsibilities of
operations personnel in conducting oil
transfer operations under this pai-t.
(b) In determining whether • the
manual meets the requirements of this
part, the Captain of the Port considers
the size, complexity, and capacity of the
facility.
§ 154.S60 Operations liirinu'.il; contents.
Each o.w.:ations manual required by
§ 154.355 must contain—
(a)	The geographic location of the
facility;
(b)	A physical description of the facil-
ity inc.lucLns a plan of the facility show-
ing mooring areas, transfer locations,
control stations, and locations of safety
equipment;
(c)	The hours of operation of the
-facility;
(d)	The sizes, ty]>es, and number of
vessels that the facility can transfer oil
to or from simultaneously;
(e)	Tne frrade and trade name of each
product iransferreU at the iacibty that
is not compatible with oil;
(f)	The minimum number of person-
nel on duty during transfer operations;
(g)	Tr.e names nui telephone num-
bers of facility, Coast Guard, and other
personnel who may be called by the em-
ployees of the facility in an emergency;
(h)	The duties and responsibilities of
watchmen required by § 155.810 of this
chapter and 46 CFR 35.05-15 for un-
manned vessels moored at the facility;
(i)	A description of each communica-
tion system required by this part;
(j) Tne location and facilities of each
personnel shelter, if any;
(k) A description and instructions for
use of dnp Md discharge collection and
vessel slop reception facilities;
(1) A description and the location of
each emergency shutdown system;
(m) Location and instructions for use
of the containment equipment required
by § 154.545;
(n) The maximum relief valve setting
or maximum system pressure when relief
valves are not provided for p^ch oil
transfer system;
¦ (o) Procedures for—
(1)	Operating each loading arm in-
cluding the limitations of each loading-
s-rm; - -
(2)	Transferring oil;
(3)	Completion of pumping;
(4)	Emergencies;
(5)	Reporting oil discharges; end
(6)	Containing discharges.
§154.365 Operations manual: eopifs.
Each ixirmitholn er shall maintain at
lea-st one compleix copy of the opera-
tions manual .at the facility and shall
make it readily available to the operating
personnel and, upon request, to the Cap-
tain of the Port.
§ 154.370 Inspection authority.
Each applicant for an oil transfer ixt-
mit and each permitholder shall allow
the Commandant, at any time, to make
any inspecP.on or test to determine com-
pliance with the Federal Water Pollu-
tion Control Act, as amended, and this
pait.
FEDERAL REGISTER, VOL. 36, NO. 248—FRIDAY, DECEMBER 24, 1971
L4

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2-1964
PROPOSED RULE MAKING
Subpart C—Equipment Requir, .its
§ 154.500 Hose assemblies.
• (a) Each assembly consisting of a
hose and couplings that is manufactured
after September 1, 1972, and used for
transferring oil must meet the require-
ments of this section.
(b)	The pressure which the manufac-
turer represents to be the minimum
bursting pressure for each hose assem-
bly must be—
(1)	More than 600 pounds per square
inch; and
(2)	At least four times the pressure of
the relief valve setting (or the maximum
pump pressure when no relief valve is .
installed) plus the static head pressure
of the oil transfer system in which the
hose is installed;
(c)	The pressure which the manufac-
turer represents to be the recommended
working pressure for each hose assembly
must be—
(1)	More than 150 pounds per square
mch; and
(2)	More than the pressure of the re-
lief valve setting (or the maximum pump
pressure when no valve is installed) plus
the static head pressure of the oil trans-
fer system in which the hose is installed;
(d)	Each nonmetallic hose must be
specified for oil service by its manufac-
turer.
(e)	Unless otherwise authorized by the
Commandant, each hose assembly must
have flanges that met Standard B16.5,
Steel Pipe Flanges and Flanged Fittings,
of the American National Standards In-
stitute.
(f)	Each hose must be marked for
identification or with—
(1)	The products for which the hose
is used:
(2)	Date of manufacture;
(3)	Burst pressure;
(4)	Manufacturers recommended work-
ing pressure;
(3) Date of the last test required by
§ 156 170 of this chapter; and
(6) The pressure used for that test.
§ 154.310 Xx>atlin£ arm*.
(a)	Each mechanical loading arm used
for transferring oil and placed into serv-
ice after April 3, 1973, must meet the
design, fabrication, material, inspection,
and testing requirements in Standard
E31 3, Petroleum Kefinery Piping, of the
American National Standards Institute.
(b)	Each mechanical loading arm
used for transferring oil after April 3.
1973, must have a means of being
drained prior to disconnection.
§ 154.520 Closure devices.
The facility must have enough butter-
fly valves, wafer-type resilient seated
valves, blank flanges or other means ac-
ceptable to the Captain of the Port to
blank off the end of each hose or loading
aim that is disconnected after transfer
of oil.
§ 154.530 Small di^ctuirge containment.
(a) Except as provided in paragraph
(ci of this section, the facility must have
fixed catchments, curbing, or other fixed
means to contain oil discharged in at
least—
(1)	Each hose handling and loadi
arm area; and
(2)	Each hose connection manifold
area.
(b)	The discharge containment means
required by paragraph (a) of this sec-
tion must hold at least—
(1)	100 U.S. gallons if it serves one or
more 6-inch nominal diameter or smaller
hose or loading arm connections.
(2)	150 U.S. gallons if it serves one or
more hose connections larger than 6
inches but less than 12 inches nominal
diameter; and
<3) 200 U.S. gallons if it serves one or
more 12-inch or larger nominal diam-
eter hose or loading arm connections.
(c)-	The facility may have portable
means to meet the requirements of para-
graph (a) of this section if the Captain
of the Port finds that fixed means to con-
tain discharges are not feasible for part
or all of a facility.	.
§154.5-10 Discharge removal.
The facility must have a means to
safely and quickly remove discharged oil
from the containment means required by
§ 154,530 without mixing incompatible
products.
§ 154.545 Discharge containment equip-
nient.	- t	• •• ,
(a)	Each oil transfer facility must
have ready access to oil containment
equipment to contain oil discharged on
the water, considering—
(1)	Oi'l handling rates;
(2)	Oil capacity susceptible to being
spilled;
(3)	Frequency of facility operations;
(4)	Tidal and current conditions;
(5)	Facdity age, capability, arrange-
ment, and past experience; and
(6)	If the equipment is shared, the ex-
pected frequency of use and probability
of immediate availability.
(b)	For the purpose of this section.
"Access" may be by direct ownership,
joint ownership, cooperative venture, or
contractual agreement.	" .
§ 154.550 Emergency shutdown.
(a)	The facility must have in addition
to the means of communication required
by § 154.560, a means to enable the per-
son in charge of the transfer of oil on
board a vessel at his usual operating sta-
tlon to stop the flow of oil to the vessel
if normal operating procedures fail.
(b)	The point in the oil transfer sys-
tem at which the flow of oil is stopped
must be- on the facility and as close to
the vessel as practicable.
§ 154.560 Communications.
(a)	Each facility must have a means
that enables two-way voice communica-
tion between the person in charge of the
transfer operation on board the vessel
and the person in charge of the facility
transfer operation.
(b)	Each facility must have a means
that enables a person on board a vessel
or on shore to effectively signal his in-
tention to use the means of communica-
tion required by paragraph (a) of this
section.
§ 154.570 Lighting.
(a)	For operations between sunset and
sunrise, the facility must have fixed
lighting that illuminates—
(1)	Each transfer connection point on
the facility with a minimum lighting in-
tensity of 10 foot-candles;
(2)	Each work area on the facility
with a minimum lighting intensity of 2
foot-candles;
(3)	Each transfer connection point on
any barge moored at the facility, to or
from which oil is transferred, with a
minimum lighting intensity of 10 foot-
candles; and	' '
(4)	Each work area on any Darge
moored at the facility, to or from which
oil is transferred, with a minimum light-
ing intensity of 2 foot-candles.
(b)-	The lighting intensity mnst be
measured on a horizontal plane 3 feet
above the barge deck or walking surface.
Subpart" D—Facility . Operations
§ 154.700 General.
The hoider of an oil transfer permit
shall provide, maintain, and use facili-
ties, equipment, personnel, and proce-
dures at least equal in condition, quality,
and quantity to the facilities, equipment,
personnel, and procedures required for-
the issue of the oil transfer permit, for
that facility.
§ 154.710 Persons • in charge: tlesigna-
lion.
The permit holder shall—
(a)	Designate the person or persons in
charge of the transfer of oil to or from
the facility; and
(b)	Advise the Captain of the Port ia •
writing of each designation.
§ 154.720 Persons in charge: (nullifica-
tion.
Ca) No person may serve, and the per-
mit holder may not use the services of a
person, as a person in charge of oil trans-
fer operations unless—
(1> He has had at least 48 hours of
experience in oil transfer operations
under the supervision of the permit
hoider or a person in charge of transfer-
ring oil at the facility for which qualifi-
cation is desired, except that for new fa-
cilities, the Captain of the Port may au-
thorize alternative experience require-
ments;
(2)	The permit holder has determined'
that he can operate the oil transfer
equipment of the facility: and
(3)	The permit holder has determined
that he knows—
Ci) The hazards of each product to
be transferred;
Cii) The rules in this part and in
Part 15S of this chapter;
Ciii) The operator's discharge con tain -
ment procedures;
(iv) The facility operating procedures;
Cv) Vessel oil transfer systems, in gen-
eral;
(vi)	Vessel oil transfer control sys-
tems, m general;
(vii)	Each facility oil transfer control
system to be used;
FEDERAL REGISTER, VOL. 36, NO. 243—FRIDAY, DECEMBER 24, 1971

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(viii) Applicable Federal, State,^^Fd
local oil pollution laws end regulations;
and
oii in charge: evidence of
(a)	Each person in chary;5, shall carry
evidence of his designation as a person
in charge when he is engaged in transfer
operations unless such evidence is im-
mediately available at the lacility.
(b)	A person holding a valid qualifi-
cation as a person in charge of oil trans-
fers under ? 12G.15(o) of this chapter on
April 3, 1073, is qualified to serve as a
person in charge for the purpose of this
section.
§ 154.740 . Records.
Ca) E2Ch permit holder shall keep at
the facility and make available lor in-
spection by the Captain of the Port—
- (1) A copy of the operating permit for
the facility;
(2)	The name of each person currently
designated as a person in charge of oil
transfer operations;
(3)	The date and result of the most
recent test or inspection-of each item
tested or inspected under § 156.170 of this
chapter; and _ • •
(4)	The hose information required by
§ 154.500(f) unless that information is
marked on the liose. -
§ 1 54.750 (AunpliiiiH'e nidi operations
mumud.-
The permit holder shall use and re-
quire its personnel to use the procedures
in the operations manual prescribed by
§ 154.355 for operations under this part.
C—Oil Transfer Personnel, Procedures,
Equipment, oiid Rocorcs
Desjcjnr.tion of person in charge.
Qualifications oX person In charge.
Oil transfer procedures.
Compliance \.-ith oil i-ran^f^r pro-
cedure's.
Posting o' oil tiansfer procedures.
CoLitenus of oil transfer procedures.
Amendment of oil transfer pro-
cedures. .
Machinery oi) drains* Unit-ed States
vc^eis.
Emergency shutdown
Decl: lir.htmg
Oil irp-nsfer bo-.se.
Tank vessel security.
Records.
PART 1 £5—VESSEL DESIGN AND
OPERATIONS
Subport A—General
Sec.
155.100 Applicability.
155.105 Definitions.
155.130 Waivers.
Subport E—Vessel Dei.'gn and Equipment
1R5.305 Double walls: tank burghs.
155.310 Cargo oil discharge containment.
155.320 Fuel oil discharge containment.
155 330 Oily waste ana clop retention.
155.340 BiIqo slops oil \essels more than
100 gross tons- international
¦ voyages.
150.350 B;lge slops on vessels more than
100 gross tons: operations otlier
than international voyages.
155.360 Bilge slops on vessels les.s than 100
gross tons.
155.370 Ballast discharge: vessels of 100
gross tons or more: international
\ojuges.
155.380 Ballast discharge: vessels more
than 100 gro=a tons: operations
oilier than International voyages.
155.390 Bail wt discharge: vessels less than
100 gross tons.
355 400 Valves.
155.410 Bilge and ballast valve seals.
155.420 Valve teals: identification and
reuse.
155.430 Valve seal record.
PROPOSED RULE MAKING
Sc-c.
155.440 Placard: vessels less than 100 gross
to:is.
155 430 Exc>:pvion for nil vessel: oily waste
procttt-sliif; equipment.
155 460 Exception for tank vessels: oily
\wLSiort area, described in
Part 3 of this chapter, or his au-
thorised representative or, where there
is no captain of the port area, a district
commander ot a Coast Guard district
described in Part 3 of this chapter, or his
authorised representative.
(c)	"Discharge" includes", but is not
limited to, any spilimg, leaking, pump-
ing, pouring emitting, emptying, or
dumping'.
(d)	"Officer in Charge Mm me Inspec-
tion" means a U.S. Coast Guard officer
commanding a marine inspection zone
ric-cnbed m Part 3 of this chapter or his
authorized representative.
(e)	"Offshore facility" means any
facility of any kind located in on, or
under, any of the navigable waters of the
United States other than a vessel or a
public vessel.
(1) "Oil" means oil of any kind or in
any form, including, but not limited to,
petroleum, fuel oil, sludge, oil refuse, and
2 m:>
\
•^1 mixed with wastes other than dredged
spoil.
CfT> "Onshore faciliity" means any fa-
cility (including, but not limited to' motor
vehicles and rolling stock) of any kind
located in, on, or under, any land within
the United States other than submerged
land.
(h)	"Vessel" means every description
of watercraft or othrr artificial contriv-
ance used, or capable of being u^ed ar; a
means of transportation on water other
than a public vessel. .
(i)	"Person in charge-'" means a pit-
son designated as a pei-son m charge
under f 154.710 or § 155.700 of this
chapter. ¦
§153.110 "V\ai\ers. J	'
The Commandant may waive, in whole
or in part, compliance with any require-
ment in T.hLs part if— I
Ca) Application for the waiver is sub-
mitted to the Captain of the Port or
Officer m Charge of Mr.nne Inspection
30 days before operations under the
waiver are proposed unless a lesser tune
- is authorized by the Captain of the Port
or Officer in Charge of Marine Inspec-
tion; and	. |
(b) The Commandant finds that an
equivalent level of protection of the
navigable waters from pollution by oil
will be provided by the alternative pro-
cedures, methods, or equipment stand-
ards to be used by the vessel operator.
Subpart B—Vessel Design and.
Equipment
§ 155.305 Donlile vialls: lr>I;tiii-
ilient.
(a) After December 31. 1974, no per-
son may operate a tank vessel that is
cars-j-ing oil that lias a tank capacity
for 10.000 U.S. calkins or moie of oil
unless it has—¦
(1) Fixed containers or enclosed deck
areas that meet the requirements of this
section under or around each oil leading
FEDERAL REGISTER, VOL. 36, NO. 248—FRIDAY, DECEMBER 24, 1971
L6

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2-1966
PROPOSED RULE MAKING
manifold and each oil transfer co»
tion area; and
(2)	A means of draining or removing
discharged oil from each container or
enclosed deck area.
(b)	Each drain and scupper in an en-
closed deck area required by this section
must have an attached means of closing.
(c)	Each fixed container or enclosed
deck area must hold, in all conditions of
vessel list or trim, to be encountered dur-
ing the loading operation at least—
(l) 100 U.S. gallons if it serves one or
more 6-inch nominal diameter or
smaller hose or leading arm connections:
12; 150 U.S. gallons if it serves one or
mors hose or loading arm connections
larger than 6 inches, but less than. 12
inches, nominal diameter; or
(3)	200 U.S. gallons if it serves one: or
more 12-inch or larger nominal diameter
hose or loading arm connections.
§ 153.320 Fuel oil discharge contain-
merit. - .	_ , . .. ^
After December 31, 1974, no person
may transfer oil for fuel to a vessel of
100 gross tons or more unless—
(a)	It has a fixed container or en-
closed deck area of at least 14 CJ.S. gal-
lons capacity under or around each fuel
tank vent, overflow, and All pipe; or
(b)	Each fuel tank vent, overflow, and
fill pipe is located where a portable con-
tainer that is at leist 18 inches deep and
has at least 14 U.S. gallons capacity can
be placed under it.
§ 155.330 Oily waste and blop retention.
(a)	After December 31, 1974, no per-
son may operate a vessel of 100 or more
gross tons unless it has capacity to retain
on board all oily waste and oily bilge
slops that may accumulate while oper-
ating in the navigable waters. ¦
(b)	No person may use a-tank for
oily bilge slops or oily waste on U.S. ves-
sels unless the tank meets the require-
ments of 46 CFR 56 50-50(h) for isola-
tion betwen oil tanks and bilge systems.
§ 155-340 Bilge slops on vessels more
than 100 gro*-:> Ions: international
voyages. -	. .
After December 31, 1974, no person
may operate a vessel of 100 or more gross
tons that is certificated under 46 CFR
Chapter I for international voyages or a
foreign vessel of 100 or more gross tons
unless—
(a)	The vessel has at least one pump
installed to discharge oily bilge slops
through a fixed piping system;
(b)	The piping system required by this
section has at least one outlet—
(1)	For vessels of 1,600 or more gross
tons, on each side of the weather deck;
or
(2)	For vessels of less than 1,600 gross
tons, accessible from the weather deck;
(c)	Each outlet required by this sec-
tion has a shore connection that meets
the specifications in appendix A of this
part or the vessel has at least one porta-
ble adapter that meets the specifications
in appendix A and fits the required
outlets;
(d)	The vessel has a means on the
v.eather deck near the discharge piping
to stop each pump that is used to dis-^
charge oily waste and;
(e) The vessel has a stop valve in-
stalled at each outlet required by this
section.
§ 155.350 Bilge slops on vessels more
titan 100 j:ro*s tons: operations other
than international voyages.
After December 31, 1974, no person
may operate a vessel of 100 or more gross
tons that is not subject to § 155.340 of
this part unless—
(a)	The vessel has at least one pump
installed to discharge oily bilge slops
through a fixed piping system;
(b)	The piping system required by
this section has at least one outlet that
is accessible from the weather deck;
-	(c) Each outlet required by this sec-
tion has a shore connection that meets
the specifications in appendix A of this
part or the vessel has at least one port-
able adapter that meets the specifica-
tions in appendix A and fits the required
outlets; and "	. -
(d) The vessel has a stop valve in-
stalled at each outlet required by this
section.
§.155.360 Bilge blons on vessels less
than 100 gross tons.
After December 31, 1974, no person
may operate a vessel of less than 100
gross tons unless it has a fixed or portable
means to discharge oily bilge slops to
a reception facility.	,
§ 155.370 • linllast discharge: vessels of
100 gross tons or more: international
voyages. ,
After December 31, 1974, no person
may operate a vessel of 100 or more gross
tons that (1) is certificated under 46
CFR Chapter I for international voyages
or a foreign vessel and (2) that ballasts
fuel oil tanks or has combined fuel and
ballast tanks unless—
(a)	The vessel has at least one pump
installed to discharge ballast through a
fixed piping system;
(b)	The piping system required by this
section has at least one outlet—
-	(1) For vessels of 1,600 or more gross
tons, on each side of the weather deck; or
(2)- For vessels of less than 1,600 gross
tons, accessible from the weather deck;
(c)	Each outlet required by this sec-
tion has a shore connection that meets
the specifications in Appendix A of this
part or the vessel has at least one port-
' able adapter that meets the specifica-
tions in Appendix A and fits the required
outlets;
(d)	The vessel has a means near the
discharge piping on the weather deck to
stop each pump that is used to discharge
oily ballast; and
(e> The vessel has a stop valve in-
stalled at each outlet required by this
section.
§ 155.380 n.ill.i-t discharge: vessels
more than 100 gross tons: operations
otlier than international voyages.
After December 31, 1974, no person
may operate a vessel of 100 or more gross
tons that (1) is not subject to § 155.370
Bhd (2) ballasts fuel oil tanks or has
combined fuel and ballast tanks unless—
(a)	The vessel has at least one pump
installed to discharge all oily ballast
through a fixed piping system;
(b)	The piping system required by this
section has at least one outlet that is
accessible from the weather deck;
(c)	Each outlet required by this sec-
tion has a shore connection that meets
the specifications in Appendix A of this
part or the vessel has at least one port-
able adapter that meets the specifica-
tions in Appendix A and fits the required
outlets; and
(d)	The vessel has a stop valve in-
stalled at each outlet required by this
section. .
§ 155.390 Ballast discharge: vessels less
- than 100 gross Jons.
After December 31, 1974, no person
may operate a vessel of less than 100
gross tons that ballasts fuel oil tinks un-
less it has a fixed or portable means tc
discharge oily ballast to a reception
facility.
§ 155.400 Valves.	-
After December 31, 1974, no person
may operate a vessel of 100 or more gross
tons unless—	" ......
(a)	It has a valve in each fixed over-
board bilge and ballast discharge line
except a line used only for discharges
from spaces free from sources of oil;
(b)	It has a positive means of clos-
ing each valve required by paragraph (a)
of this section at the valve if it is ac-
cessible and— ... . .	¦
(1)	On or" above the freeboard deck
of a - vessel that is required to have a
freeboard deck under 46 CFR 43.05-1
¦(g); or
(2)	On or above the main deck of a
vessel that does not have a freeboard
deck;
(c)	Each valve required by §§ 155.340,
155.350, 155 370, 155.330, and paragraph
(a) of this section has a positive means
of being sealed in the-closed position;
and
(d)	Each valve required by §§ 155.340,
155.350, 155.370, 155.330, and paragraph
(a) of this section is conspicuously iden-
tified by a label on or next to the valve
and each remote means of closing the
valve.
§ 155.410 Bilge and ballast valve seals.
Except when discharging bilge slops or
ballast, no person may operate a vessel
of 100 or more gross tons unless each
valve required by §5 155.400, 155.340,
155.350, 155.370, 155.380, and each emer-
gency bilge suction valve is sealed in the
fully closed position in a way that the
valve carrno'. ' e opened without breaking
the seal.
§ 135.420 alve seals: identification and
reuse.
Each person who seals a valve required
to be sealed under § 155.410 shall use a
seal that—
(a) Is numbered or otherwise marked
to distinguish it from all other seals on
board;
FEDERAL REGISTER, VOL. 36, NO. 248—FRIDAY, DECEMBER 24, 1971
L7

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PROPOSED RULE MAKING
249G7.
(b)	Cannot be resealed after it .
broken; and
(c)	Breaks without 'restricting valve
operation, when the valve is opened.
§153.430 W.We se;t! record.
(a)	Each operator of a, vessel required
to have the bilge or ballast valves sealed
under 5 155.410 shall maintain a record
lor each valve containing—
(1)	The name or number of the
vessel;
(2)	The identification number of each
seal used on the valve;
• (3) The date and time each seal is
applied;
(4)	Tiie date and time each seal is
broken; and
(5)	The reason each seal was broken.
(b)	Each person who makes a record
required by paragraph (a) of this section
shall keep tnat record for at least 30
days after the seal is broken.
§ 155.440 Placard: ¦vessels Ie« tlmn J 00
{TroirS tons.
After December 31, 1S74, no person
may operate a vessel of less than 100
gross ions,/except a foreign \essel or a
vessel less than 20 feet in length, unless
it has at least a 5 by 8 inch placard made
of durable material fixed in a conspic-
uous place stating the following:
DrSCHAKGE OF OXL FV.Oi-IISITED
Tiie discharge of oil or oily -waste Into or
upon, trie iiayiga-ble waters oi the United
States which causes a film or sheen upon
or discoloration of the water or causes a
sludge or emulsion, beneath the surface of
fAe V. P.Urr is prohibited by the Feoeral Water
Pollution Control Act, as-amended. Viola-
tors are subject to a penalty of $10,000.
§ 155.450 Exception for ;ill ^e.~~cls: oily
waste processing equipment.
Sections 155.340 through 155.390 do
not apply to a vessel that has a means
approved by the Commandant to process
oily bilge slops or oily ballast.
Exception for tank ^sselr:
oily w.iste transfer equipment.
Sections 155.340 through 155.390 do
riot apply to tank vessels that have a
means of transferring oily bilge slops to
a cargo tank used for slops if that means
meets the bilge and oil system isolation
requirements in 45 CFR 5G.50-50(h).
§ 155.4-70 Prohibited oil spaces.
(a)	Except as provided in paragraph
(b) of this section, after Dc-cember 31,
1974, no person may operate -a vessel
carrying bulk oil or oily .waste in— - ¦
(1)	Any space forward of a collision
bulkhead;
(2)	The forwaramost space of any ves-
sel that does not-have a collision bulk-
head; or	- -	¦
(3)	Any space between double walls,
including spaces on the aft end, on a
barge that is requited to have double
walls under § 155.305; or
(4)	The aftermost space on any barge.
(b)	Fuel oil l'or use on the vessel may
be carried in independent tanks in the
spaces specified in paragraph (a) of this
section if such a tank is at least 24
niches inboard of the hull structure or is
aft of the forward quarter length of the
vessel.
§ 155.480 ln-j>ectioii of\al\e*.
No person may operate any vessel that
has a certificate of inspection issued
under" 4G CFR Chapter I unless each of
the following- valves has been opened,
inspected, and found to function prop-
eriy by tiie owner or operator of tiie i es-
sel or Ins representative at or since the
last drydocking or hauling out of the
tessel required by 46 CFR Chapter j:
(a)	Bilge emergency suction valves
(b)	Ballast sea suction valves except
in lines to oil free tanks.
(c)	Bilge overboard dischaige valves
required by § 155.400.
(d> Baliast overboard discharge valves
required by I 155 400.
te) Valves used to separate clean bal-
last from oil or oily ballast.
(f) Valves used to isolate oil or oily
ballar-t from the sea.
Subpart C—Oil Transfer Personnel,
Procedures, Equipment, arid Records
£ 155.700 )-iij;iiHiK»it of person in
cliarj;c.
The operator of each vessel shall riesig-
nate the person or persons in charge of
each transfer of oil to or from the vessel
and of each tank cleaning operation.
§ 155.710 Qualifications of person in
charge.
(a) No person may serve, and the op-
erator of a vessel may not use the services
of a person, as a person in charge of the
tra-iisfer of oil to or fiom a vessel or of
tank cleaning operations unless—
(1)	For oil transier operations on tank
sliips, he holds a valid license as a master,
mate, pilot, or engineer for tank vessel
.service, except that the person in charge
of tank cleaning operations-conduci.ecl
at an onsiioie tank cleaning facility may
be a certificated tanlcennan;
(2)	For tank barges, he holds a valid
license as a master, mate, pilot, or engi-
neer for tank vessel service or is a certif-
icated tankerman;
(3)	For vesseis other than tank vessels
that are reo.uired by Chapter 1" of Title 4G
to have a licensed officer on board, he
holds a valid license as master, mate,
pilot, engineer, or operator; or
(4)	For all other vessels, he has been
instructed by the operator in his duties
and the Federal water pollution laws and
regulations that, apply to tiie vessel.
§ 153.720 Oil transfer procedures.
No pe;-son may operate a vessel that
has a tank capacity for oil of 10,000 U.S.
gallons or more unless that vessel lias oil
transfer procedures that meet the re-
quirements of this part.
§155.730 Compliance v»illi oil transfer
procedures.
The operator of each vessel shall use
and require it-s personnel to use the oil
transfer procedures required by § 155.720
lor each oil transfer operation.
.7-10 PoMi'iip of oil transfer pio-
ceowrcs.
The oil transfer procedures required by
§ 155.720 must—
(a) Be legibiv printed in a language
understood by the crew; and
 Ee permanently posted at the fuel-
ing station, or cargo control station or a
place where the procedures can be ea.:.'!y
seen and used by the crov.'.
§ 155.750 Content- of oil tran'-fcr > > fl-
eet! tire?;.
Tiie oil transfer p: oceaurcs required hy
$ J 5a.720 must contain—
(a)	If the vessel carries incompatible
cargoes, a list oi the products to winch
the-oil transfer procedures apply:
(b)	A description of each oil transfer
system installed on the vessel including—
(1) A line diagiam of the vessel's oil
transfer piping including the location cf
each valve,.pump, control device, \ent,
and overflow; and
>2) Tiie location of tiie shutoff valve
oi other isolation de\ice that separate.--;
any bilge or baliast system from the oil
transfer system.
(c)	The number of persons required
to operate each oil transfer system;
(d)	The duties by title of each officer,
person in charge, tankerman, deckhand,
and any other person required lor each
oil transfer operation;
(e)	Procedures and duty assignments
for tending the vessel's moorings during
the transfer of oil;
(fi Procedures for operating the
emergency shutdown means reouired by
§ 155.780;
(g)	Any special procedures for topping
oil tanks;
(h)	Procedures for closing all valves
used during the oil transfer operation;
(i)	A description of the deck dis-
charge containment system:
(3) Tiie procedures for emptying the
deck discharge containment system;
(ki Procedures for containment oi" oil
discharges on tiie water; and
(1) Procedures for reporting oil dis-
charges on the water.
§ 155.700 Amendment of oil transfer
procedures.
(a)	The Captain of tiie Port or Officer
in Charge of Mann? Inspection may re-
quire the operator of any vessel that is
required to have oil transfer procedures
to amend those procedures if, after in-
spection, he "finds that the oil transfer
procedures are not adequate to meet the
requirements of Part loO of this chapter.
(b)	When the Captain of tiie Port or
Officer in Charge of Marine Inspection
determines to require an amendment of
an oil transfer procedure, lie notifies the
operator, in writing, of a date not less
than 14 days from the date of the notice
on or before which the operator may sub-
mit written information, views, and
arguments on tiie amendment After con-
sidering all relevant material presented,
the Captain of the Port or Officer 111
Charge of Marine Inspection notifies the
operator of any amendment required
or of his decision to rescind tiie notice.
The amendment becomes elTectiio not
No. 248—Pt. n——2
FEDERAL REGISTER, VOL. 36, NO. 24G—FRIDAY, DECEMBER 24, 1971

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¦MUSS
PROPOSED RULE MAKING
less than 30 days after the opf ' re-
ceives the notice, unless the ator
petitions the Commandant to reconsider
the notice, in which case it effective date
is stayed pending a decision by the Com-
mandant.
(c) If the Captain of the Port or Offi-
cer in Charge of Marine Inspection finds
that there Is a condition requiring im-
mediate action- to prevent the discharge
of oil that makes the procedure in para-
graph (b) of this section impracticable
or contrary to the public interest, he may
require an amendment effective, without
stay, on the date the operator receives
notice of it. In such a case, the Captain
of the Port or Offlcer in Charge of
Marine Inspection includes a brief state-
ment of the reasons for his finding in
the notice, and the operator may peti-
tion the Commandant to reconsider the
amendment.	'
. Cd) Petitions to the Commandant
must be submitted in writing to the Cap-
tain of the Port or Officer in. Charge o£
Marine Inspection who issued the-re-
quirement to amend.
§ 155-770 Machinery oil drainsr -U.S.'
" - • ¦ - -
Ca) Except as provided in paragraph
(b)-, no person may drain the sumps of
oil lubricated machinery or the contents
of oil filters, strainers, or purifiers into
the bilge of any United States vessel.
(b) Before December 31, 1974, oil may ,
be drained from, the sump of oil lubri-
cated machinery into the bilge of a vessel
that is not otherwise required to have a
means to prevent oil draining into the
bilge if—
(1)	The-oil can only be removed from
the sump by first draining it into the
bilge; and
(2)	The oil is removed from the bilge
other than by discharging into the water.
§ 135.780 Emergency shutdown.
(a) No person may operate a tank ves-
sel carrying oil in a cargo tank with a
capacity of more than 10,000 U.S. gallons
unless it has on board an emergency
means to enable the person in charge of
the transfer of oil to stop the flow of oil
to a faciiicy or another vessel if normal
operating procedures fail.
(b> The emergency means must be a
pump control or a quick acting-, power
activated valve. If an emergency pump
control is used, it must stop the flow of
oil if oil could syphon through the
stopped pump.
(c> The emergency means must be op-
erable from the cargo deck, cargo con- -
trol room, or the usual operating station
of the person in charge of the transfer
of oil.	. .
tj 15,">.790 Deck lighting.
' fa) After December 31,1974, no person
may operate a tank ship that is transfer-
ring oil to or from the ship between sun-
set and simrise unless that tank ship has
cm-go click lighting that illuminates—
(1) Each cargo transfer connection
point ?.nd each ullage point with a mini-
mum lighting intensity of 10 foot
candles; and
(2) Each work area, tank trunk,
dome with a lighting intensity of 2 .
candles.
(b) The lighting intensity must be
measured on a horizontal plane 3 feet
above the cargo deck or walking surface.
§ 135.800 Oil transfer hose.
No person operating any vessel may
use, and no person may operate a U.S.
vessel that carries, an oil transfer hose
that is larger than 3 inches in diameter
unless it meets the requirements of
§ 154.500 of this chapter.
§153.210 Tank.vessel security-
No owner or operator of any vessel or-
facility may leave unattended a tank
vessel that contains more than a residual
amount of oil in any cargo tank.
§ 155.320- Records. •
The operator of each vessel shall keep
and make available-for inspection by the
Commandant—
'(a> The name of each person cur-
rently designated as a person in charge
of oil transfer operations;
(b)	The date and result of the most
recent test or inspection of- each item
tested or inspected under § 15G.170 of this
chapter; and	. .
(c)	The-hose information required by
§ 154.500(f) of this chapter unless that
information is marked on the hose.
appendi* .V—Specifications fok Shore Connection
Item Description.
Dim Boston
1 Outsiri*	215 mm- (SV60-
'1 Iiisidbdmineter,.. According to pipVoutsidy-
cltometer.
3	liott (itcle (U.im- ItM mm-(73/ln*)
4	SloU \i\ fl.ing*	G holts 22 mm. (7/iO in
iliametpr shtill be cjiu-
distaiuly nmeetl on oolt
circlo oi th* above di.irn- -
cier, stottihl to the
periphery. The blot width
n Co be 22 mm^ (7.3').
o Flange thickness.. 20nim. (V).
b Bolts ind nuts	b, ^ch of mrrr 0 i") in
diameter ami of suitable*
length.
The flange shall be of steel having a flat
face, with a gasket of ollprooC material, and'
both shall be suitable for n service pressure
of 6 kg/cm-* (85 psl ).
PAST 156—OIL TRANSFER'
OPERATIONS
Sec.
156.100 GsneraJL
156 105 Definitions.
156.110 Person in. charge: limitations.
156 120 Requirements for oil transfer.
156 l.'JO' Connections.
156.150' Declaration of Inspection.
156.160 Supervision by person In charge.
156.170 Equipment tests and Inspections.
Authority: The provisions of this Part
156 Issued antler sees. 11(J)(1) (C) &nd (D)
of the Water Pollution Control Act of 195G,
tuldfcd by the Water Quality Improvement Act
of 1970 (fU Stat. 91); 33 U S.C. 1161 (J) (1)
(C) and (D); E O. 11548, 3 CFR. 1971 Supp.,
p. 545; £9 CFR 1.-16 (m).
§ 156.100 General.
This part prescribes rules that apply
to the transfer of oil to or from any
vessel on the navigable waters of th
United States that has a capacity or
10,000 U.S. gallons- or more for that oil,
except the transfer of—
(1)	Lubricating oil for use- on board
the vessel; and
(2)	Nonpetroleum based oil that is
transferred to or from a vessel other
than a tank vessel.
§ 15<">.]05 Definitions.
As used in this part:
(a)	"Oil"'means- oil' of any kind or
in any form, including, but not limited
to, petroleum, fuel oil, sludge, oil refuse,
and oil mixed "with wastes other than
dredged spoil.
(b)	"Vessel" means every description
of watercralt or other artificial contriv-
ance used,, or capable of being used
as a means of transportation on water
other than a' publle vessel.
(c)	"Person in charge"- means a per-
son designated as a person in charge
under §154.110 or 5 155.700- of this
chapter.	~	"
§ 156.110 'Persons in:charge-----limitations.
Ca) No person may serve as the per-
son in charge of oil transfer operations
on more than one vessel at. a time
unless— ..." -	'	•'
- (1) The vessels - are . immediately
adjacent;- •''	¦- _¦ - • ¦
(2)	There is. a ready- means of access
between vessels; and
(3)-	The person in charge- is not- also
the person in charge of the facility
(b> No-person may serve as the person
in charge of both the- vessel and the
facility during oil transfer operations ex-
cept when the facility permit authorizes
such procedure. .	- - -
§ 156.120 Keqmremeiili for oil Irixnsfer.
No person may transfer oil to or from
a vessel unless— - .. .. . , . .
(a) The vessel's moorings are stron;
enough to hold in all expected condi-
tions of surge, current, and weather and
long enough to allovr adjustment for
changes in draft, drift,, and tide during
the transfer operation;
(b> Oil transfer hoses or leading arms
are long enough to. allow the vessel to
move to the limits of its moorings with-
out placing strain on- hose or loading
arm; "	.
(c) Each hese is supported in a man-
ner that prevents- strain on its coupling;
. (d> Each part of the transfer system
necessary to allow the flow of oil is lined
up for thetrajisfer;.	~
(e)	Each part of the facility and ves-
sel transfer system that Is not necessary
for the transfer operation is secureiy
blanked or shut off;
(f)	The transfer system is connected
to a fixed piping distribution system on
the receiving vessel or facility;
(g)	Except when used to receive or
discharge ballast, each overboard dis-
charge or sea suction valve that is con-
nected to the vessel's oil transfer, bid-
last, or cargo tank systems is sealed in
the closed position:
(h)	Each oil transfer hose is free from
loose covers, bulges, gouges, cuts, slashes,
and soft spots;
FEDERAL REGISTER, VOL. 36, NO. 248—FRIDAr, DECEMBER 24, 1971
L9

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PROPOSED RULE MAKING
24969
(i) Each bolted flange coupling meets
the requirements in ? 156.130;
(j) Tlio discharge containment re-
quired by §§ 151.530, 155.310. and 155.320
of this chapter as appropriate is in place;
(k) Each scupper or drain in a dis-
charge containment system is closed;
(1) The communications required by
5 154.560 of this chapter are operable for
the transfer operation;
(m) The emergency means, of shut-
down required by §§ 154.550 and 155.780
of this chapter, as appropriate, is in
position and operable;
(n) Enough personnel are on duty to
conduct the transfer operations in ac-
cordance with the facility operations
manual and vessel oil transfer proce-
dures that apply to the transfer opera-
tion;
(0)	At least one person is present who
fluently speaks the language spoken by
each person in charge;
(p) The person m charge of the trans-
ferring vessel or facility and the perron
in charge of the receiving vessel or facil-
ity have held a conference to assure that
each person in charge understands all
aspects of the transfer operations, in-
cluding at least—-
(1)	The identity of the product to be
transferred; ¦ -
(2)	The sequence of transfer opera-
tions;
(3)	The transfer rate;
(4)	The name or title and location of
each person participating in the transfer
operation;
(5)	Particulars of the transferring and
receiving systems;
(6)	Critical stages of the transfer
operation;
(7)	Federal, State and local rules that
apply to the transfer of oil;
(8)	Emergency procedures;
(9)	Discharge containment proce-
dures;
(10)	Discharge reporting procedures;
(11)	Watch or shift arrangements;
and
(12)	Transfer shutdown procedures,
(q) The person in charge of the trans-
ferring vessel or facility and the person
in charge of the receiving vessel or fa-
cility ¦ agree to - begin the transfer
operation;
(r) Each person in charge required by
this part is present;"
(s) Between sunset and sunrise the
lighting required by § 154.570 and § 155.-
790 of this chapter is provided; and
(t) For transfer operations on a barge
between sunset and sunrise, lighting of
the intensity specified in § 155,790 of this
chapter is provided.
§ ] 56.130 Connections.
(a) Each person who maKes a connec-
tion for oil transfer operations shall—
(1)	Use suitable material in joints and
couplings to make a tight seal;
(2)	Use at least four bolts and a bolt
in at least every other hole of each tem-
porary connection utUizing an ANSI
standard flange coupling;
(3)	Use a bolt in each hole of couplings
other than a ANSI standard flange;
(4)	Use a bolt in each hole of each
fixed coupling; and
(5) Use bolts of the same size in each
bolted coupling; and
(G) Tighten each bolt and nut uni-
formly to distribute the load.
(b)	No person who makes v connec-
tion for oil transfer operations may use
any bolt that shows signs of st'.ain or is
elongated or deteriorated.
(c)	Unless otherwise authorized by the
Commandant, no pei«;on who makes a
connection lor oil transfer operations
may use a quick-comiect coupling or any
coupling that is not bolted or full
tlii'eaded.
§ 156.150 LVcl.imlion nf institution.
(a)	No person may transfer oil to or
from a vessel unless the persons desig-
nated under §§ 154.710 and 155.700 of
this chapter as person in charge of the
trpaisfening facility or vessel ana the re-
cernng facility or vessel have signed the
declaration oi inspection form prescribed
in paragraph (c) of this section.
(b)	No person in charge may .sign a
declaration of inspection of a vessel or
facility unless he has determined by in-
spection that the facility or vessel meets
the recjuirmcnts in ? 150.120.
(c)	The declaration of inspection le-
quired to be signed in paragraph (a) of
this section may be in any form but must
contain at least—
(1)	The name or other identification
of the transferring vessel or facility and
the receiving vessel or facility;
(2)	The address of the facility or loca-
tion of the transfer operation if not at a
facility;
(3)	The date the transfer operation is
started:
(4)	A l.st of the reouirements in
^ 15G.120 with spaces on the form follow-
ing each requirement for the persons in
charge to indicate whether the require-
ment is met for the transfer operation;
and
(5)	A space for the date, time of sign-
ing, signature, and title of each ]>erson in
charge during oil transfer operations on
the transferring vessel or facility and a
space for the date, time of signing, signa-
ture, and title of each person m charge
during the oil transfer operations on the
rcceh ine facility or vessel.
(d)	The form for the declaration of
inspection required in paragraph (a) of
. this section may incorporate the declara-
tion requirements in 4G CFR 35.35-30.
(e)	The opera'-or of each vessel and
each facility shall retain at least one
signed copy of each declaration of in-
spection required for that vessel or
facility' for at least 2 months from the
date it is signed.
§ 156.760 Supervision liy p^r-on in
clmrgc.
fa)	No person may connect, top olf,
disconnect, or engage in any other criti-
cal oil transfer operation unless the
person in charge designated under
?§ 154.710 and 155.700 of this chapter
personally supervises the operation.
fb)	No person may start the flow of
oil to or from a vessel unless instructed
to do so by the person in charge.
(c) No person may transfer oil to or
from a vessel unless the person in charge
is iimmediate vicinity of the trans-
fer operation and immediately available
to the crew.
 No person may transfer oil lo or
from a vessel—
(1)	While any transfer component is
releasing oil at a rate that will exceed
the capacity of the containment system;
or
(2)	While then, i.s oil in the water
near any transiei component Jrom an
unknown source;
§1?6.]70 iZt;i!i|>in<'iil tc-ts am: iiiMicf-
tioris.
(a)	No person may use any item of
equipment listed in paragraph (c) of this
section in oil transfer operations unless,
since the beginning of the 11th calendar
month before the month in which it is
used, the operator of the vessel or facility-
has tested and inspected it in accordance
with paragraphs (b) ana (c) of this sec-
tion and found that it is ui the condition
specified in paragraph (c) of this section.
(d)	Durins anf; test or inspection re.-
quiied by this section, a hose must be in
a straight and horizontal position and
the entire external surface must bo
accessible.
(e)	For the purposes of paragraph (a)
of this section—
(1) Each nonmetalhc oil transfer
hose, other than submarine hose, that is
larger than 3 inches in diameter must—
(1)	Have no loose covers, kinks, bulges,
gouges, cuts, slashes, or soft spots;
(ii)	Have no external and, to the ex-
tant internal inspection is possible with
both ends of the ho.^e open, no internal
deterioration; and
(iii)	Not burst, bulf!C, leak, or abnov •
mally distort under static liquid pres-
sure at least as great as the pressure of
the relief valve setting (or maximum
pump pressure when no relief valve is
instilled) plus any static head pressure
of the system in which the hose i.s used;
(2)	Each transfer system rebel valve
must open at tne pressure at which it is
set to open;
(3)	Each pressure gauge must show
pressure within 10 percent of the actual
piessure;
(4)	Each loading arm and each oil
transfer piping' system including each
metallic hose must mil leak under static
liquid pressure at least as great as the
pressure of the relief valve setting (or
maximum pump pressure when no relief
val\e is installed) plus any static head
pressure in the system; and
(5)	Each item of remote operating or
indicating equipment such as p. remotely
operated valve, tanls level alarm, or
'emergency shutdown device must per-
form its intended function.
(d) No person may use any hose in
underwater service for oil transfer oper-
ations unless, since the beginning of the
23d month before the month in which
it is ii--.ea, the operator of the ve'-sel or
facility has tested and inspected it in ac-
cordance with paragraph (c)(1) or (4)
of this section, ns applicable.
(b)	By icvismg 5 351.35(10 of Part
151 to read as follows:
§ 151."35 Oil record book.
FEDERAL REGISTER, VOL. 36, NO. 248—FRIDAY, DECEMBER 24, 1971
L10

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21970
PROPOSED RULE MAKING
(h) The Oil Record Book mf .ned
on a vessel when not engaged on a for-
eign voyage shall be submitted during
the- months of January, April, July, and
October with entries for the preceding
3 monxhs to the Commander, 3d Coast
Guard District(m), New York, if the
home port is located on the east or gulf
coast; or to the Commander, Twelfth
Coast Guard District(m), San Fran-
cisco, if the- home port of the vessel is
located on the West Coast.
(Sec. 11(J)(1)(C) or the Water Pollution
Control Act or 1958, added by the Water Qual-
ity Imorovement Act of 1970 (84 Stat. 91):
33 U.S.C. 1161 (J) (1) (C) r E.o. 11548. 3 CFR,
1971 Supp., p. 545; 49 CFR 1.46(m>)
Dated: December 15r 1971. ..
C. R. Bender,
Admiral, Tf.S'. Coast Guard, .
Commandant.
[53 Dcc.71-18641 Piled 12-2»-71; 8:45 ami
[ 46 CFR Parts- 10r 1 2, 31r 7Vr 91, 176,
187, 189]
[CGFH 71—101J
POLLUTION PREVENTION •
Inspection of Vessels and Deck and
Engineer Officers Lieenses-
The Coast Guard has under consider-
ation the amendment of Chapter I of
Title 46, Code- of Federal Regulations to
require additional knowledge by mer-
chant marine officers and seamen of the
effects- of oil pollution and of laws, regu-
lations and procedures to prevent oil
pollution; to require pollution: prevention
equipment for vessel certification; and
also to require increased inspection of
tank barges. This proposal is issued in
conjunction with a proposal for new
Parts 154. 155, and 156 of Title 33, Code
of Federal Regulations governing vessel
and facility oil transfer operations that
is published ort page — of this issue of
the FsDjrsAi. Register.
Interested persons are invited to par-
ticipate in this proposed rule making by
submitting- written data, views, or com-
ments to the Coast Guard (CMC),
Washington, D.C. 20590. Communications
should identify the- notice number
(CGFR 71-161), any specific wording
recommended, reasons for any recom-
mended change, and the name, address,
and organization-, if any, of the com-
mentator.	. ~
The Coast Guard will hold a public
hearing on February 15, 1972, at 9:30
a.m. in Conference Room 2230, Depart-
ment of Transportation Nassif Building,
400 Seventh Street SW., Washington,
DC 20590. Interested persons are invited
to attend the hearing and present oral
or -written statements on this proposal.
All communications received before
February 21, 1972; or at the hearing, will
be fully considered and evaluated before
final action is taken on this proposal.
Copies of all written communications
received will be available for examina-
tion in Room 8234, Department of
Transportation, Nassif Building 400
Seventh Street SW., Washington, DC
both before and after the closing:, date
for the receipt of comments. The »
posal contained in this document may
changed in the light of the comments
received.
During the drafting of the proposed 33
CFR Parts 154, 155, and 156, it became
apparent that to have an effective anti-
pollution program three subjects covered
in Chapter I of Title 46, Code of Federal
Regulations would require revision:
(1)	Merchant marine officers and sea-
men must be required to possess a
greater knowledge than presently re-
quired concerning the law and regula-
tions governing oil pollution and the
methods and equipment to- prevent or
clean up oil pollution;	-
(2)	The equipment required in the
proposed Part 155 must be a prerequisite
for vessels before they are issued a cer-
tificate of inspection; and
(3)	The existing vessel drydocking in-
terval for inland vessels must be short-
ened to- eliminate the - continued oper-
ation of leaky vessels.	. .
The professional knowledge of all
licensed: and certificated seamen would
be required to include oil pollution abate-
ment procedures. All such seamen who
by their rating may be- engaged in oil
transfer operations would be required to
have knowledge of oil transfer operations
equivalent to that of a certificated
tankerman. All officers licensed for ocean
service would have to have- additional
knowledge that includes international
, law and tank cleaning procedures that
do not pollute the oceans.
Requiring the vessel's equipment to
comply with standards for oil pollution
prevention in order to obtain a certificate
of inspection would assure that inspec-
tors and technical personnel examine the
vessel and its plans for compliance with
the regulations.
The proposed 33 CFR 155.305 requires
all inland barges built after January 1,
1973, to be of double-wall construction
to phase out single-skin construction
which, results in pollution. To minimize
the existing single-skin fleet's pollution
contribution from hull leaks, the period
. between drydocking of single-skin vessels
would be reduced to not more than 3
years. This change eliminates the 4-year
and 5-year drydocking interval for cer-
tain. inland vessels and eliminates the
5-year extension, privilege on initial dry-
dockings. The purpose of this shortening
of drydocking- intecvals is to subject
single-skin vessels to examination for
operational damage which may permit
cargo or fuel oil leakage. Double-skinned
vessels in fresh water service may go 6
years between drydocking- if their condi-
tion as determined by an internal inspec-
tion during the third year since docking,
permits.
In consideration of the foregoing, it is
proposed to amend Title 46 of the Code
of Federal Regulations- as follows
 By amending Part 31 as follows:
(1)	By amending § 31.01-l(a) by
striking the period and adding the words
"and 33 CFR Part 155, Subpart B."
(2)'	By revising- the citation of au-
thority following § 31.01-1 to read as
follows;
(R.S. 4418, as amended, 4433, as amended,
4472, tis amended, 4438, 03 amended, sec. 11
(J) (1) (C) and (D> of th& Water Pollution.
Control Act ot 1966, added "by the- Water
Quality Improvement Act of 1970 (84 Stat.
91). National Environmental Policy Act of
1959 (83 Scat. 852); 48 US.C. 392, 411, 170,
481, 33 TT.SC. 1161(J)(1) (C) and (D), 42
U.3.C. 4321. et seq.; E.O. 11548; 3 CFR, 1971
Supp., p. 545; 49 CFR 1.4<3(m))
(3) By revising 3 31.05-l(a) to read
as follows:
§ 31.05—1 Issuance- of certificate of in-
spection—TH/ALL.
(a> When a tank vessel Is found to
comply with law and the regulations in
this subchapter, and applicable- provi-
sions of subchapters, E, F, J, O, and Q of
this chapter and 33 CFR Part 155, Sub-
part B, a certificate of inspection shall
be issued- to- it, or to- its owners by the
Officer In Charge;- Marine Inspection..
*	* J . * " *
.. (4). By adding at citation, of authority
following S31.05-L to. read as follgws:,
(See. 11(J)(1)- (C) and. (D> of the Water
PoUctloa- Control Act- of 1956. added by tiie
Water Quality Improvement Act ot 1&70- (34
Stat. 91), National Environmental Policy
Act or 1969 (83 Stat. 852); 33 TT.S.C. 1161
(J)(l) (C) and (D). 42 US.C. 4321', et seq.;
E.O. 11548; 3 CFR, 1971 Supjr, p_ 545," 49
CFR 1.4S(m)X
(5) By revoking subparagraphs- (4)
and (5) and revising subparagraphs. (2)
and (3), of § 3L10-20(a). to read, as
follows:
§ 31.10-20" Drydocking or hauling out—
TB/ALL. ¦
Ca> * * *
(2) Each tank vessel that operates m
salt water an aggregate of less than 6
months in. any 12-month period since it
was last drydocked or hauled out shall
be drydocked" or hauled out at intervals
not to exceed 35 months, except that any
tank barge that operates in salt water an
aggregate of less than 3 months in each
12-m.on.ch. period since it was last- dry-
docked need, not comply with this sub-
paragraph until after April 3, 1973. Each
tank vessel that, operates in salt water
an aggregate of. more than. 6 months in
any 12-month pericd since it was. last
drydocked. shall be drydocked or hauled
out within 6 months after the end of that
period-
(3> For double-waited tank barges
that- operate- in salt water an aggregate
of less than 1 month in any 12-month
period, the Officer in. Charge of Marine
Inspection may authorize the substitu-
tion of an internal inspection of the
space between the double walls for the
initially required drydocking or hauling
out. and for each alternate drydocking
or hauling out thereafter.
(6> By adding- an authority citation
following § 31.10-20 to read as follows:
(National Environmental Policy Act of 1969
(83 Stat. 852); 42 U.S.C. 4321, et seq.)
(b) By amending Part 71 as follows:
- (1) By amending- § 71.20-15(a) by
inserting the words "pollution prevention
equipment," immediately after the words
"pilot ladders," in the second sentence^
FEDcRAL REGISTER VOL jo, NO. 243—FRIOAY, DECEMBER 24, 197>
LU

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(2)	By revisuig the citation of author-
ity following $ 71.20-15 to read as
follows:
(K S. £472, us amended, sec. 2, 23 Stat. 110, as
amended, sec. 2, '63 Stat. 49G, its amended,
tec. 633, 03 Stat 545, sec. 11 (J) (1) fC) of the
Water Pollution Control Act of 1950, added
by the Water Quality Imp:oveinenc Act of
1970	(84 Stat. 91). National Environmental
Policy Act of 3969 (83 Stat. 852); 46 U.S.C.
170, 2, 14 USC 2, 03.i, 33 U.S.C. 1103 (J) (1)
(C), 4?. U.S.C. 4321,el foq ¦ K O. 1154H, 2 CFit,
1971	Supp., p. 545, 49 CFR 1.4G(:u))
(3)	By adding a new § 71.25-37 with
an authority citation immediately fol-
lowing § 71.25-35 to rend as fo!lov,s:
§ 7 1.2 j—37 Pollution prevention.
At each inspection for certification,
the inspector shall examine the \ essel to
determine .that it meets the vessel de-
sign and equipment requirements lor
pollution'prevention in 33 CrR Pari 155,"
Subpart B.
(Sec. 11(J)(1) (C) and (D) of the Water
Pollution Control Act of 1950, p.dced by the
Wel«r Quality Improvement Act of 3 9VO (84
St'it. 91), National Environmental Policy Act
of 1969 (83 Stat. 852); 33 U.S.C. 1161(j)(l)
(C) and (D), 42 U.S C. 4-321, et seq.; E.O.
11548; 3 CFR, 1971 Supp.. p 545; 4'J CFR
1.4G(m.))
(c) By amending Part. 91 as follows;
(1)	By amending § 91.20-15(a) by in-
serting the words "pollution prevention
equipment," immediately after the words
"pilot ladders," in the second sentence.
(2)	By p.menduig the citation of au-
thority following § 91.20-15 to read as
follows:
(P,S 4472, as amended, pcc. 2, 23 Stat 118,
as amended, sec. 2. t>3 Stat. 4'J6, as txneuded,
sec. 033, 63 Stat 545, sec. 11(J) (1) (C) of the
Water Pollution Control Act of 195C, adaed
bv the Water Quality Improvement Act of
1970	(84 Stat. 01), National Environmental
Policy Act of 1909 (83 Stat. 852); 46 U5.C.
170, 2, 14 U.S C. 2, 633, 33 U..f C 1161 (J)
(1)(C), 42 US.C. 4321, et seq; i; O. 115^8;
3 CFR, 1971 Supp., p. 545; 49 CFR 1.46 (m) )
(3)	By amending § 91.25-10(ai by in-
serting the words "pollution prevention
I'/.iuipmenfc" immediately after the words
"pilot .ladders," in the second sentence.
(4)	By a'dduig a citation of authority
following § 91.2.0-10 to read as follows: -
(Sec. 11 (J) (1) (C) of the Water Pollution
Control Act of 1956 added by the Water
Quality Improvement Act of 1970 (84 Slat.
91), National Environmental Policy Act of
1969 (83 Stat. 852); 33 U.S C. 1161 (J) (1) f C),
42 U.S.C. 4321. et seq ; E.O. 11548; 3 CFK,
1971	Supp., p. 545; 49 CFR 1 4G(m) )
(5)	By adding a new § 91.25-38 with
an authority citation immediately fol-
lowing § 91.25-37 to read as follows'
f; 91.25—38 Pollution jirevenlion.
At each inspection lor certification, the
inspector shall examine the vessel to de-
termine that it meets the \ essel design
and equipment requirements for pollu-
tion prevention in 33 CFR. Part 155, Sub-
part B.
(Sec. ll(J)l) (C) and (D) of the Water Pol-
lution Control Act of 195G, added by the
Water Quality Improvement Act of 1970 (64.
Stat. 91), National Environmental Policy Act
of 1959 (83 Stat. 852); 33 U.S.C. 11G1(.J)(1)
PROPOSED RULE MAKING
m§ and (D), 42 U.S.C. 4321, et seq; EO
^Ws48, 3 CFR, 1971 Supp , p. 545 ; 49 CEft 1.46
(ni))
(d)	By amencLm;; the citation au-
thority for Subchapter T by striking the
words unless otherwise noted" and
adding the words "Additional authority
cited v.ith regulations affected."
(e)	By amending Part 17G as follows:
(1)	By amending § 17G.03-5(c) by ni-
sei ling the vorc; ''pollution prevention
equipment,"' immediately after trie words
•'fire extinguishing equipment," i:i the
¦first sentence.
(2)	By adding a citation ol authority
following § 17G.05-5 to read as follows:
(Sec. llfJ) (l) (C) of the Water Pollution
Control Act of 1956, added by the Water
Quality Improvement Act of 1970 ( 84 Stat.
91), National Environmental Policy Act of
1969 (83 Stat. 852); 33 U.S.C. 1161(J) (1) (C),
42 U.SC. 4 301. et s-.-q ; EO. 1I54S, 8 CFR,
1971 Sup p., p 545; CFK. 1 4G(m) )
(3)	By amending 5 17G.05-10 by in-
serting the words "pollution picvention
equipment," imniecLa te)y after the words
'¦fire extinguishing equipment," and by
adding a new paragraph (b) to read as
follows:
§ I 76.0.1-10 Suh^e9.2rt—oft Pollution proveniiou.
At each inspection for certification, the
inspector shall examine the vessel to de-
termine that it meet1, the vessel design
and equipment leouirements for pollu-
tion prevention in 33 CFR Part 155, Sub-
part B.
(Sec. 11(.!)(1) (C) and (]"J) of the Wo.ttr
Po'lution Control Act of 195G, Added by the
Water Quality lnipro\ement Act of 2970 (84
Stat. 91), National Environmental Policy
Act of 1S69 (83 Stat. 852); 33 U.S.C. 1161 (J)
(1) (C) and (D), 42 U S.C. 4321, et seq ; E O.
11548; 3 CPI?. 1971 Supp., p. 545, 49 CFR
1 46(m) )
(h) By amending Parts JO, 12,105, and
187 Title 40 as follows:
(1) By adding the following sentence
as subparagraph (2) ot g 10.02--9(a); sub-
paragraph (2) ol J 10.20-9(a); and para-
graph (e) of § 187.15-1: "Upon the first
renewal of a license after June 30, 1972,
each applicant must meet, the knowledge
requirements for sn original license on
pollution abatement."
- (2) By amending the authority cita-
tions following §§ 10.02-9 and 10/20-9 by
adding an additional citation and by add-
ing a. new authority citation to follow
5 187.15-1 to read as follows:
(National Environmental Policy Act of ISS'J
(83 Stat 652); 42 U.SC 4321, et ieq )
(3)	By adding the new subject "Pol-
lution abatement" as subject number
(7-a) m § 10.05-43'u ) ; (28-a) in the
table in § 10.05-45 (b) ; (20-a) in is 10.05-
47(a); (13-a) in § 10.05-49(a); (9-a) in
§ 10.05-51 (a) ; (10-a) in § 10.05-52(a);
(9-a) in § 10.05-58; and by inserting an
X in each column for the new subject
"(23-a) pollution abatement" in the table
in g 10.05-45(b).
(4)	By adding the following authority
citation following §s 10.03-43, 10.0r.-45,
10.05—47, 10.05-49, 10.05-51, 10.05-52, and
10.05-58 to read as foilows:
(National Environmental Policy Act of 1959
(83 Stat. 852); 42 USC. 4321, et seq.)
(5)	By adding the following sentence
to §§ 10.05-53; 10.05-55; 10.05-57; 10.05-
59; as (c-1) of § 12.05-9; as (e) of
§12 10-5; to §12.20-5; as (a) (30) of
§ 105.60-10; (a) (8) of 5 187.20-10; 
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245)72
PROPOSED RULE MAKING
for disposal of sludge and was om
cargo and fueling operations.
(7)	By adding an authority citation to
follow §§ 10.03-53, 10.05-55, 10.05-57,
10.05-59, 12.05-9, 12.10-5, 12.15-9,
12.20-5, 105.60-10, 187.20-10, 187.20-15,
187.20-17, 187.25-20, 187.25-21, and
187.25-25 to lead £us follows:
(National Environmental Policy Act of 1969
(63 Stat. 853); 42 U.S.C. 4321. et seq.)
(8)	By adding the following new sub-
jects to the table in § 10.10-4(b) and by
inserting an X in each column for each
new subject:
Pollution-
73.	Pollution laws and regulations.
79.	Discharge containment and cleani'o.
80.	Disposal of sludge and wast®.
81.	Loading and transfer of bunkers.
82.	Bilge and ballast disposal.
(9)	By adding an authority citation
following § 10.10-4 to read as-followsr
(Natlonal Environmental Policy Act of 1
(83 Stat. 852): 42 U.S.C. 4321, et seq.)
(10)	By adding the subject "pollution
abatement" as new paragraphs (b) (2)
(viii); (c) (8); and (e) (7) of § 10.15-31.
(11)	By adding an authority citation
following § 10.15-31 to read as follows:
(National Environmental Policy Act of 1069
(83 Stat. 852); 42 U.S.C. 4321, et seq.)
(12)	By adding the following new sub-
division (vii) to 5 10.20-5(b) (1):
§ 10.20-5 Professional examination*.
m	*	m .	•	0
(b> -
(1) * * *
(vii> Pollution laws- and regulations,
procedures for discharge containment
and cleanup-, and methods foe disposal of
sludge and. waste" material from cargo
and fueling operations.
(13) By adding-an authority citation
following 5 10.20-5 to read as follows:
(National Environmental Policy Act of 1969
(33 Stat. 852); 42 U.S.C. 4321, et seq.)
These amendments are proposed under
the authority- of (R.S. 4405, as amended,
R-.S. 4462, as amended, section 11(J)(1)
(C) and CD) of the Water Pollution Con-
trol Act of 1955, added by the Water
Quality Improvement Act of 1970 (84
Stat. 91), National Environmental Policy
Act of 1969 (83 Stat. 852), sec. 6(b)(1),
80 Srat. 937; 46 U.S.C. 375, 416, 33 U.S.C.
H61(J) (1) (C> and (D), 42 U.S.C. 4321,
et seq., 49 U.S.C. 1655(b) (l>,-E.O. 11548:
3 CFR,. 1971 Supp.„ p. 545; 49 CFR (b)
and (m)).
Dated:. December 15, 1971.
C. R. Bender;
Admiral, U.S. Coast Guard,
Commandant.
[FR Doc.71—18642 Filed 12-23-71:8:45 am;
FEDERAL REGISTER, VOL 36, NO. 248—FSIDAY, DECEMBER 24, 1971
L13

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APPENDIX M
PERTINENT CORRESPONDENCE

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metropolitan Washington
COUNCIL OF GOVERNMENTS
1225 Connecticut Avenue, N.W., Washington, D. C. 20036 223-680O
June 12, 1970
4r. Norman E. Jackson, Principal Engineer
Director of Sanitary Engineering
'residential Building
118 12th. Street, N.W.
Washington, D. C. 20004
)ear Mr. Jackson:
It is a pleasure to inform you of the favorable action by
;he Metropolitan Washington Council of Governments on your
ipplication for Federal funds referenced below.
The Council determined that this project is consistent
;ith the metropolitan planning process and the Council of
iovernments1 adopted policies. Six copies of the review
comments on this project are enclosed.
The endorsement of these comments constitutes the formal
letropolitan clearinghouse review required under Section 204 of
:he Demonstration Cities and Metropolitan Development Act of 1966
ind Section 201 and Title IV of the Intergovernmental Cooperation
^ct of 1968.
It has been a pleasure to be o^ assistance to you in the
levelopment of this project. The completion of the project will
contribute to the sound and orderly development of the metro-
>olitan Washington region.
Sincerely yours,
.../ill). \f-f.

Walter A. Scheiber
Executive Director
LE:
'¦c:
COG No. 70-DC-W/S-l (Project No. WPC-DC-22)
Construction of additional primary treatment facilities
COG NO. 70-DC-W/S-2 (Project No. WPC-DC-23)
Construction of new Sludge processing facilities.
COG No. 70-DC-W/S-3 (Project No. WPC-DC-24)
Construction of additional secondary treatment facilities 9 3
RrnrivEC
Hon. Walter E. Washington, Mayor
District of Columbia
Mr. Comer S. Coppie, Budget Officer
District of Columbia Government
Ml
RECEIVED
! V'lOA
JUN
iqm
WATER QUALITY CONTROL
DIVISION
:stiici.of_f!ohimhia_
_ Af linDrnn_f rmnrv_
_Fairfav_f*/itinrv_
_I/Mi/lAnn.rAiinr\>_
	Xfnn rsAmnrv.^ni m r<
«	Pr.'nrA-Wi'll.'ifM-fT.'Mifw-

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COMMENTS AMD RECOMMENDATIONS
OF
STATE, REGIONAL OR METROPOLITAN CLEARINGHOUSES
Date: June 16» 1970
Clearinghouse or planning agency:
	By	 —&	DEPT. OF SANITARY [N'fTR
Name: Metropolitan Washington Council of GovernmenfcfeE! Q H. ! V I7:. O
Address: 1225 Connecticut Avenue, N.W.	I'lhl "j $ IC'?':
Washington, D.C.	/
Source of Authority for Establishment of Agency	PROGRAM PLANNING
^ t	& REVIEW
Bureau of the Budget Circular No.	A-95
An application is to be made under 33 USC 466 et seq. to the Federal
Water Pollution- Control Administration^ Department of the Interior.
The estimated date the application will be filed: 	June 29. 1970
Applicant's Name: Government of the District of Columbia
Address: District Building, 14th & E Streets, N.W., Washington, D.C. 20004
Geographic Location of Pro.ject: 5000 Overlook Avenue, S.W.
Washington, D.C.
Pro.iect Description: Construction of additional primary treatment facilities
at the District's Water Pollution Control Plant. Included are grit removal
facilities, preliminary sedimentation tanks, chlorine contact tank, and mis-
cellaneous connecting conduits.
Clearinghouse Certification:
The project described above does (X) does not ( ) conform with the
comprehensive plan developed or in process of development for the
metropolitan area in which it is located.
Comments and Recommendations:
Please see attached letter dated June 12,	1970 and Metropolitan
Clearinghouse Review Comments.
received	.-vynViVED
JUN 1*197(1 (Signature)	~T
"'w	Authorized Representative of Clearin'ghoiiye
WATER QUALITY CONTROL	\
DIVISION m2	"

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COMMENTS AND RECOMMENDATIONS
OF
STATE, REGIONAL OR METROPOLITAN CLEARINGHOUSES
Date: June 16, 1970
Clearinghouse or planning agency:
Name: Metropolitan Washington Council of Governments
Address: ^225 Connecticut Avenue, N.W.
Washington, D.C.
Source of Authority for Establishment of Ager.cy
Bureau of the Budget Circular No. A-95
•
An application is to be made under 33 USC 466 et seq. to the Federal
Water Pollution Control Administration, Department of the Interior.
The estimated date the application will be filed: June 29, 1970	#
Applicant's Name: Government of the District of Columbia
Address: District Building, 14th & E Streets, N.W. Washington, D.C. 20004
Geographic Location of Project: 5000 Overlook Avenue, S.W.
Washington, D.C.
Project Description: Construction of additional secondary treatment facilities
of the District's Water Pollution Control Plant. Included are six aeration
tanks, fifteen secondary sedimentation tanks, expansion of existing blower
facility, additional blower facility, modifications to existing sedimentation
tanks, and miscellaneous connecting conduits.
Clearinghouse Certification:
The project described above does (x) does not ( ) conform with the
comprehensive plan developed or in process of development for the
metropolitan area in which it is located.
Comments and Recommendations:
Please see attached letter dated June 12, 1970 and Metropolitan
Clearinghouse "Review Comments.
RECEIVED	,
im	-vx c-r «.f*ecF.r'cD
JUW 1 9 W	(Signature)	~
ATER QUALITY C0NTR01	Authorized Representative of dikarirfghotSe
DIVISION
M3

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COMMENTS AMD RECOMMENDATIONS
OF
STATE, REGIONAL OR METROPOLITAN CLEARINGHOUSES
Date: June 16, 1970
Clearinghouse or planning agency:
Name: Metropolitan Washington Council of Governments
Address: 1225 Connecticut Avenue, N.W.
Washington, D.C.
Source of Authority for Establishment of Agency
Bureau of the Budget Circular No. A-95
An application is to be made under 33 USC 466 et seq. to the Federal
Water Pollution Control Administration, Department of the Interior.
The estimated date the application will be filed: June 29, 1970	.
Applicant's Name: Government of the District of Columbia
Address: District Building, 14th & E Streets, N.W. , Washington, D.C. 20004
Geographic Location of Project: 5000 Overlook Avenue, S.W.
Washington, D. C.
Project Description: Construction of new Sludge Processing Facilities to
replace existing facilities at the District s Water Pollution Control Plant.
Included are eight fltation thickening tanks, four sludge blending tanks,
twenty vacuum filters, six multiple hearth furnaces, and necessary and re-
quired structure to house same.
Clearinghouse Certification:
The project described above does ( ) does not ( ) conform with the
comprehensive plan developed or in process of development for the
metropolitan area in which it is located.
Comments and Recommendations:
Please see attached letter dated June 12, 1970 and Metropolitan
Clearinghouse Review Comments.

*	^ r- 1 \ /
RECEIVED	" ' 	p' r
(Signature)
JUN 1® 1970	Authorized Representative of Cleaj^)"g^i^u^^-7Q
'	M4
WATER QUALITY CONTROL	[ W Q /\
DIVISION

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Metropolitan Clearinghouse Review Comments
COG PROJECT NUMBERS AND NAMES:
70-DC-W/S-l Construction—Additional
Primary Treatment
Facilities (WPC-DC-22)
70-DC-W/S-2 Construction—New Sludge
Processing Facilities
(WPC-DC-23)
70-DC-W/S-3 Construction—Aditional
Secondary Treatment
Facilities (WPC-DC-24)
APPLICANT: Government of the District of Columbia
FEDERAL AGENCY; U. S. Department of the Interior, Federal Water
Quality Administration.
FEDERAL PROGRAM AND AUTHORIZATION: Water Pollution Control—
Waste Treatment Works Construction
Federal Water Pollution Control
Act, as amended.
PROJECT DESCRIPTION:
The District of Columbia is seeking assistance from the
Federal Water Quality Administration for expansion of its
Water Pollution Control Plant {Blue Plains.) The total cost of
the proposed projects under review for the initial phase of the
expansion is estimated at$90,673,084, of which $49,870,196
is sought in grant funds from FWQA and the remainder, $40,802,888
would be supplied by the applicant.
The initial phase of the proposed expansion involves three
Projects. The first of these projects (WPC-DC-22) is for the
construction of additional primary treatment facilities, including
grit removal facilities, preliminary sedimentation tanks, and a
chlorine contact tank. The total cost of these facilities is
estimated at $17,265,000 of which $9,495,750 is sought as a
grant and $7,769,250 would be provided in"local funds.
The second of these projects (WPC-DC-23) is for the construc-
tion of additional sludge processing facilities, including eight
flotation thickening tanks, four sludge blending tanks, twenty
vacuum filters, and six multiple hearth furnaces. The total
cost of this project is estimated at $27,327,000, of which
$15,029,850 is sought as a grant and the remainder, $12,297,150
would be supplied in local funds for which the District of
Columbia has requested loan authority from the Congress.
The third project (WPC-DC-24) is for the construction of
additional secondary treatment facilities including six aeration
tanks, fifteen secondary sedimentation tanks, expansion of the
RECEIVED
JUN lq 1970
WATER QUALITY CONTROL

-------
existing blower facility, an additional blower facility, and
modifications to the existing sedimentation tanks. The total
estimated cost of these facilities is $46, 081, 084 of which
$25,344,596 is requested as a grant and $20,736,488 would be
contributed in local funds for which loan authority has been
requested from the Congress.
The three projects are designed to provide grit removal,
primary sedimentation capacity, sludge processing capacity,
incineration of dewatered sludge, aeration, and secondary
sedimentation capacity for the 1980 design rate of 309 million
gallons per day for a service population of 2,227,000. All of the
proposed facilities are designed to be accommodated on the
present site of the Plant.
The present (average daily) design capacity at Blue Plains
is 240 million gallons per day (fftEfd). A recent Federal Water
Quality Administration report indicates that the total current
average f low ^t the plant is about 249 mgd. At present, the
hydraulic load on the plant from the District of Columbia is
about 124 mgd, from Maryland is about 114 mgd, and from Virginia
is about 11 mgd. The report indicates that as a consequence of
earlier agreements, the Washington Suburban Sanitary Commission
has "purchased" about 45 mgd of treatment plant capacity, and
by virtue of agreements associated with the Potomac Interceptor,
has acquired rights to 22 mgd. However, the June 2, 1970,
memorandum of the Sewer Task Force of Montgomery County points out
that no authority has been granted to either the enforcement
conference of the Secretary of the Interior to make any deter-
mination as to the degree of the respective parties' rights in
the facility. The Sewer Task Force Report further states that
the vested capacity rights under agreements between the District
of Columbia and the WSSC appear to be far in excess of 67 mgd.
The WSSC believes that it has reserved under the agreements,
peak flows of 267 mgd which would require a treatment capacity
of approximately 135 mgd. On the assumption that the District
of Columbia can, in the foreseeable future, need up to 170 mgd
daily average (by the year 2000), based upon the Metcalf and
Eddy report prepared for the District of Columbia Department of
Sanitary Engineering as modified by more recent population
projections for the District of Columbia by Hammer, Greene, Siler,
Associates, a design demand (average daily) for 295 mgd
(170 + 114 + 11) is already seen to exist, if present contributions
from Maryland and Virginia are neither expanded to nor diverted
from Blue Plains. Reliable estimates suggest that, even by taking
special measures, discussed below, the site cannot accommodate more
than 419 mgd of total hydraulic capacity. The facilities
currently under review would expand biological (secondary)
treatment capacity to 309 mgd; a second phase of design would
expand the total biological capacity to the full 419 mgd. The
Metcalf and Eddy report indicates that an advanced waste treatment
capacity of 419 mgd cannot be accommodated on the present site
unless an additional 50-55 acres of land is made available through
filling portions of the Potomac Estuary or by "double-decking" '
the plant. Either alternative would incur substantially greater
M6

-------
dollar cpst than construction on existing land; the first alter-
native has also been criticized as being possibly, undesirable
from an ecological viewpoint.
At the Blue Plains site, however, biological treatment
capacity to remove BOD (biochemical oxygen demand) by itself is
insufficient to protect the Potomac Estuary from degradation
resulting from BOD loadings beyond those agreed to at the April-
May 1969 sessions of the Enforcement Conference. The present
plant was designed to remove 80% of the applied BOD as a result
of the recommendations of the 1957 Potomac Enforcement Conference
sessions, but is providing, at present, about 70% removal. In
accordance with the recommendations of the 1969 session of the
Enforcement Conference, the District of Columbia will be required
to limit its discharge of BOD, phosphorus, and nitrogen to the
Estuary to 12,700 pounds per day, 560 pounds per day (as P), and
6,130 pounds per day (as N), respectively, effectively requiring
removal rates of 96%, 96%, and 85% respectively based on present
flows. Recommendations of the continuing Potomac Enforcement
Conference also call for continuous and effective disinfection
(to reduce bacterial pollution) and for the removal of nitrogen
and phosphorus to attempt to eliminate algae blooms and mitigate
secondary oxygen depression due to the death and decay of those
organisms. The Recommendations also established a detailed
schedule for providing facilities to achieve the specified
removal requirements.
Since the May, 1969 session of the Enforcement Conference,
disinfection has been begun at all plants on the estuary, and the
Federal Water Quality Administration (FWQA) has reported signi-
ficant reductions of bacterial contamination. Meeting the removal
requirements for biochemical oxygen demand (measured for conven-
ience after five days (BOD5) ), nitrogen, and phosphorus, is not
easily accompolished, and requires the coordinated use of con-
ventional secondary biological treatment facilities, such as the
ones currently under review, along with advanced waste treatment
facilities (AWT) which are designed specifically for nitrogen
and phosphorus removal but which also have the capability of
removing additional BOD5.
At the Potomac Enforcement Conference, it was agreed to limit
the discharge of BOD5 to the Potomac Estuary from Blue Plains to
12,700 pounds per day. At present flows and loading rates.
Blue Plains is discharging aboiut 94,000 pounds per day of BOD5 to
the estuary. At design flow (309 mgd) and a 90% removal rate, the
facilities under design will permit the BOD^ discharged to be
reduced to 49,000 pounds per day. Complete conformance to the load
limitation of 12,700 pounds per day can be achieved upon completion
of the full complement of facilities. At that time, the entire
facility, operating at a removal rate of 97.4% on a total flow
of 309 mgd or 98.2% on 419 mgd, will cause a discharge of 12,700
pounds per day to the estuary. The former is well below, and the
latter is well within, the range of treatment levels required at a
plant which the FWQA proposes be constructed on the Anacostia ,
River to relieve the loads at Blue Plains. The point should be
stressed that at levels of treatment in this range, wastewater
M7

-------
ceases to be a, liability to the receiving water, and in fact,
enhances its quality.
RELATIONSHIP TO METROPOLITAN PLANNING PROCESS AND THE
ACHIEVEMENT OF AREAWIDE GOALS AND OBJECTIVEST
The projects described above have been submitted to COG
in accordance with established Regional Review Procedures.
Following an initial staff review of the projects, a pre-appli-
cation conference was held at COG on May 11, 1970. A summary of
that conference is attached to these review comments.
The projects are consistent with the Ten-Year Water and
Sewerage Plans and Six-Year Programs for Montgomery and Prince
George's Counties adopted by the WSSC, the M-NCPPC, and the
Montgomery County Council and Prince George's County Board of
Commissioners, respectively. They are also consistent with the
recommendations of the Report on Sanitary Sewers and Waste Water
Disposal in the Washington Metropolitan Region adopted by COG in
1965 and Water and Sewerage Facilities Planning and Programming in
the Washington Metropolitan Area approved by COG's Board of
Directors on October 9, 1969.
The COG studies were based on population projections of
about 5 million persons by the Year 2000. Since that time an
economic base study sponsored by COG has suggested a much more
rapid rate of growth. A special task force of COG members is
currently assisting the impace of these projections; including
their impact on planning for water and sewerage facilities.
The Blue Plains Water Pollution Control Plant, which
treats approximately 80% of all municipal wastes in metropolitan
Washington, plays a vital role in the protection of the Potomac
River in the Washington metropolitan area. It treats wastes which
drain naturally to its site from the District of Columbia (D.C.),
and by virtue of agreements between D.C. and the Washington
Suburban Sanitary Commission (WSSC), it treats wastes conveyed by
interceptors through the Rock Creek and Anacostia valleys. This
relieves those valleys from the need to carry treated effluent
through District of Columbia parkland. Moreover, in 1961, in
order to protect water supply intakes at Great Falls and Little
Falls, Congress authorized the construction of the Potomac
Interceptor to convey sewage to Blue Plains for treatment from
Dulles Airport and adjacent fprritory in Virginia and Maryland.
In 1961, the "no effluent policy", which discouraged the discharge
of wastewaters to the Potomac ant5 its tributaries between the
Monocacy River and Little Falls, was adopted by the Regional
Sanitary Advisory Board. That policy was amplified without change
in concept in recognition of emerging waste treatment technology
and the Federal requirements for adoption and enforcement of
stream standards by the states in 1969. At the present time,
studies by the Corps of Engineers and the Federal Water Quality
Administration, and legislation pending in the Senate?of the
United States, suggest that the Potomac estuary itself ma]p P^eome
a source of municipal water supply for the metropolitan regidn.
riu

-------
Protection of the estua,;r^y, especially as a possible wa,ter
resource, must be the pri.ma.ry objective of all persons and
agencies concerned with wates1 pollution control in the Washington
metropolitan area. To that end, the facilities-under review
represent critical components of a total system, and are desperately
needed. Recommendations of the Enforcement Conference, in fact,
call for their completion by 1975-1977. In order to protect the
Potomac River, especially as a water supply source, preference for
the restricted capacity available at the Blue Plains site must
be given to jurisdictions draining naturally to the estuary and to
those entitled to such capacity under agreements associated with
the Potomac Interceptor. Whenever possible, capacity should also
be made available for other flows which would otherwise need
to be discharged to the Potomac river above water supply intakes.
For the time when flows to Blue Plains will exceed the presently
known limit of 419 mgd, all jurisdictions will need to consider •
the benefits to be achieved from the use of alternate locations
for the treatment and discharge of sewage.
The need to protect the region's primary water supply, the
feasibility of alternate treatment systems, the region's rapid
growth rate, and the impact of the region's water and sewerage
facilities system on its ability to maintain a desirable quality
and quantity of growth are the main reasons why it is imperative
that immediate consideration be given to alternative future
roles for the Blue Plains facility and alternative systems of
collecting and treating the region's liquid wastes.
The revision of COG's Water and Sewerage Facility Plan and
Program, now in progress, must include these considerations.
The agencies and jurisdictions affected must also consider such
alternatives.
It should be noted that the Montgomery County Planning Board
has historically supported efforts to improve the quality of the
region's water resources through pollution abatement. Conse-
quently, it endorses the proposed improvements to the Blue Plains
facility, but feels that such expansion should include adequate
provision for tertiary treatment even if the requested 51 acres of
landfill are not secured.
STAFF RECOMMENDATION;
The staff recommends that its comments be endorsed by the
Health and Environmental Protection Policy Committee and the Land
Use Policy Committee.
M9

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PPLI. ANTS' STATEMENT
ON
PLANNING ACr:.: -V: REVIEW
APPLir VI I; 3 FOR „0 i.RU TI< M GRANTS
UNDER 3 USC '<66 et seq.
DATE: June 18, 1970
APPLICANT: Government of the District of Columbia
ADDRESS:	District Building, 14th & E Streets, N.W., Washington, D.C. 20004
PROJECT DESCRIPTION: c instruction of additional primary treatment facilities
at the District's Water Pollution Control Plant. Included are grit removal
facilities, preliminary sedimentation tanks, chlorine contact tank, and mis-
cellaneous connecting conduits.
STATEMENT (Check Applicable):
X 1. Application is accompanied by comments and recommendations of
planning agency which have been considered prior to su bmission.
If the pro ect described above does n ;t coiiform with the
comprehensive plan developed or in process of development for
the metropolitan area in which it is located pro ide explana-
tion on attached sheet.
X 2. Applicant wishes to be considered for a 10 percent increase in
grant pursuant to Section 8(f) of the Federal Water Pollution
Control Act.
3. Application is not accompanied by comments and recommendations
of planning agency, because:
	 (a) no agency has been designated to perform metropolitan or
regional planning for the area in which the project is
located, or
(b) the application has lain before an appropriate planning
agency for a period of sixty days without comment or
recommendations.
RECEIVED
m^w
WATER QUALITY CONTROL
DIVISION
Sjaaifofe)
Authorized Representative of Appli
Mil
JUM23 ID
FWQA

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PPLI. ANTS' STATEMENT
ON
PLANNING AG^CY REVIEW
APPLIf v; I. ;j FOR COi::-Vi.RU:.TI-GRANTS
UNDER 3. USC i:66 et seq.
BATE: June 18, 1970
PPLICANT: Government of the District of Columbia	
DDRESS:	District Building. 14th & E Streets. N.W., Washinetion, D.C. 20004
'ROJECT DESCRIPTION: Construction of additional secondary treatment facilities
>f the District's Water Pollution Control Plant. Included are six aeration
:anks, fifteen secondary sedimentation tanks, expansion of existing blower
lacility, additional blower facility, modifications to existing sedimentation
ITATEMENT (Check Applicable): tanks, and miscellaneous connecting conduits.
^	1. Application is accompanied by comments and recommendations of
planning a;;ency which have been considered prior to bmission.
If tlie pro ect described above noes n ;t conform with t'-.ie
comprehensive plan de.eloped or in process of development for
the metropolitan area in which it is located pro ide expl- na-
tion on attached sheet.
X 2. Applicant wishes to be considered for a 10 percent increase in
grant pursuant to Section 8(f) of the federal Water Pollution
Control Act.
	3. Application is net accompanied by comments and recommendations
of planning agency, because:
	 (a) no agency has been designated to perform metropolitan or
regional planning for the area in which the project is
located, or
	 (b) the application has lain before an appropriate planning
agency for a period of sixty days without comment or
recommendations.
RECEIVED	U )—-
(SWh^re) RTCEIVE
JUN lA 1970	Authorized Representative of Applicant
*	JII.V n r, 1Cf-,
WATER QUALITY CONTROL
DIVISION	m12	| vv;-A

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PPLI. ANTS' STATEMENT
ON
PLANNING AGI^:C7 REVIEW
APPLir i. 5 for coi::viru;..ti< ;o grants
UNDER 3 use i;66 et seq.
BATE: June 18, 1970
APPLICANT: Government of the District of Columbia	
ADDRESS:	District Building. 14th & E Streets. N.W.r Washington. D.C. 20004
PROJECT DESCRIPTION: Construction of new Sludge Processing Facilities to
replace existing facilities at the District's Water Pollution Control Plant.
Included are eight flotation thickening tanks, four sludge blending tanks,
twenty vacuum filters, six multiple hearth furnaces, and necessary and re-
STATEMENT (Check Applicable): quired structure to house same.
X 1. Application is accompanied by comments and recommendations of
planning a-.ency which have been considered prier to bmission.
If the pro ect described above ooes n ;t conform with the
comprehensive plan ae'eloped cr in process of development for
the netropolitan area in which it is located pro ide explana-
tion on attached sheet.
X_2. Applicant -wishes to be considered for a 10 percent increase in
grant pursuant to Section 8(f) of the Federal Water Pollution
Control Act.
3. Application is net accompanied by comments and recommendations
of planning agency, because:
(a)	no agency has been designated to perform metropolitan or
regional planning for the area in which the project is
located, or
(b)	the application has lain before an appropriate planning
agency for a period of sixty days without comment or
recommendations.
received
JUN 141970
WATER QUALITY CONTKOL
DIVISION
Authorized Representative of Applicar
JM! 21 :~7o
Ml 3
P ' ¦ »
'>. A

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APPLICANTS1 STATEMENT
ON
PLANNING AGENCY REVIEW
APPLICATIONS FOR CONSTRUCTION GRANTS
UNDER 33 USC k66 et seq.
APPLICANT: Washington Suburban. Sanitary Commission
ADDRESS; 4017 Hamilton Street, llyattsville, Maryland 20781
PROJECT DESCRIPTION: Expansion of District of Columbia's Water Pollution
Control Plant at Blue Plains
STATEMENT (Check Applicable):
* 1. Application is accompanied by comments and recommendations of
planning agency which have been considered prior to submission
If the project described above does not conform with the
comprehensive plan developed or in process of development for
the metropolitan area in which It Is located provide explana-
tion on attached sheet*
x 2. Applicant wishes to be considered for a 10 percent Increase in
grant pursuant to Section 8 (f) of the Federal Water Pollution
Control Act.
	3. Application Is not accompanied by comments and recommendations
of planning agency, because:
		 (a) no agency has been designated to perform metropolitan or
regional planning for the -area in which the project is
located, or
	 (b) the application has lain before an appropriate planning
agency for a period of sixty days without comment or
recommendations.
* Conjraonta and Recommendations by the Metropolitan Washington Council of Covernmenta
forwarded through District of Columbia Covernment.
DATE: October 28, 1970
(Signature)
Authorized Representative of Appl$6aiv$ J ;070
Robert J. McLeod, General'Manager
Chief Englnee
M14

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I).44
Mny 1967
Memorandum O Government of the District of Columbia
"Vt .. i'i
i
1 */
Department,
T0;	Norman E. Jackson, Director ; ' Agency, Office: Executive,Office
Department of Sanitary Engineering	'	Budget & Executive
1/	Management
joft/
FROM: Comer S. CoppieJ^	Date:	WAR 10 1971
Budget Officer, D. C.
SUBJECT: Clearinghouse Review of Project WFC-DC-26
This Office hos concluded its review of your request for a federal
construction grant to modernize and expand the Water Pollution Control Plant
at Blue Plains. The construction of an adequate waste treatment facility is
greatly needed to improve the water quality in and around the District of
Columbia,
This project is in accord with the interests of the District of
Columbia; therefore, we recommend that you proceed with the necessary action
to obtain funding for this project.

W-fl
Ml 5
RECEIVED
MAR 191971
FWQA

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D.C.-44
May *1967
Memorandum
Government of the District of Columbia
TO:
FROM:
i I
Norman E. Jackson, Direct6r J: f
Department of Sanitary Engiy
.A
I I
£
Comer S. Coppie
Budget Officer, D
4%'
Department,
-Agency, Office: Executive Office
ng	Budget & Executive
Management
Date:
MAR11 W*
SUBJECT:
Clearinghouse Review of Project WPC-DC-23
This Office has concluded its review of your proposed project for
the construction of new Sludge Processing Facilities to supplement existing
facilities at the District of Columbia's Water Pollution Control Plant.
As specified in Section tol(a) of the Intergovernmental Cooperatiot
Act of 1968, it is our finding that this project contributes to the achievement
of the objectives of the District of Columbia.
We recommend that you proceed with the necessary action to obtain-
ing funding for this project.
w-a
M16
RECF'>!"0
MAR 231971
r A
I < j >

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D.C.-44
May Ji907
Memorandum # Goyeriimleiit of the District of Columbia
SUBJECT: Clearinghouse Review of Project WPC-DC-2U
This Office has concluded its review of your proposed project
for the construction of additional secondary treatment facilities at the
District's Water Pollution Control Plant.
As specified in Section l+Ol(a) of the Intergovernmental
Cooperation of 1968, it is our finding that this project contributes to
the achievement of the objectives of the District of Columbia.
We recommend that you proceed with the necessary action to
obtain funding for this project.
TO:
FKOM:
Executive Office
Budget & Executive
Management
RECEIVED
W-8
MAR 25 1971
FWOA
M17

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metropolitan Washington
COUNCIL, OF GOVERNMENTS
1225 Connecticut Avenue, N.W./W^sh IngtQn, D. C. 20030 223-6800
— / ¦ . .
" April 27, iril
ill; i
1 < -, t '' f '
L * tit
Mr. Norman E. Jackson, P.E.
Director of Sanitary Engineering
District of Columbia
415 12th Street, N.W.
Washington, D.C. 20004
Dear Mr. Jackson:
We have concluded our review of the Environmental Statement
for the project cited below. Six copies of our comments on the
Environmental Statement are enclosed. These comments were endorsed
by the Health and Environmental Protection Policy Committee at its
April 23, 1971 meeting.
In endorsing the staff comments, the Committee strongly
emphasized the need to proceed with the project with all appropriate
environmental safeguards in view of the adverse economic and
environmental consequences of delay in the expansion and upgrading
of Blue Plains.
Subsequent to the consideration of this project by the Health
and Environmental Protection Policy Committee, the Council of
Governments received your letter dated April 22, 1971, responding
to our earlier comments. We are pleased to note your willingness
to provide environmental safeguards in the pursuit of this project,
and trust that additional environmental controls will be applied
if found necessary.
If we may be of further assistance, please call upon us.
Sincerely yours,
Walter A. Scheiber
Executive Director
RE: COG No. 71-DC-W/S-2
D.C. Water Pollution Control Plan Expansion -
Dredging and Dock Facilities; General Excavation
and Dewatering; Concrete Plant
cc: Hon. Walter E. Washington, Mayor
District of Columbia
Hon. James P. Gleason, County Executive
Montgomery County
Hon. Idamae Garrott, President
Montgomery County Council
Ml 8
Columbt* * Arlington County • Fairfax Courtly • Fj>u
-------
Hon. William W. Gullett, County Executive
Prince George's County
Hon. Winfield M. Kelly, Jr., Chairman
Prince George's County Council
Hon. Achillas M. Tuchtan, Mayor
City of Rockville
Hon. George M. Miller, Mayor
City of Takoma Park
Hon. William R. Reading, Mayor
City of College Park
Hon. Edgar L. Smith, Mayor
City of Greenbelt
Hon. William S. Hoofnagle, Chairman
Fairfax County Board of Supervisors
Hon. Joseph L. Fisher, Chairman
Arlington County Board
Hon. Thomas G. Eastham, Mayor
City of Falls Church
Hon. Donald R. Bowman, Chairman
Northern Virginia Planning District Commission
Mrs. Caroline Freeland, Chairman
Maryland-National Capital Park and Planning Commission
Mr. Charles J. Jeckell, Chairman
Regional Sanitary Advisory Board
Mr. Robert B. Russ, Chairman
Waste Water Committee, RSAB
Ml 9

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METROPOLITAN CLEARINGHOUSE REVIEW COMMENTS
COG PROJECT NUMBER: 71-DC-W/S-2
PROJECT NAME: D.C. Water Pollution Control Plant Expansion -
Dredging and Dock Facilities; General Excavation
and Dewatering; Concrete Plant
APPLICANT: District of Columbia Government
FEDERAL AGENCY: Environmental Protection Agency-Water Quality
Office
FEDERAL PROGRAM AND AUTHORIZATION: Construction Grants for
Wastewater Treatment Works,
Federal Water Pollution Control
Act, as amended.
PROJECT DESCRIPTION;
The District of Columbia Department of Sanitary Engineering
is making application to the Water Quality Office for financial
assistance to support a number of activities that will facilitate
the construction involved in the expansion of the D.C. Water
Pollution Control Plant (Blue Plains). These activities involve
dredging and shoreline adjustments of the Potomac River to
provide access to the Plant site by water. The dredging would
create em entrance channel and turning basin with a uniform depth
of 16 feet below mean low water, which is generally less than two
feet.
Docking facilities# 1200 feet long by 75 feet wide would be
constructed, over the water, adjacent to the turning basin.
During construction, the dock would be used in transporting excava-
ted materials downriver and in receiving raw materials for the
concrete batch plant, thereafter it would be used to transfer
chemicals used in the treatment processes and residue resulting
from the processes.
This project, in addition would support advance preparation
of the construction site, including excavation for all facilities,
sheeting and dewatering, utilities, roads and lighting. The
excavated materials would be used to restore Dyke Marsh. The
project also would allow the construction of a plant for bulk
batch concrete processing adjacent to the proposed docking
facilities. Total project costs are estimated at $46,900,000 of
which the District of Columbia would provide $10,450,035'in cash
and seeks $12,772,265 in grant funds. An additional $22,463,460
would be provided by the Washington Suburban Sanitary Commission
and $1,214,240 by Fairfax County.
M20

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RELATIONSHIP TO THE METROPOLITAN PLANNING PROCESS AND THE
ACHIEVEMENT OF AREAWIDE GOALS AND OBJECTIVES:
The need for expanded and upgraded waste water treatment
facilities at the Blue Plains site is undeniable, and is
supported by the recommendations of the Potomac Enforcement
Conference and by the Memorandum of Understanding prepared by
responsible participants in the Conference. The expansion of
Blue Plains was endorsed by the Council of Governments on June
12, 1970. Maryland-National Capital Park and Planning Commission,
in a letter dated April 6, 1971, has urgently recommended approval
of the project.
The limited space available at the Blue Plains site, along
with the compressed time schedule for completion of the Blue
Plains plant expansion are each factors which can create ad-
verse environmental effects if proper precautions are not taken.
The need to dredge portions of the Estuary, occasioned by
the compressed time schedule and space limitations, could create
environmental inpacts at both the dredging and disposal points.
The river bottom in the vicinity of the Water Pollution Control
Plant is almost certainly covered with a blanket of sludge which
may, in turn, contain pathogenic organisms as well as high
concentrations of nutrient materials and possibly heavy metals
and pesticides, as well as being a source of immediate oxygen
demand, if disturbed. The staff understands that the D.C.
Community Health Services Administration has reviewed this
proposal and concluded that the dredging operations will not
contravene the water quality standards of the District of Columbia.
It would be desirable that more adequate discussion of this
matter be included in the Environmental Impact Statement.
It also appears that a large volume of spoil will be created
in carrying out excavation on the dry land portion of the site.
The plans for disposal of such spoil should be more clearly
addressed in the statement, and the techniques to be used to
prevent erosion and sedimentation of excavated materials and to
meet the sediment control regulations of the District of Columbia
should be specified.
The concrete batching plant necessitated by the unusual
construction requirement at the site could, if not properly
designed, contribute to air pollution. The D.C. Department of
Sanitary Engineering is encouraged to include a discussion of the
steps to be taken to ensure compliance of the batching plant with
all appropriate air pollution control standards.
STAFF RECOMMENDATION:
The staff recommends the endorsement of these comments by the
Health and Environmental Protection Policy Committee.
M21

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L3 L A K T :.i L Y
Or l r» i L i ^ l. A iX rl i k\ G
V. \f\Vi.\
o-YL x \ w i%
^ ^ i \\ r ^ ; o.-; v wse t
*"¦ - i I f'; O f 5 V ;* ' ,' V I,. A D 2 1 2 U ;
1LLl,'';iOMI, "JC I -	£» i
fi'j"' K /• ,'. r1 :
LLf	'_,tf „
July ?, Wi
-ir. S-;_\ity .lervakos
Principal Engineer
"Washington Suburban Sanitary Commission
U017 riamilvor. St,rect
Hyattsville, L.-iryj-and 20761
Dear :£r. Zervakos:
SU3J3CT: P.IOJECT ^JTD'ICaTUN RiVILVj
Applicant: HSSC
Project: Locking Facilities at D. C. Plant
State Clearinghouse Control dumber: hOS
State Clearinghouse Contact: Allen miles (3o3-2ii7l)
The State Clearinghouse has reviewed the above project,. In accordance vith the
procedures established by the Office of Kanagement and Eudget Circular A-9p, the
State Clearinghouse received comments (copies attached) from the following:
Department of Health and Mental hygiene: recommended approval,
noting that this project provides facilities to be used for
the massive construction techniques required to cor.plete plant,
expansion by 197U.
Department of Natural Resources: recommended approval.
As a result of the review, it has been determined that the pror.-osea *^£oject is in
accord with State plans, programs, ana objectives as of this date. v>
You should now complete and file your formal application, A cop;QajF this letter
must be attached to your application. Please notify this State^J^eari^v hous,e of
the filing date r.s soon as the application is submitted by com^etin.^^.d fcrwara
the enclosed, self-addressed card. If you have any questions'^"pleas'^ contact the
State Clearinghouse member named above.
Sincerely,
£.nc.
c c : Jo::er/n /'_n a s ti
'iorara -'JL-Vlin
'//. KcLcan Jsingley
Herbert i;i„ Sachs
Vladimir 'Jahbe
M22

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1	iViAP.YL.A!\D
•- *	iv,i i O .* i r-v t [£ i'J L. A r*: /\ ' i\ Cj
:.oi w^fj"r PiicsTcr-i
m vr.Vi:.	FS -\ L.Ti .vo K C maky;. ..mi 1 j- o "i
¦U oL,\ i_-1.	1
July 7^.1971--=.
' :-Y	' /
Mr. Straty Zervakos
Principal "Engineer	-/.
Washington Suburban Sanitary Commission	^ . •
i;017 Hamilton Street	'	\-'
Hyattsvilie, Ma ly land 20781
\
SUBJECT: PROJECT ivCTIIICATION AnD REVIEW	" ' ' ' - "
Applicant: Washington Suburban Sanitary Commission
Project: Jew Sludge Processing Facility at D. C. Plant
State Clearinghouse Control Number: 1*06
State Clearinghouse Contact: Allen Miles (383-2i;7l/
Dear Mr. Zervakos:
The State Clearinghouse has reviewed the above project. In accordance
"with the procedures established by the Office of Management and Budget
Circular A-95, the State'Clearinghouse received comments (copies attached)
from the following:
Department of Natural Resources: recommended approval.
Department of Health and Mental Hygiene: recommended approval, noting T-hat
this plant expansion is in accordance with the recommendation of the
Potomac Enforcement Conference and that a Federal grant offer of
$7,358,170 was issued on May 20, 1971.
Is a result of the review, it has been determined that the proposed project is in
iccord with State plans, programs, and objectives as of this date.
fou should now complete and file your formal application. A copy of this letxer
nust be attached to your application. Please notify this 3tat,£? Clearinghouse cf
the filing date as soon as the application is submitted by completing and iorwarcir.,
ohe enclosed, self-addressed card. If you have any questions,/-please contact the
State Clearinghouse member named above.
Sincerely,
Vladimir i\rahbe
Herbert M. Sachs
VI. McLean HinfO.oy
inCc
;c: Joseph Anastasi
Gerard Devlin
M23

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J A L i I .s O'.u	Y: . A fv	i O 1
¦July 7, 1971
P~!
Mr. Straty lervakos
Principal Engineer
Washington Suburbs^ Sanitary Commission
L.017 Hamilton Street
Hyatt3vilie, Maryland 20781
SUBJECT: PROJECT NOTIFICATION AND RLVIE/J
Applicant: Washington Suburban Sanitary Commission
Project: Additional Primary Treatment facilities at, D.
State Clearinghouse Control Number: lj.07
State Clearinghouse Contact: Allen Kiles (383-2
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Charles H.Graves
OiMCCTO*
Commonwealth of Virginia
Governor's Office
OFFICE OF ADMINISTRATION
DIVISION OF STATE PLANNING AND COMMUNITY AFFAIRS
IOIO JAMES MADISON' BUILDING
109 GOVERNOR STREET
RICHMOND. VIRGINIA £3219
> '
L0>
JUL
81971/
fwoa
w 1
federal programs section'
TCLCPMOMC (703) 770*4 60 1
MEMORANDUM
Trj,	Federal State Aid Coordinator
4100 Chain Bridqe Road
Fairfax, Virqinia 22030
FROM:	A.-95 Project Review Officer
Division of State Planning and Community Affairs
SUBJECT:	Project Notification and Review
Applicant: County of Fairfax
Project: D.C. Water Pollution Control Plant (Blue Plains)
State Clearinghouse Control Number: 71 060 125
DSPCA Staff Contact: C. R. Burbach
The State Clearinghouse has reviewed the Summary Notification for the
above project.
As a result of the review, it has been determined that the proposed
project is in accord with State plans, programs and objectives as of
this date. You should now complete and file your formal application
with the appropriate Federal agency(s). A copy of this form must be
attached to your application.
Please notify this State Clearinghouse of the filing date as soon as your
application is submitted. If you have any questions, please contact the
DSPCA staff member named above.
Comment: Div. of Engineering, Dent, of Health J^n^f
additional treatment facilities".
Copy to Regional Clearinghouse
A-9 5 Stare Rej
:s for
0fficer^orm SC-A95-4
M25

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!. i]; oj• iiu i L...j
J (
¦\ ^ J
w *-*
1 V ZD
OCT "1 9 1Q71
	}
}	
f '¦
Date: October 15, 1971
!b ryland rerarv-vnt of State
¦>v~.;o Off "1	c;.'n-'
*01 best yrc-\'.cn 3trcet
'ir.l tir.xre, Maryland 21?01
vTl!>r^T* vof'\rm ^T'W • .?v yr^rvrn »
H iWi. » i .»»/i. i. Jti L.'.i. . J..».. J_f j L< :• x J. O •« . il; * jl .• i
Applicant: Washing-con ¦Subio'ban Sanitary Commission
Blue Plains - Chemical Handling Facilities
and Operations Building C'/?C-I-!D~299)
Scale Clearinghouse Control .vj-btr: £l6
circc:-' o:-r.
1. Tliis agency eoes net have a.n ^ni.crest :Ln the aKove project.
?« The above rro;'cot j r; consistent v:: Vn this agency's nlans or
~-,ieetives sr.: ve reeor.r'r-.nl apr.ro?.'al of the rrciect.
T;'.?s ecer.ev has 5 rather : ;y ere?!, in nr.d/or ouestions concernl nr the
above ',>re;:-ec, arici w: sne:? to cent r.-r '.'.'.th the • i e;>r.t.
Our, inte rest or r.v.cstlor.s are L-hovrn on cnc'i a ttaah'.rvn1.,.
1 I	""-T?
< J Ji?
agency eoes net believe a conference :.s nec^ss-i~y; but wishes to
r.^'ce favorable er quelifyinr cor::-,en t s shovrn on erirj cseci attachment. x
V^cL3:CIG:dls
Attachment
cc: Department of Natural
Resources
^7	r" ¦ /- , i
Sj p;r.?>:.u-e /.'<	Ml /
Titie Chief., Division of bater h. Sc'.'er-;:e
A pen cy Environmental Health Acr.ilnistrati cn
M26

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October 15, 1971
attaches::? to tks
PROJECT SUT-iMARY NOTIFICATION REVIEW
Blue Plains - Che::.leal Handling Facilities
and Operations Building (V/PC-KD-299)
This project is a phase of the r.ajor expansion of the
Blue Plains Treatment Plants This plant is bo in 3 expanded in
accordance i/ith the racesndali cr.3 of the Potomac Enforcement
Conference and the "'Icmcrandum cf Understanding^ in order tc
r.eet irater qualify standards established for the Potomac River
You. ma7 be interested tc hnc:" zhnt the Federal gran^ for the
District of Columbia portion 01 uhis project T.-;as approved on
September 28, 1971j and the Federal grants for the Maryland
and Virginia portions were approved cn October 7, 1971# We
also sugjesj that you change "cne project, designation for this
project to "Blue Plains - Secondary Treatment" as that title
more adequately describes the work to be accomplished.
/ \
si /y^	--7	/* / sff
Signature s> . --- -x—' -- >• / ¦/>-' *
Title Chief, Division of V.ater and Sewerage
Agency Environmental Health Administration.
VH-icLB :CEO :dls
cc: Department of Natural
Resources
M27

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Date: October 8, 1971
I
< !
Karvland Department of State Planning	'"*
State Office Building
301 VJest Preston Street	j	Q^T o i 1
Baltimore, Maryland 21201	j	u 6 ' 1971
SUBJECT: PROJECT SUtSIARY NOTIFICATION REVIEW	HlHj	j
Applicant: l.'n3hin~icn Suburban Sanitary' Ccrsrdsaion	-—:
Project: Bine Plains - Ch™icai Handling Facilities end
O'oc-raticns BTrlldir.'*
*	f- i-. /
Stata Clearinrhouse Control Number: ;!-5lo
CHECK ON3
1.	This agency does not have an interest in the above project.	
2.	The above Droiect is consistent with this apency's plans or
objectives and we recommend approval of the project.	XXXXX	
3« This afenev has further interest in and/cr auestions concerning the
above project and wishes to confer with the applicant,		
Our interest"or cuestions are shovm on enclosed attachment.
lj. This arencv dees not believe a conference is necessary, but wishes to
make favorable cr qualifying comments shown on enclosed attachment.	
The Maryland Environmental Service is involved in the disposal of raw sludge
resulting from the chemical treatment of the sewage for approximately twenty
months before incinerators are completed at the end of 1973. Investigation
of alternate methods and sites of disposal are being conducted in cooperation
with E.P.A., Department of Health and Mental Hygiene, Department of Water
Resources, and representatives of the Water Pollution Control Division of
Blue Plains.		
Signature	Y'9/^-r'Jc-
I'
Title Assistant Secretary
Agency Dept. of Natural Resources
Thomas C. Andrews, MES
Edgar H. Hollis, F&WA
Joseph Knapp, DWR
William A. Parr, F&P
W. McL. Bingley, SHD
M28

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MARVIN MANDEl
eovcRNon
MARYLAND
Department of state Planning
301 WEST PRESTON STREET
BALTIMORE. MARYLAND 21201
TELEPHONE- 301-3B3-24S!
November 30, 1971
VLADIMIR A. WAHBE
SECRETARY OF ITATK PLANNII
NORMAN HEBDEN
DEPUTY SECRETARY
Mr. Straty Zervakios
Principal Engineer
Washington Suburban Sanitary Commission
1*017 Hamilton Street
Hyattsville, Maryland 20781
SUBJECT: PROJECT NOTIFICATION AND REVIEW
Applicant: Washington Suburban Sanitary Commission
feirf)
*s.>
Project: Blue Plains - Secondary .Treatment -
Chemical Handling Facilities and Operations Building
Funds: Federal - $11,755,582; State - $5,31*3,1*1*7; Local - $1*,271*,557
State Clearinghouse Control Number: 5l6
State Clearinghouse Contact: Edwin L. Powell, Jr. (383-21*67)
Dear Mr. Zervakos:
The State Clearinghouse has reviewed the above project. In accordance with the procedures
established by the Office of Management and Budget Circular A-95, the State Clearinghouse
received comments (copies attached) from the following:
Department of Health and Kental Hygiene: recommended approval, noting that
Federal grants for this project were approved for the District of Columbia
(September 28, 1971) and for Maryland and Virginia (October 7, 1971).
Department of Natural Resources: recommended approval, noting the department's
involvement in the development of sludge disposal programs.
As a result of the review, it has been determined that the proposed project is in accord
with State plans, programs, and objectives as of this date. Approval and funding is
recommended.
Tou should now complete and file your formal application. A copy of this letter must
be attached to your application. Please notify this State Clearinghouse of the filing 4
date and the amount of Federal funds requested as soon as the application is submitted by
completing and forwarding the enclosed, self-addressed card. If you have any questions,
please contact the State Clearinghouse member named above#
Enc.
cc: Joseph Anastasi
Gerard Devlin
W. McLean Bingley
Herbert M. Sachs
Walter A. Scheiber
Sincerely,
Vladimir Wahbe
M29

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COMMENTS AND RECOMMENDATIONS
OF
STATE, REGIONAL OR METROPOLITAN CLEARINGHOUSES
DATE:
Project Number; ^	
'learinghouae or planning agency:
Name: Maryland Department of State Planning
Address: 301 West Preston Street
Baltimore, Maryland 21201
Source of Authority for Establishment of Agency:
Chapter 155 - Maryland Laws of 1969
in application is to be made under 33 USC et seq. to the Wat6r Quality
iffice, Environmental Protection Agency. The estimated date the application
rill be filed: Sqftenfcer 17, 1971	
Lpplicant'j?	Washington Suburban Sanitary Commission
U017 Hamilton Street
iddress:	Hyattsville, Maryland 20781
teo graphic Location of Proiect: ** district of Columbia, south of confluence of
Anacoaxia and Potomac Kivers at Blue Plains (D. C, V<'ater Pollution Control Plant)
fro.iect Description:
Additional Secondary Treatment, Cheaical Handling Faoilitiea and Operations
Building at D. C, Plant.
Clearinghouse Certification:
The project described above does (*) does not ( ) conform with the
jomprehensive plan developed or in process of development for the
netropolitan area in which it is located.
Comments and Re^""im^^ationa:
The State Clearinghouse reviewed this project and made final consents in the
Letter of Noveaber JO, 1971 (copy attached) • As a result of this review, we
reocnaaand that the project be approved and funded.
Authorized Representative of Clearinghouse
(Signature)
Vladlair Wahbe
Secretary, Department of State Planning
M30

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GOVERNMENT OF THE DISTRICT OF COLUMBIA
EXECUTIVE OFFICE
SPECIAL ASSISTANT TO THE
MAYOR-COMMISSIONER
OFFICE Or BUDGET AND PROGRAM ANALYSIS
QEO 1
REPLY TOl
ROOM 423. DISTRICT BUILDINO
14TH A C 6TRCCT9. N. W.
WASHINGTON, D. C. 10004
Mr. James Alexander, Director
Department of Environmental Services
Presidential Building
*~15 12th Street, N. W.
Washington, D. C. 20004
Dear Mr. Alexander:
This Office has concluded its review of your application
requesting Federal assistance to construct tertiary facilities at
the District of Columbia's Water Pollution Control Plant (WPC-DC-27).
Our review has Indicated that this project is consistent
with the interests and objectives of the District of Columbia. We
recommend that your proceed with the next step In the development of
this project, namely, submission of your application to the appropriate
Federal agency for funding consideration.
Slnc^Aly yours,y
Comer S. Coppie
Special Assistant to the
Mayor-CommIssI oner
* r \}	ntfTVtl
\
< 10T7?	JMIfWf
^72
ruink	WATW 0UAL,IY ^
DIVISION
M31

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GOVERNMENT OF THE DISTRICT OF COLUMBIA
EXECUTIVE OFFICE
SPECIAL ASSISTANT TO THE
M AYOR-COM MISSION ER
nmri OP BUDGET AND PROGRAM ANALYSIS
REPLY TOi
ROOM 423, DISTRICT BUtLDINO
14th &'E STREETS. N. W.
WASHINGTON, D. C. 10004
OEC 6 1371
Mr. James Alexander, Director
Department of Environmental Services
Presidential Building
415 12th Street, N. W.
Washington, D. C. 20004
Dear Mr. Alexander:
This Office has concluded its review of your request
for Federal assistance to construct wastewater treatment facilities
at the District of Columbia's Water Pollution Control Plant (WPC-
DC-28).
Our review has indicated that this project is consistent
with the interests and objectives of the District of Columbia. We
recommend that you proceed with the next step in the development of
this project, namely submission of your application to the appropriate
Federal agency for funding consideration.
Corner b. topple
Special Assistant to the
Mayor-Commlssloner
RF.' r . iV'Et)
deceived
10 1972
JAN 171972
WATER QUALITY CONTROL
DIVISION
M32

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COG 28 (8-10-71)
metropolitan Washington
COUNCIL OF GOVERNMENTS
1225 Connecticut Avenue, N.W., Washington, D. C. 2003G 223-6800
January 4, 1972
MEMORANDUM
Tq. Mr. Paul V. Freese, Director
Water Resources Management Administration
D.C. Department of Environmental Services
415 12th Street, N.W.
Washington, D.C. 20004
SUBJECT: Review Comments on Final Application for
PROJECT: D.C. Water Pollution Control Plant Expansion - Tertiary
facilities also site loaming, seeding and landscaping;
wastewater treatment facilities
COG NO: 72-DC-W/S-3 and 72-DC-W/S-4
APPLICANT: D.C. Department of Environmental Services
As Metropolitan Clearinghouse for the Washington SMSA,
the Council of Governments has concluded a review of the
final application for the project noted above. The Council
has endorsed the attached Metropolitan Clearinghouse Review
Comments.
Endorsement of these Comments constitutes the Metropolitan
Clearinghouse review that is required for this project. A copy
of this Memorandum and the attached Comments should accompany
your application when it is filed with the Federal Agency so as
to indicate that this review has been completed.
Your cooperation with the Clearinghouse procedures is
appreciated greatly.
Attachments	*
Executive Director
M33
. District of Columbia • Arlington County • Fairfax County • Loudoun County • Montgomery County • Prince George's County • Prince William Count
Alexandria * Bowie • College Park • Fairfax City • Falls Church • Grecnbelt • Hockville • Takoma Park

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1 ,'i Ic.'. C J I .:Ct id i L . \	I) i J ii: > O , V;. C. i of_. v- 22;)-(i,.'^0
ft!7.'P1 -'OPCLl T.V J C^EArilJCiHOTJSM KVVJB'.v' COMMENTS
COG PROJECT KUMtJr.l'S : '/2-DC-W/S-3
72-DC- W/S- 4
PROJECT WiME: D.C. Water Pollution Control Plant Expansion -
Tertiary Facilities and sice learning, seeding,
an d 1 cin da c ap j ny
D.C. Water Pollution Control Plane Expansion -
Waste Water Treatment Facilities
APPTjj."C7\NT: Government of the District of Columbia
FEDERAL AGEPC'Y : Environmental Protection Agency, Office of Water
Programs
FEDERAL PRC-GRAM AND AUTHORIZATION: Federal Water Pollution Control
Act, as amended
P RQ JECT D E S C RIP TI ON :
The District of Columbia Government is making two related
applications to Vhe Environmental Protection Acjency for grants
totalling £47,518,062 for the purpose of constructing tertiary
wastewater treatment and appurtenant facilities at its Water
Pollution Control Plant at Blue Plains. Cost allocations in
connection with these two projects are as follows:
District of Columbia $ 28,195,300	$10,683,113
WSSC 60,608,6 34	22,964,427
Fairfax County 3,276,143	1,241,321
Federal 34,460,923	13,057,139
$ 12 6 , 5 417 O'O 0	S 4 7 ,~9 4 6 70 0 0
Suburban jurisdictions and agencies participating in the
upgrading and expansion of the facilities at Blue Plains are
responsible lor making their own independent applications for
Federal grants.
RELATIONSHIP TO THE .METROPOLITAN PLANNING PROCESS AND THE
ACinv^:.:': /... of' areawYde"coals >¦.:¦•)d objectives:
Improvements to the District of Columbia Water Pollution
Control Plant are beinc- undertaken pursuant to water quality
standards adopted by -die District of Columbia and approved by
the Secretary of the Interior in January, 1969, and recommenda-
tions of th;: Potomac Enforcement Conference. These stand:m:os
are designed to provide recreational opportunities eis a result
M34
D isi rin of C .>hi rtjl i. • * Ailin;,!	* I j'if.i*' ( oi.i'lj • i Jonn (. "u.i ly • A! : .tma i > L-i-uoiy • Pi ;t ic<. (n wrj:e ("no i) • I'r incc W illi.ua C"uir. ty

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of water r,u.. 1 ;i ;-v	nownstro<:rri uses to ho benefited
]•-- upcr.-:di so w ' CO '. !. L q C: c. i on .
Loaoi'.-'Cjs per;o.;. i.tcd by	Potomac rnforcement Conference
nt Pino Pla.- lis ore as follows: BODr - 12,700 pounds/day;
ohr.-f.phoru -- j60 poim Jp/(J&.y ; nitcogen - 6,130 pounds/day. In
or do f L"0 Post these effluent standards, construe L.i on of advanced
waste t ro-'i rr.cni t works (AWT) w,-.n reooiiT.iendod. In U .ially , it was
onv.-i sionctl that expsms1 on of D l.uo Plains to 419 ingd (compared to
2 <10 mod ex » r»	dosiea copac.i iry) would be undertaken, but by a
"i irsnoi andun of [Jnders tanding" dated October, 1970 it was agreed
tli.it the plant would be expanded only to 309 mgd, with capacity
to be c-i I located a:: follows:
District of Columbia	135 mgd
WSSC	14 8 mgd
*Dulles-Poto:nac Interceptor	18 mgd
Pintra11 Run Interceptor		B_ mgd
309 mgd
*Seven mgd to be used'by WSSC.
(An important corollary to the limitation of capacity at Blue
Plains to 309 mgd is the necessity of the provision of additional
treatment capacity in the Maryland suburbs.) Installation of
AWT and other facilities will reduce BODr loadings to Enforement
Conference effluent standards resulting in almost complete
renovation of wastewater.
Improvement of water quality in the Potomac River will
complement COG-adopted policies pertaining to the banks of the
Potomac. by resolution of February 27, 1964, COG went on record
in .support, of the preservation of scenic:,- historic, scientific,
and ceorcs t J onal values of the Potomac shores. There are a number
of exist:: n:: ooen spaces and recreational tncil itics on the
Potomac whose amenity will be directly increased by cleaner
v/ater—Fort Foote , Port Washing ton, Pohick Regional Park, Fort
Hunt, and the George Washington Memorial Parkway are examples.
Installation of AWT facilities at Blue Plains will directly
contribute to the reduction of environmental pollution, one of
COG's water resource goals. A second goal is the assurance of
an adequate water supply. Construction of AWT facilities at
Blue Plains may indirectly contribute to the future feasibility
of utilizing estuary waters as emergency supplementary supplies
during summer ti r.-.e low flow conditions. (The Corps of Engineers
is at present designing an emergency estuary water intake.) In
connection with the regional Wo'ter supply question, reduced
reliance upon the Blue Plains facility on the p??-'t of the Mary-
land suburbs will moke necessary the construction of additional
capacity to serve portions of Montgomery and Prince George's
Counties which would otherwise be served at Blue Plains. Design
of such facilities must be coordinated ^ith due regard for regional
water sup pIv n ee ds .
M35

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I\ third go.-J is vhe coord in at .i on of physi cai development.
It has been clo^r:n9trc.¦„ cd ;!iac t;ic location air.! rate of urbaniza-
tion in the V/ar.ln no ton meL.r.opol.it.et) area can ];e infrJ ue-ncatl by
tho location and timino of provision of sever service. Until
recently sewer service policy bad not been used as a conscious
tool oJ- c5evelop"ion i: policy. out the institution of ton-year
sewer f ac.l li. tier; olann ing in the Maryland suburban a ».eas is
rapid j v chang j.no this state of. a Hairs. Reduced reliance upon
Blue Plain.'; -will probably act to give suburban jurisdictions
increased flexibility in local land use planning.
The environmental statement submitted in connection with
this project states, "The proposed work is not expected to
significant]y affect population distribution or concentration
even though land use plans in the tributary area were based on
expansion and upgrading of the facility." This statement may
be correct for those parts of Northern Virginia which are
linked to Blue Plains via the Dulles-Potomac and Pimmi.t Run
Interceptors and for whom capacity ceilings at blue Plains
appeal" sufficient, at least for the short run. The interim
water quality management plan current]v being prepared jointly
by the Porthern Virginia PJanning District Commission, the
Council of Governments, the Fairfax County Department, of Public
Works, the Alexandria Sanitation Authority, and the Arlington
County Department of Public Utilities reaffirms the continued
use of the Blue Plains facilities for affected Northern Virginia
service areas and recommends no other alternative.
The Maryland suburbs, on the other hand, will need to develop
additional treatment capacity in the relatively near future.
To the extent that the removal of the Blue Plains a]ternative
imposes a different set of regioiurl or local constraints upon
treatment plant site selection, location of future .service areas,
or other elements of facilities design, it is likely that allocations
of households and employment will, in fact, differ from those
afforded by the assumption of the unlimited expansion of the Blue
Plains facility.
In order to evaluate the impact of public policies in
transportation, sewer and water service, land use regulation,
and open space, the EMPIRIC activity allocation model has been
developed as pa'rt of Lhe Council of Goveinrients' comprehensive
planning program. Through the model probable distributions of
households and employment in response to major policy decisions ,
such as the location of a new freeway link, rapid transit line, or
greatly expanded public sewer service, is determined. At present
the EMPIRIC model is being used to examine four alternative growth
configurations in connection with the re-evaluation of the original
"Year 2 000" policies plan adopted in January, 1964.
Two urban water resource."? projects arc underway in COG's
Department.of Health and Environmental Protection that bear
directly on water, quality management r<.'.anning. The first of
these projects is a Demonstration Grant administered by the
EP7a. The objective of this projecL is to demonstrate that
existing, but independently developer!, ma themati cal models of
M36

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; i i. if e"er- •. t,ow-,o:>.'!i:"r oI: the urban water resource system can be
icru i.'.a lit	:r; m such a v.'av as to es t j I'vi to the impact of
, ¦ ai.d :! c	- '.Lcr -p.;.'Lit/ in 1::;.' roLo;1. u': River. Con'^onent
models v;i.i L "iimv.1. *• Ui loathvimuti callv iho grov/frh of households and
.;>iiyloy ..f.Ti t (EK>P:r-VLO) , water supply demand, v.'ater supply distribution,
s to.rmva1 tor runori: end the PuLomac Estuary,
T'lii:; r. aa Ivy ipackage, in itself, in not intended to provide
;.>ns\.ers to the f;o''orc vatei quality problem in the Potomac. Rathen-
:i t vri LI be an op-.:rcu:.ionnl "tool" foe estimating and comoaring the
v/atr,r qv'.'ity- ihipll i eo hi ons of alternative metropolitan development
pattern:-.. It \/ i j 1 be the kind oi" analysis that sliould be incorpo -
rated i a i o metropoj itan water Quality management planning.
Preliminary demonstration?; of this methodology are anticipated
before dune, 197 2.
STAFF J?.r;CO:i:'ENDAT j.OT-T:
The staff recommends er^dorsemerrt of these comments by the
Health and Environmental Pjotec Lion Policy Committee and the
Land Use Policy Committee.
M37

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w
h&5Sh\£Lt\ 9
SLUE Plftl'rtS
IWILL Cost :
*35,170,OCO pc»» y^tiK
-V© op«-a4e "the Wmei-9zc> 46ns pev olaa
6% lueret. >SLUP6rjF
98,ooo pe«-cUv
P«oiay ces vrflcK 0X 5A-6S VM»l(£&&at}
RfAD OfJ
M38

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November 13, 1971
Dear Members of the 92nd Congress:
Environmentally concerned citizens call upon you to meet this
national crisis:
~EVERY CONGRESSIONAL DISTRICT IN THE UNITED STATES HAS A SEWAGE OR WATER PROBLEM.
*A "CLEAN WATER" BILL IS BEING DISCUSSED BY THE HOUSE PUBLIC WORKS COMMITTEE,
(the Senate bill is S. 2770) Passed 86-0. Muskie Bill.
*THIS STUDY OF THE BLUE PLAINS TREATMENT PLANT ON ROUTE 295 AND THE POTOMAC
SHOWS WHY PHYSICAL-CHEMICAL TREATMENT AND RESULTANT BURNING OF SLUDGE
WILL NOT SOLVE MUNICIPAL, INDUSTRIAL SEWAGE PROBLEMS, AND WILL TRANSFER
THE POLLUTION PROBLEM FROM THE WATER TO THE AIR.
*PLEASE SUPPORT THE LAND-CONTAINED SYSTEM SECTIONS OF THE SENATE BILL
(section 201, Section 209) BECAUSE THIS METHOD IS:
1.	capable or nandimg mauscnai, municipal, storm water,
agricultural wastes. See Muskegon studies. Document A.
2.	not adding poisonous gasses (NOX), to the air by burning
sludge. Document D—Washington Metropolitan Coalition on
Clean Air.
3.	it is cheaper both for capital outlay and operations. Document A
Muskegon studies. Document C—Denver Metro Study.
4.	it solves the problem of disposing of Viruses that escape the
physical-chemical treatment method. Document E-r-Study of Viruses.
*PLEASE URGE YOUR COLLEAGUES TO REPORT THIS BILL OUT OF THE HOUSE PUBLIC
WORKS COMMITTEE BEFORE THE END OF THIS SESSION OF CONGRESS.
Marian K. Agnew, President
Northern VVrginla Conservation Council
Cd* 3©*. A220C3
M39

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POTOMAC ENFORCEMENT CONFERENCE
November 10, 1971
Marian K. Agnew - Northern Virginia Conservation Council
Since we met here last month, I have received comments on my testimony that
vary greatly both in content and in approach. I appologize to you for the fact that
that document was a rather hasty job. We were not informed about the conference
until several days before it convened, though we had monitored your publications,
tfe therefore did not have time enough to do the research required to document fully
our position. However, that situation has been rectified to the best of our ability.
We therefore refer you to the reference materials at hand. Document A. is a cost
and performance comparison for alternative treatment systems in Muskegon County,
Michigan. These are the aerated lagoon spray irrigation facility versus two-stage
activated sludge, chemical treatment and filtration system. The second document,
B., contains pages from a report made for Congressman Vander Jagt by Battelle
Laboratories, Richland, Washington, on the Lake Tahoe, California Plant. The third
document, C., contains excerpts from a study made by Ronald McLaughlin, of Wright-
McLaughlin Engineers, Denver, Edwin Bennett, Associate Professor, University of
Colorado Department of Civil and Environmental Engineering, John Puntenney, Plant
Superintendent and William Martin, Assistant Plant Superintendent, Metropolitan
Denver Sewage Disposal District No. 1. This document is a study of the sludge in-
cineration process at METRO, Denver.
Before our formal presentation, I feel that a philosophical comment on the
nature of citizen organizations and their roles in this Conference is in order. We
are both the taxpayers and the consumers of the systems which we will discuss. We
are not the experts. You are paid to do that job. However, it is incumbent upon
groups such as the Northern Virginia Conservation Council to raise questions rela-
yent to both past activity and to future directions in wastewater management.
M40

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In our statements at the last Conference, the Water Quality Study Committee
made three points. 1. The Corps of Engineers Permit Application for dredging a
channel in front of the proposed facility varies from the Environmental Impact
Statement by more than 600,000 cubic yards of sludge spoil. We questioned the impact
of this toxic material on the ecology of Dyke's Marsh where it will be dumped. We
have received no answer from your office on this point or any other. 2. We ques-
tioned whether Blue Plains when upgraded to AWT 309 MGD will have enough capacity
to handle the wastewater problems of the Metropolitan area. Thursday, November 4,
when we visited the plant, it had been running at 300 MGD hydraulic for 6 hours,
and at 295 hydraulic all night. Mr. Noman Cole, Chairman of the Virginia State
Water Control Board, has told us that the flow may even exceed these figures inter-
mittently. In the AWT process, sewage must be retained for 18 hours, and no provisior
has been made to handle flows that exceed 309 MGD. When we asked our guide at the
plant, a bypass to Piscataway was suggested as the answer. 3. We stated that the
Blue Plains Plant is not part of a totally integrated sysC«m that respects the in-
tegrity of the natural system. We have studied this aspect of our last statement
and concluded that conventional treatment is at best an interim solution. Blue
Plains may treat water to an acceptable standard, but the resultant sludge problems
attendant to this treatment require careful evaluation. Such facilities are over-
taxed easily, their life expectancy Is relatively short and they are expensive to
operate.
Alternative waste treatment methods, which requires the return of pollutants
to natural cycles, are only new in the sense that they have re-emerged for modern
application, adapted to today's technology. 1600 such facilities are in use in the
United States today. Disney World in Florida is perhaps the best known. The plant
now under construction at Muskegon, Michigan, a 35 MGD facility will combine a
waste water treatment facility for both municipal and industrial byproducts with
a 33 megaton Nuclear reactor, and a sanitary landfill that will serve the area for
more than a hundred years. Work has been done on this method at Penn State and at

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Michigan State University. Under the direction of the Corps of Engineers, studies
are now being made to apply this methode to five urban areas totaling 15% of the
U.S. population; they are Boston, Cleveland, Detroit, Chicago, San Francisco. The
report of the Senate Public Works Committee states, 'The ground disposal systems
have the great virtue of recycling the materials so disposed, both by replenishing
water tables and by converting and utilizing organic waste matter in natural life
processes of decay and growth." "Their secondary merit is more germane to this
discussion. Water reaching watercourses after passage through the filtering and de-
composition processes afforded by soil is far purer - provided that soil loading
rates are not exceeded - than any waste treatment process short of distillation
could make them." Senate Public Works Committee Report
An examination of document A, the comparative study of the two systems, reveals
the following salient differences:
(1)	comparable levels of treatment can be achieved with both technologies with
some exceptions. One of these is in the level of expected Nitrogen removal which is
85% in the aerated lagoon or land contained system, but only 50% in the conventional
system. It is possible, by the addition of the methanol nitrogen removal process
to up conventional plant Nitrogen removal to a level comparable to the land contained
system, but at an additional cost of approximately 100,000 dollars a years for an
average flow of 35MGD (p. 11, Document A).
(2)	Total elimination of viruses was considered reliable only in the land
based system (p. 12, Document A & Document E).
(3)	Failures from accidental spillages or toxic surges are more of a hazard
to the conventional activated sludge plant than to the land contained system as weekly
analyses winter and summer of the aerated lagoons indicated BOD and TSS reduction of
80 to 90 per cent on four days detention in summer and 6 days in winter. (Engineer-
ing Feasibility Demonstration Study for Muskegon County, Michigan, "Wastewater
Treatment-Irrigation System.")
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(4)	Conventional treatment is also far more susceptible to failure resulting
from reduction in efficiency of treatment when normal flows are exceeded whereas the
irrigation system would achieve full treatment up to and including peak flows of
88 MGD (p. 12, Document A).
(5)	The occasional need for a high degree of chlorination in the conventional
plant, discharging into a natural river or stream results in severe problems with
fish or other aquatic forms of life. In the land contained system chlorination of
the effluent never poses a problem as it is done in the lagoons, before irrigation
and no chlorine is discharged into streams or rivers (p. 12, Document A).
(6)	Although color is not a problem presently at the D.C. sewage treatment
plant, it has been demonstrated that both color and heavy metals will be effectively
removed by the land contained system (p. 12, Document A). We are all well aware
that the build up of heavy metals in the bottom deposits of the Potomac adjacent to
the Blue Plains sewage treatment plant pose a serious environmental threat. The
very real danger posed by these heavy metals concentrated by sewage treatment plants
is that they may enter aquatic food chains.
COST COMPARISONS
Because we are both taxpayers as well as consumers, a comparison of relative
investments might be considered for these two systems to demonstate relative costs
of conventional vs. land-contained systems. The following figures from Muskegon
study (Document A) and approximately extrapolated to Blue Plains will indicate our
concern: (pp. 15-18, Document A)
35 MGD (Muskegon)
309 MGD (Blue Plains)
Capital Cost8 of Land-
contained systems
$34,000,000
$299,200,000
Conventional A.W.T.
However, lowest bid
$23,000,000(estimate)
$43,000,000
$359,000,000
(WSSC estimate)
Operating costs of Land-
contained systems
$ 1,100,000
$ 9,700,000
Conventional A.W.T.
$ 2,200,000
$ 19,400,000
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The most troublesome feature, perhaps, of the conventional AWT plant Is the
volume of wet sludge produced per day, amounting to 560 tons/day (p. 18, Document A)
which, when extrapolated for the proposed 309 MGD Blue Plains facility becomes
4,928 tons per day of wet sludge!
It would appear then that the prc^osed land-based system is not only superior
on the basis of reliability and degree of treatment, but it also cost a great deal
less. Table 3, Document A (p. 21) indicates the total annual local cost is on the
order of magnitude of one million dollars less, not including profits from crop
production on irrigated lands. To summarize the superiority of this kind of system
over the water-oriented system presently envisioned for Blue Plains:
(1)	It is possible to obtain tremendously valuable riverfront property by
relocating Blue Plains away from the present site it occupies and at the same time
enhance the aesthetic value and quality of the river through improved water quality.
The technology presently exists for pumping sewage for the lagoons at least 100
miles. Thus many possible sites for such a regional plant exist anywhere within
a radius of 100 miles. The desirability of substituing land of much lower value for
the required land-sewage ration of 130 acres per MGD is obvious.
(2)	Since the primary capital investment in a land-based system is in land
rather than capital costs and plant construction, the depreciation of the citizen's
investment is minimal. In a conventional plant, however, where the primary capital
investment is in the treatment plant, the expectation is tint depreciation to a value
approaching zero will take place as new technologies become available and present
ones obsolete.
(3)	An additional problem scarecely touched upon by conventional plant advocates
is that of sludge incineration. (We have inserted a flow diagram (p. 9a, Document A,
figure 3 and 4) in the body of Document A. The schematic of the proposed Blue
Plains facility is placed directly behind that of the conventional Muskegon plant
schematic in order to directly compare these two treatments. Except for some
M44

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unresolved N removal problems, the two processes seem directly comparable.) With
the proliferation of conventional sewage treatment plants with increased emphasis
on sludge production (physical-chemical processes) the problems of sludge incinera-
tion become ever more apparent. Recent studies on the Lake tahoe sludge inciner-
ator reveal no visible emissions, but unbelievably dangerous levels ef nitrous
oxide emission, i.e. 52 to 65 ppm (see p. D-3, Document D). Since this is a multiple
hearth sewage sludge incinerator very comparable to many others currently in opera-
tion, it may be assumed that similar emissions are occurring from other plants and
that the air pollution standard of 5 ppm is being exceeded in many of these operations
Furthermore, the very considerable fuel supplies consumed to keep these sludge incin-
erators in operation may, as extrapolated from the fuel costs of natural gas for
Tahoe's incinerators, cost as much as $5,000 a day just to run the incinerator for
the proposed Blue Plains sewage treatment plant. In winter when fuel shortages
occur, it might become necessary to make the decision as to whether to incinerate
sludge or heat homes. (See Washington Post clipping on gas shortage - Document F.)
Additional data on incinerators from the Denver area (Document C) indicates that
among the problems plaguing this incineration of wet sludge are low production
efficiency coupled with dangers of explosion, severe odor problems and mechanical
failure due to many corrosive substances in the wet sludge. Several installations
have been abandoned because of these problems as well as difficulty in meeting air
pollution standards, particularly for sulphur and nitrogenous oxides. No technology
presently exists for removing these oxides from the stack gases. At the rate of
$19.70 per ton for sludge incineration, the Blue Plains production of 4,900 tons/day
will cost $98,000 per day.
This conference has already received a letter from John Winder of the Clean
Air Coalition which I would like to read to you.
^We of the Northern Virginia Conservation Council would like to second his
request for an Environmental Impact Statement on the incinerator. We must also be
assured that there is no intention by WSSC to use the channel to barge sludge out to
M45

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sea and dump it J | In the 102 statement we feel that an alternate land-contained
facility must be considered and highest priority given to finding the proper place
to put it. I understand from the Corps that there are several acceptable sites well^J
within the range of pumping capability and for which technology is presently available.
Since before recorded history man has marveled at the wonderful facility of
the Earth to support him and to supply his needs. Go asked of Job:
"Did you proclaim the rules that govern the heavens or determine the laws of
nature upon Earth? Who is wise enough to marshall the rain-clouds and empty the cis-
tern of heaven when the dusty soil sets hard as iron and the clods of earth cling
together? Who has cut channels in the downpour and cleared a passage for the thunder-
storm, for rain to fall on land where no man lives and on the deserted wilderness
clothing land's waste and derelict with green and making grass grow on thirsty
ground?" And Job answered the Lord: "I know that thou canst do all things and
that no purpose is beyond thee."
Let us like Job learn the magnificence of interrelated natural systems that
came with this Earth long before any of us arrived and which have been seriously
damaged within the life span of most of us in this room. These life systems must
be protected and preserved. Damage such as the improved Blue Plains facility will
do both to the river and to the air above it cannot be allowed. We cannot solve one
problem such as water pollution only to create another - pollution of the air. The
land-contained waste treatment facility alone resolves the problems of human waste
totally, sensiblily, cheaply and environmentally. Muskegon started with a letter
from President Nixon in 1969 and is being constructed today.
If we start now, in 1971, we will have a clean Potomac by July, 1976. What
greater gift for the Nation's Bicentennial!
M46

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MUSKEGON COUNTY WASTEWATER MANAGEMENT
SYSTEM NUMBER ONE
COST AND PERFORMANCE COMPARISON
FOR ALTERATIVE TREATMENT SYSTEMS
Aerated Lagoon-Spray Irrigation Facility
Versus
Two-stage Activated Sludge,
Chemical Treatment and Filtration System
By
Bauer Engineering, Inc.
Chicago, Illinois
April 1971
A MUSKEGON-REFERENCE
M47

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TABLE OF CONTENTS
Page
Introduction	1
Description of Alternative Systems	4
Performance of Alternative Systems	11
Costs of Alternative Systems	13
Summary	18
List of References	22
LIST OF TABLES
TABLE 1 Two-Stage Activated Sludge, Chemical
Treatment and Filtration Systems-Bases
of Design and Functional Procedures	10
TABLE 2 Comparison of Costs of Systems	20
TABLE 3 Comparison of Costs to Residents of
Muskegon County	21
LIST OF FIGURES
FIGURE 1 Aerated Lagpon Spray Irrigation System	5
FIGURE 2 Plan Map Alternative Treatment Systems	8
Figure 3 Alternative Treatment System	9
M48

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INTRODUCTION
The following comparison of the alternative treatment systems
for combined industrial and domestic wastewaters in Muskegon County,
Michigan comes after two years of investigations and engineering de-
sign work. The style of the paper is intentionally terse and con-
densed. Those interested in greater detail are referred to the several
reports listed at the end.
Alternative systems are compared to handle the following flows
from the urbanized area around Muskegon Lake and Mona Lake:
Avg.	Peak
Flow	Flow	Design Design
Source	Rate	Rate	BOD	S. S.
Domestic and com-
mercial wastes
(160,000 pop.)	18.5 MGD	46.2 MGD	190	190
S. D. Warren Co.
(paper mill)	12.0 MGD	13.0 MGD	400	400
Other industrial
wastes	11.5 MGD	28.8 MGD	190	190
42.0 MGD	88.0 MGD	250	250
The design objectives for the quality of treated effluent discharged
back to Lake Michigan (via streams) at this location are:
Muskegon-Flows
M49

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Project
Parmeter
BOD
Suspended Solids
Objectives
< 4 rag/1
A mg/1
Total Phosphorus
0.5 mg/1
Pathogenic Organisms
(Bacteria and Viruses)	Total removal
Nitrogen
Color
Nitrate-N
Ammonia-N
^ 0.5 mg/1
^ 5.0 mg/1
No evident color
Heavy metals
Concentrations
well below thresh-
hold levels for fish,
wildlife and agre-
culture*
*Accomplished through sewer ordinances and treatment processed.
These performance objectives have been established to pro-
vide protection for the shoreline lakes consistent
with conservation, recreational and economic development
goals expressed by the community and with the opportunity poten-
tial of the County's water resources. They are higher than the
minimum standards established by the Federal and State regulatory
agencies.
Muskegon-Perfonnance
Objectives
M50

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Federal regulatory requirements are presently in effect
that require the elimination of 80 per cent of all phoshporus
discharge by municipalities and industries that discharge to
the Lake Michigan drainage basin. The State of Michigan has
a first stage program in effect of requiring a minimum of
secondary treatment of all municipal and industrial sources
of organic pollution and higher levels of treatment in
special areas where protection of the designated water uses
require it.
Color is an important problem in the combined waste re-
sulting form the S. D. Warren paper mill waste. Laboratory
studies by the millft1 consultant Quirk, Lawler and Matudky
Engineers^- showed that with activated sludge treatment alone
there would be only a 50 per cent reduction in apparent color.
Color is an important pollutant for aesthetic reasons as
unnatural discoloration of lakes and streams can lead to
substantial public dissatisfaction and loss of recreational
value.
Although there are no present standards on virus or
nitrates discharged to Lake Michigan (via streams), it was
considered desirable to minimize the»e as much as is practi-
cable . In the;-case ,<7f the					
Quirk, Lawler & Matusky Engineers, Laboratory Scale
Treatment Studies, for S. D. Warren Company, New York,
New York, July 1969
M51

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irrigation system, up to 85% of nitrates and 100% of virus are
expected to be removed. In the case of the alternative system,
an estimated 50% of nitrates and as much virus as possible are
to be removed.
In both systems there are pumping stations and force mains
to convey wastewater to the place of treatment. Differences in
these costs are included in the comparsion.
DESCRIPTION OF ALTERNATIVE SYSTEMS
Aerated Lagoons plus Irrigation
This system (located about 10 miles east of muskegon Lake)
employs 3 days detention in mechanically aerated open lagoons
followed by further treatment in large naturally aerated storage
lagoons. The schematic layout is shown in Figure 1. Sufficient
storage is provided to contain 4 months of flow at the full de*:
sign rate of flow in two 9 foot deep, 850 acre storage laggons.
During the warmer 8 months, the full year's volume of wastewater
would be first chlorinated and then irrigated over 6,000 acres of
land using mechanical irrigation machines to achieve a relative-
ly uniform distribution of the water. The maximum design rate of
irrigation is 4 inches per week. At ultimate design
MUSKEGON- AERATED LAGOON
M52

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COLLECTION 0JOIOG/CAL TQEATNPftJ
MP	ANO
TRAfTSMfSStOtf	ST0f?4G£
7tRTtAKf TREATMENT
BY IQfUQATION
/ TMSMfSS/Cs'
,' ftmftNG-
/ STMIOtf
i»
*
I 5
*-5
n7
-)
A)* m*K> Afloat fVMHNG Sfimotf
s^v-vr-.A
1—_L	J	1	1	Ll	^
SUB-DRAW AC e VrSTfM pfAlHMC
PUMP/HG
STATfOt*
	-		

* *.
FIGURE /
$' B * : JH 1
SaB'DF(A>fiAGE P/Pf
4trfiAT£D LAGOON
spray iW6Ar«*/ SysreM

-------
conditions, about 45,000 acre-foot of water be irrigated,
most of. it in 6 months at an average rate of 3.A inches
per week.
The nitrogen content of the wastewater is estimted
to be ultimately about 30 mg/litre, which would result in
about 3,600,000 pounds per year of N beinp, delivered to the
treatment site. Of this, approximately 2/3 is expected to
lie converted to organic forn in the sludge which is produced
in the lagoons and is to be dredged out for land application.
T?iis fraction would be converted slowly to available TI at
the rate of 3% per year. The retraining 1/3 or about 200 lbs.
per acre per year would be applied to the land with the treated
wastewater. It is likely that very high crop yields can be
expected ultimately. Initially, however, there may be in-
sufficient II for such crops as corn or grass. For this
reason, alfalfa and soybeans nay be used in..the early years.
The site is underlain by a permeable sand (having
2
a permeability of about 400 gpd/ft ) in thicknesses ranging
from 25 to 100 feet. An extensive drainage system is provided
to receive the large quantity of infiltration which is expected.
The capacity of the drainage system is at least 0.4" per day,
or 0.016 cfs/ncre.
M54

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Plans and specifications for this system have been completely
drawn up, and detailed cost estimates based upon these documents have
been made.
Two-stage Activated Sludge with Chemical Treatment plus Filtration
This system is assumed to be located on the nearest available
site of adequate size. A 200-acre site on the Muskegon River east of
the urbanized area was selected (figure 2). The treatment processes
employed would include primary sedimentation* activated sludge biological
treatment, biological nitrification, lime settling and sand filtration.
The final effluent would be chlorinated before discharge to the Mftskegon
River. A schematic layout of the processes is shown in Figure 3 and
Table 1 summarizes the bases of design and the functional purpose of
each of the processes employed. A downtown pumping station-located
in the same location as for the alternative system-would pump the
flow about 2 miles through a 66" force main to the plant. The treated
effluent would be discharged Into the Muskegon River. The sludge would
be utilized on farm land in Muskegon County as for the other system.
Plans and specificaticns for this system have not been drawn
up. Cost estimates are based upon experience with other plants of
similar nature and size.
Physical Chemical
Muskegon-Advanced
Waste Treatment
M55

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f t • 4^ r* / •'» w»»
(SQUOS 4fM0V*U
ft&rvtovTAi-
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I
i
c
u
*
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a
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-r
fO*GA*/lcS, K£M°WU*)
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SfCOfVDfl'RV f?EH0V/Jt-
CftmidfrJLI T&£ArM£Mf
COAOOUA 77C/V oc?
^{*rJe rtrte A**

IftrrClt
PLANT DtCCH4*&f
ro
ALTERNATE W?flrM£n/T SY^TCMS
^ * »omm	a /

-------
/fW


\
Si
&raw/y SA>a£f
7%/*j£/s/p


77/c&/rp-
l/y
-------
TREATMENT AND FILTRATION SYSTEM
BASIS OF DESIGN AND FUNCTIONAL PROCESSES
Process Unit
Design P.asis
Performance Function
Preliminary treatment
3o MGD - 1 ft/sec.
controlled velocity grit
chambers with mechanical
grit removal equipment.
Primary sedimentation GOO gal/ft^ overflow rate
for 67 'ICD peal', day flow.
High rate activated
sludge aeration tanks
Activated sludge
nettling basins
3-hr aeration for 67 *'GD
with 25% return sludge.
100 gpd/ft^ overflow
rate for 67 ?-rGD.
Debris, coarse particle
removal, flow measure-
ment .
Pemoval of settleable
solids.
Oxidation of carbonaceous
BOD.
Settling of 1st stage
aeration sludge.
ditrification
aeration tanks
Nitrification
settling basins
3-hr aeration for 67 1'GD
with 25Z return sludge.
800 gpd/ft^ overflow
rate for 67 "GO.
Biological oxidation of
ammonia to nitrate.
Settling of 2nd stage
aeration sludge.
Line clarification
lias ins and equipment
25^ mg/1 lime addition
for 67 "CD, two upflow
1000 gpd/ft^ overflow rate
clarifiers in series with
recarbonation.
Phosphorus, color and
suspenrled organic matter
removal.
Line reca]cination
7 0 ton/day cap?city Id ick-
c i.:r c..::triTuge _vnd Mir.
pocoverv of spent line.
"ixed-' 'cdia
"iltration
6 gpn per snuarc foot for
67 MGD, 2.0 gpn back-
wash rate.
Removal of solids sus-
pended in the clarified
'later, some removal of
pathogens.
Sludge thickeni ng
tanks
Concentration of 1",'
activated sludge to A?
reduction of required
digestion volumes.
Sludge digestion and
holding tanl s
high rate-15 day heated
digestors,	lbs.
of solids per day at h"
2°" solids reduction,
j-:ionth's sludge storage
at
noli'.'s.
^eduction and. concen-
tration of solids, odor
and pathogen elimina-
tion, winter storage.
Sludge transfer
facilities
7 '"lo/'-'r-0?" tons/da^
capacitv for sludge.
^apid loading for rail
or true'", transportation.
rklor:i nation
F.nci 1 '.ties
ph] orin.a tion ca-oacitv up
to 25 i"g/1 for h«n' "H,
15 : limite detention of 2P.
¦ ¦e.n -icak rate.
Pac teriologi c and
virologic disinfection.
M58

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PERFORMANCE OF ALTERNATIVE SYSTEMS
The two treatment systems were designed to accomplish the
effluent objectives listed with as equal performance comparison aa
reasonably practical. Lime settling was, therefore, specified for the
conventional system to accomplish phosphorus, color and heavy metals
removal in. an efficient manner and to reduce the discharge of BOD and
Suspended S©i;f
-------
reduce suspended solids and phosphorus in the percolation water to virtu-
ally zero concentration levels; BOD will be reduced to well below h mg/1
and total nitrogen to between 2 and 5 mg/1. Color and heavy metals will
also be effectively removed. The filtration and adsorption phenomena wxll
totally remove bacteria and virus contaminants.
Although both systems would usually remove all viruses, only the
irrigation system is considered reliable in this respect. Other differences
are as follows:
1.	The activated sludge aystem is far more susceptible to
failure resulting from accidental spillages of industrial
wastes which are toxic to the bacteria which are essential
to this process.
2.	At flow rates in excess of 67. MGD, the activated sludge
process may not achieve the required degree of treatment,
whereas the irrigation system would achieve full treatment
up to 88 MGD.
chlorination of effluent from the activated sludge process
Is assumed to take place just prior to discharge of the
effuent into the effluent into the Muskegon River. The
Quirk, Lawler and Matusky Report^- identified the potential
need for high levels of chlorine oxidation potential of
the high COD effluent of the combined S.D. Warren and
domestic waste. This may at times cause problems to fish
in this area. On the other hand, chlorination of effluent
from the lagoon process takes place before irrigation, in-
suring that there can be no chlorine in the water discharged
to streams.
llbid.
M60

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COSTS OF THE ALTERNATIVE SYSTEMS
Aerated Lagoons plus Irrigation
The capital cost of this system, based upon
and specifications, is estimated as follows:
1.	Clearing and site preparation
2.	Drainage pipes and wells
3.	Drainage ditches and pumping stations
4.	Irrigation piping and pumping
5.	Irrigation Equipment Test Program
6.	Irrigation machines
7.	Electric power distribution
8.	Force main to site
9.	Pumping station to site
10.	Lagoons and treatment facilities
11.	Miscellaneous buildings and equipment
12.	Access pumping stations and force mains
Subtotal
13.	Land
Subtotal
14.	Engineering and administrative costs
Total
detailed plans
MS?ooo
2,763,000
1,098,000
2,695,000
542,000
1,500,000
791,000
4,700,000
1,350,000
,6,302,000
325,000
5,373,000
$28,364,000
3.200^000."
$31,564,000
3,000,000
$34,564,000
fluskegon-Costs
M61

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Note that the items numbered 1 through 7 may be considered to De
permanent investments in agricultural production, remaining valuable
even if the waste water treatment process should become obsolete.
The operating costs of the aerated lagoon plus irrigation
system for the 1982 mid-point year flow of 35 MGD are estimated as
follows:
OPERATING COST OF COUNTY WASTEWATER
TREATMENT SYSTEM
Lagoon Treatment System
Labor
Superintendent - 1	$ 20,000
Operators - 7 @ $12,000	84,000
Electrical and Mechanical Maintenance -
4 @ $12,000	48,000
General Maintenance -30 $8,000	24,000
Laboratory
Director	18,000
Assistant	22,000
$ 216,000
Overhead 30%	64,000
Subtotal	$ 280,000
Electrical Power
Lagoon Aerators and Mixers	100,000
Misc. other Utilities	25,000
Equipment and Facilities Maintenance and Repair	70,000
Chemicals - Chlorine Disinfection and Misc.
other Chemicals	90,000
Sludge Application to Land - 520 tons/day @ $l/ton	190,000
Lagoon Treatment Total	$ 755,000
MUSKEGON - COSTS
M62

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Irrigation and Drainage System
Labor
Supt. of Operations	$ 17,000
Irrigation Rig Operators - 10 for 8 mo.
0 $800/mo.	64,000
Irrigation Rig Maintenance - 4
0 $10,000	40,000
Irrigation Site and Drainage System
general maintenance - 3 0 $9,000	27,000
Overhead 30%
$ 148,000
45,000
Subtotal	$ 193,000
Power
Irrigation Pumping Station	70,000
Drainage System Pumping	20,000
Equipment Ilaintenance and Repair
(Irrigation Rigs, Drainage System,
Irrigation and Drainage Pumps)	100,000
Subtotal	$ 190,000
Irrigation Total	383,000
Treatment System Total	$1,138,000
Spread over the 1982 average flow of 35 MGD, these costs work
out to be about $90 per million gallons. No credit is taken
for possible return from crop production.
M63

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Two-stage Activated Sludge with Chemical Treatment plus Filtration
The capital cost of this system is estimated is follows:
Treatment Plant
Preliminary Treatment (screening, grit removal,
metering)
Primary Sedimentation Basins
High Pate Activated Sludge Aeration Tanks
Activated Sludge Settling Basins (including
return sludge pumping facilities)
Nitrification Aeration Basins
Nitrification Settling Rasins (including return
sludge pumping facilities)
Lime Clarification Basins and Equipment
Lime Recalcination
Mixed-Media Filtration Facilities
Sludge Thickening Tanks
Sludge Digestion and Hoiking Tanks
Sludge Transfer Facilities (rail or truck loading)
Chlorination Facilities (equipment and contact tank)
Yard Piping and Electrical
Control and Laboratory Building
Site Preparation
Outfall
Site Acquisition
Subtotal
Collection and Transmission Facilitics
'Iain Transmission Pumping Station (C)
66 ' Pipeline
Access Pumping Stations and Force Mains
Subtotal
Engineering and Administration Costs
Project Total
M64
$ J35Qw000
1,150,000
1,150,000
1,600,000
1,500,000
1,900,000
3,300,000
2,300,000
2,000,000
500,000
A,050,000
200,000
200,00
2,000,000
300,000
500,000
200,000
400,000
$23,950,000
1,200,000
1,640,000
5,373,000
$^£,213,000
3,000.000
$35,163,000

-------
This capital cost is not based upon an actual detailed set
of plans as was the case for the alternative system. By way
of comparison, the Salt Creek Sewage Treatment Plant of tne
Metropolitan Sanitary District of Greater Chicago has a
design average day capacity of 30 MGD and 50 MGD peak day
capacity. Phosphorus removal, nitrification and filtration
facilities are provided. However, the lime settling process
was not Included. The Engineer's construction extimate for
just the treatment plant was $24,000,000 in 1968 when the
Engineering News Record (ENR) cost index was 1300. The pre-
sent index is over 1600. This cost estimate does not in-
clude engineering, land or collection and transmission
sewerp
The operating cost of the two-stage activated sludge
system with lime settling and filtration is estimated for
the 1982 mis-point flow of 35 MGD as follows:
Primary sedimentation, carbonaceous
an nitrification activated sludge
treatment, and sludge digestion
Lime Battling and recalcination
(lime recovery)
Replacement Lime
(Continued)
Unit
Cost
$65/mg
$30/mg
$ 5/mg
Amount
35 MGD
35 MGD
35 MGD
Total
Annual
Cost
$830,000
380,000
60,000
M65

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Filtration (mixed media)
/Chlorine disinfection
Digested sludge haulage for
~ land application
-Unit-
$25/mg
$ 5/mg
$ 3/ton
-Amount
35 MGD
35 MGD
Total Annual
Cost
320,000
60,000
Total Annual Cost for 19S2 Flow
*Blue Plains would produce 4,900 Tons per day of sludge t
SUMMARY
The proposed aerated lagoon plus irrigation system is not only superior to
the activated sludge plus filtration system in terms of reliability and degree of treat-
ment, it also costs a great deal less. Table 2 shows the savings in cost to all tax-
payers, and Table 3 shows the saving to the taxpayers and users in Muskegon County
alone with and without returns from crop production.
It is obvious that wastewater irrigation systems are applicable to many othe r
locations in this country and that they are likely to become widely used. Evidence
of this trend is already at hand in the current studies by the Corps of Engineers,
the Environmental Protection Agency, and many consulting engineering firms. The
"ability of soil-plant svstems to receive, hold, and selectivelv utilize troublesome
MUSKEGON TOTAL COSTS
M66

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pollutants such as nutrients, viruses and heavy metals is gradually
coming to be recognized as a largely untapped resource in the effort
to control water pollution. Rejections of such pollutants into the air
and water is becoming less acceptable. Use of land as the ultimate
place of disposal and utilization is the only apparent alternative.
Fortunately for us, the potential capability of soil-plant systems to
handle these pollutants without adverse effects is very large compared
to the size of our problem, and the cost of using these systems as part
of the pollution control process is less than persently available alter-
natives .
M67

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TABLE 2
COMPARISON OF COSTS OF SYSTEMS
Cost Component
Two-stage
Activated
Sludge With
Chemical
Treatment Plus
Filtration
Aerated
Lagoons Plus
Irrigation
Capital cost, including
land, access system pumping
stations and force mains,
engineering and administration $35,163,000
Annual capital cost,
assuming 20 years 0 5%
Annual operating cost
Total annual cost
2,821,000
2,260,000
5,081,000
$34,564,000
2,773,000
1,138,000
3,911,000
Annual Savings with
Aerated Lagoon
Irrigation System = $1,170,000
Total Savings over 20 years = 20 x $1,170,000 = $23,400,000
MUSKEGON - COST COMPARISONS
M68

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TABLE 3
COMPARISON OF COSTS TO RESIDENTS OF MUSKEGON COUNTY
Two-stage
Activated
Sludge With
Chemical
Treatment Plus
Cost Component	Filtration
Construction costs eligible for
State and Federal grants
(land excluded)
Local share (§> 30%
Land costs
Subtotal
Capitalized interest (16.7%)
Facilities acdjqisition
Total Local Project Cost
Annual Capital Cost
20 yr @ 5%
Annual Operating
$ 34,767,000
10,430,000
400,000
10,830,000
1,808,000
300,000
$12,938,000
1,038,000
2,260,000
Total Annual Local Cost $ 3,298,000
Aerated
Lagoons Plus
Irrigation
$31,364,000
9,909,000
3,200,000
12,609,000
2,106,000
300,000
$15,015,000
1,205,000
1,138,000
$ 2,343,000
Annual Charges to
Residents	(1)
Annual Charges to
Industries (1)
Annual Charge per family of 4
(130,000 people presently in
service area)
Reduction in charge per family
with $300,00 per year return
from agriculture
1,568,000
1,730,000
48.25
1,226,000
1,117,000
37.72
4.50.
(1) Based on industrial/residential flow ratio of 60/40 with 40% of
capital costs reaovered by user fee and 20% of acreage charge assignee
to industires.
Muskegon - Costs to Residents
M69

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REFERENCES
1.	The Metropolitan Sanitary District of Greater Chicago, Report on
Salt Creek Water Reclamation Plant by Camp, Dresser & McKee,
» Boston, Massachusetts, January, 1968.
2.	U. S. Department of the Interior, Federal Water Pollution Control
i Administration, Cost of Wastewater Treatment Processes by Dorr-
Oliver, Incorporated, Taft Water Research Center, Cincinnati, Ohio,
December, 1968.
3.	U. S. Department of the Interior, Federal Water Pollution Control
Administration, Cost and Performance Estimates for Tertiary Waste-
water treating Processes by Robert Smith and Walter F. McMichael,
Taft Water Research Center, Cincinnati, Ohio, June, 1969.
4„ Quirk, Lawler & Matusky Engineers, Laboratory Scale Treatment
Studies, for S. D. Warren Company, New York, New York, July, 1969.
5.	Hackett, James E. and Dumper, Thomas A., in association with John
R. Sheaffer & Associates, Environmental Characteristics; A Study of
Muskegon County Official and Subterranean Physical Characteristics
and their Implications Upon Land Development and Resources Manage-
ment Opportunities, Wheaton, Illinois, August, 1970.
6.	U. S. Department of the Interior, Federal Water Quality Administration,
Engineering Feasibility Demonstration Study for Muskegon County,
Michigan Wastewater Treatment Irrigation System, Water Pollution Con-
trol Series Report 11010 FMY, Washington, October, 1970„
7.	Muskegon County Board and Department of Public Works, prepared by
Bauer Engineering, Inc., Muskegon County Wastewater Management
System Number One, WPC-Mich-1503 and Environmental Protection
Agency Demonstration Project 11010 GFS, Environmental Assessment
Report, Muskegon, Michigan, March, 1971.
8.	Bauer Engineering, Inc., for Federal Water Quality Administration.
Muskegon County Wastewater Management System Demonstration Grant
11010 GFS Detailed Work Program and Special Conditions, Chicago,
Illinois, March, 1971.
90 Bauer Engineering, Inc., Muskegon County Wastewater System No. 1,
Basis of Design, Chicago, Illinois, March, 1971.
M70

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BATIiLLE LAB April 26, 1971
Table 13-9 (Continued)
ft**********************;/!:**
Factors: Blue Plains x 41.1
Units
Costs at
Blue Plains
Iluskegon x 5

7.5 rjgd
equivalent
A A A * A A A ft ft ft ft
* * *
* * * *
* * * ft *
Electricity
$/day
321.26

Natural Gas
$/day
322.72
13,162
Chemicals (Alum and polymer)
$/day
273.99

Chlorine
$/day
13.28

Make-up Lime
$/ day
233.00

Make-up Carbon
$/dav
24.63

Operational Labor
$/day
426.00

Maintenance Labor
$/day
97.40

Repair Materials
$ / day
100.10

Total Cost per day
$/day
1,814.42

Total Cost per MG plant influent
$/day
242.76

Note: Multiply right column by 41.1 to get costs of Blue Plains:
Multiply by 5.0 to get costs nf Muskegon AWT plant
N.B. In winter fuel shortages will pose crisis situation
M71

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TABLE 13-9 (Continued)
Units
Costs at 7.5 MGD
Flow
RGANIC SLUDGE TREATMENT
1 and DEWATERING


Electricity
$/daj
16.63
Chemicals —Polymer
$/ day
193.53
Operational Labor
$/ day
26.75
Maintenance Labor
$/day
26.08
Repair Material
$/day
49.65
Total Cost per day

312.66
Total Cost per MGPlant Influent

41.68
Total Cost / Ton Dry Solids
$/ton
17.66
LTION and DISPOSAL


Electricity
S/day
5.90
Natural Gas
$/day
138.71
Operational &bor
$/day
17.84
Maintenance Labor
$/day
13.36
Repair Material
$/day
1.50
Total Cost /Day
$/ day
177.32
Total Cost per MG Plant Influent
$/MG
23.64
Total Cost per ton Dry Solids
$/Ton
10.01
M72

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Table 13-9 (Cont.)
*********** *******************************************************
*********************************
fiRGANIC SLUDGE TREATMENT
******** * * * *
HANDLING AND DEWATERING
************
UNITS
Costs at
7.5 mgd
Flow
Operational Labor
MAINTENANCE LABOR
REPAIR MATERIAL
TOTAL COST PER DAY
ELECTRICITY
CHEMICALS - BOLYMER
$/day
$/day
$/day
$/day
$/day
$/day
16.63
193.53
26.75
49.65
312.66
41.68
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The experience of Metro Denver para 1leIs in many ways the collective experiences of
of the cities contacted.
AIR POLLUTION PROBLEMS
The gas cleaning system is a wet scrubber whichmes designed to produce a stack gas
meeting the air pollution standards that were then in effect. The scrubber was
intended to result in a particulate concentration of not greater than .3 grains
per cubic foot at standard conditions. The specifications also provided that no smoke
exceeding 40 per cent opacity (Ringleman No. 2) was to pass from the stack. The
governing regulatory agency is the Colorado Department of Public Health. This de-
partment has notified the District than on several occasions the stack has been
observed to exceed standards and that they have never observed the stack to be in
compliance with State regulations. The Air Pollution Variance Board ordered the
District to show progress toward controlling air contamination to within the State
standards. Later, the Board issued a conditional variance requiring the District
to limit incineration to only half of the sludge produced, the remainder to be
hauled away.
Effective March 15, 1971, air pollution control standards, as provided by the Air
Pollution Control Act of 1970, will become effective. Under these standards, sta-
tionary sources shall not emit a density which will obscure an observer's vision in
excess of 20 per cent opacity. In addition, these standards provide a maximum limit
of .2 grains per cubic foot corrected to 12 per cent CO2 concentration. Water slot
manifolds were added to the scrubbers to increase particulate capture. Test results
indicate that the District was not, and is not now, in compliance with present State
standards. The District is presently awaiting consultant recommendations regarding
plans and specifications for additbnal air pollution controls.
The Denver area has experienced increasingly serious atmospheric contamination.
Aside from the legal restrictions to air pollution, the residents now recognize the
practical desirability of air pollution abatement.
Denver Metro
M74

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It is known that equipment can be added to remove particulate matter from stack
gasses, as required. However, the incineration of sludge produces sulphur and nitr
gen oxides which are also undesirable. The technology for removal of these fractio
(either from gasses or sludge) is not yet well developed - and probable costs are
unknown.
OPERATIONAL EVALUATION
The past Metro accounting procedures have not been adequate to permit segregation
of the unit costs of various sludge disposal and treatment processes. The total
sludge disposal system costs have included concentration, filtration, incineration,
pumping, etc. so that it is impossible to specifically determine the costs of in-
cineration only. These total costs have averaged about $57. per ton of dry solids.
Recently, the staff has placed into operation an accounting system which will pro-
vide feedback as to the unit cost of each individual operation.
For budget purposes, the staff has analyzed all of the past costs and made an
estimate of future unit costs. During 1972, it is projected that the operation and
maintenance cost of the incineration system only (including the ash lagoon) will
be $727,000. This cost relates to a total sludge load of 36,865 tons of dry waste
solids. The resulting unit cost is $19.70 per ton. Note that this cost does not
include capital or operation and maintenance costs for future air pollution control
corrections.
Tor comparison, the historic and projected and estimated costs for sludge haul-off
ire presented following. The sludge now hauled off is identical to that incinerated
jeing the discharge from the vacuum filters. The 1970 costs for sludge haul-off.
Including disposal site preparation work, amounted to approximately $24.80 per ton,
lote that this was contract work, so the $24.80 per ton, includes all costs, includ-
ing capital amortization. Recently, a new method of site handling and spreading has
>een adopted which will cut disposal site costs. Also, the 1970 figure was
:or disposal at the Lowry Bombing Range, which caused a 54- mile round trip
Denver Metro
M75

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haul distance. Projecting these figures to 1972 for comparison purposes, it is
estimated that the total costs of sludge haul-off to the Lowry site would be $23.50
per ton of dry solid*. A closer site is being investigated, and, if approved,
would result in an estimated cost of $17.50 per ton of dry solids. The closer site
involves a round trip haul distance of 28 miles. Again, these figures represent
totals cost, including operation, maintenance, and capital amortization.
Based on past costs and estimates of future costs, the Metro staff put together
(January, 1971) an approximate projection of costs of the various methods of sludge
disposal. The relative cost estimates are indicated on Figure 3 following. This
curve indicates cost ranges specifically applicable only to the Metro Denver situa-
tion. This analysis did not contain input from outside design consultants - so that
later optimization of each system design could change relative costs. The curves
were intended to provide economic basis for selecting alternates reasonable for
further consideration.
Alexander Potter Associates presented a report on Disposal of Sludge by Beneficial
Recycle to Soil, dated February 25, 1971. This report included cost comparisons of
various sludge disposal plans which are summarized in the following table.
Sludge Processing and Disposal Plan
Summation of 10-Year Costs
1972-81 Period
I Digestion with beneficial
recycle to land
$22,671,000
II Incineration with digestion of
all sludges
$30,600,000
III Incineration with sludge digestion
except for raw Metro primary
sludge
$29,177,000
IV Incineration without digestion
of Metro sludge - but assuming
"Optimistic" operating results
$24,641,000
Denver Metro
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^ - - i /rKKri/Aimoic m-fear IQTfrj IQSC
j $3M Hfl.t •
! $25*4 Hit - -
' J2
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STUDY CONCLUSIONS
1.	Incinerators (at least those serving larger plants) should be designed to dis-
pose of sludge at the produced rates; that is, storage should not be assumed
to reduce the peak incineration capacity.
2.	Incineration systems must have adequate excess capacity to compensate for actual
attainable utilization rates. At Metro Denver, the past attainable utiliza-
tion factor had been less than 70 per cent.
3.	The incinerator stack discharges have not been in compliance with State of
Colorado air pollution regualtions. Equipment can be installed to control the
emission of particulate matter, but present technology does not offer proven
methods for control of the sulphur and nitrogen oxides which are produced. Since
air pollution control standards are becoming (rightly) more restrictive, good
incinerator design must solve the sludge disposal problem without creating an
air pollution problem.
4.	Applicable to the Metro Dever plant, preliminary cost and results comparisons
indicate that other sludge disposal methods merit detailed consideration for
use.
M78

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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: POTOMAC ENFORCEMENT CONFERENCE
November 11, 1971
Mr. Chairman:
My name is John Winder, and I am the Executive Director of the
Metropolitan Washington Coalition for Clean Air. I appreciate this
opportunity to bring to your attention the intense interests and
concerns of this environmental polity and to comment on the Potomac
Enforcement Conference.
The Coalition for Clean Air is a non-profit corporation, spon-
sored by the D.C. Tuberculosis and Respiratory Disease Association.
Our membership includes approximately 800 individual citizens and
over 90 civic, conservation, health, labor, and other organizations
throughout the National Capital metropolitan area. We are fully
committed to a policy of citizen education and citizen action to
insure the development and enforcement of a strong, effective air
pollution control program in the entire D.C. metropolitan area. We
sincerely urge the Environmental Protection Agency to respond to and
reflect this growing citizen concern.
EPA was established to provide a coordinated federal effort to
deal with inextricably related environmental problems which heretofore
had been monitored on a piecemeal, shotgun basis. It is ironic, there-
fore, to consider the proposed Blue Plains sewage treatment facility in
the context that water pollution problems may be reduced while air
pollution problems may be increased.
M79

Aimittad with th» Dlttrlct o I Columblt Tub*reulo*lt tnd Ruplnlory Dlitui Auoolatlon

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MWCCA
Potomac Enforcement
Conference
November 11, 1971
page 2
In this context, we are particularly concerned about the proposed
facet of this facility which would incinerate large quantities of
sewage sludge. This disposal method is clearly inconsistent with
the efforts of many municipalities across the country which have
rejected the outmoded concept of incineration for solid waste disposal.
In the specific context of sewage treatment and disposal, a total
biological treatment and recycling pattern, as is currently being
designed in a treatment facility in Muskegon, Michigan, is a far more
practical, economical, and environmentally protective method than
incineration.
In conclusion, we urge EPA to provide, at the very least, a
comprehensive environmental impact (102) statement on the potential
air pollution impact of the Blue Plains facility, including an analysis
of the potential impact the increased air pollution will have on the
ambient air quality standards for the National Capital Interstate Air
Quality Control Region, and including a comprehensive analysis of
feasible alternatives to incineration and any other sources of increased
air pollution from this facility.
M80

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TAHDE B-l
ADDENDUM TO INDUSTRIAL REPORT #231*09
Subject: Stack sampling and analysis for Los Angeles County APCD, Rule 53 Compliance
Name of firm:
Location of Plant:
Equipment tested:
Date tested:
SUMMARY SHEET
BSP Corporation
South Lake Tahoe, California
Multiple hearth sewage sludge incineratorj effluent from wet
scrubber
November 10, 1970
Test A Test B Test C
780
Process weight lb/hour wet: 88$ H^O
Sample station: One sampling port in the
13 in. cylindrical duct between sly impinjet
crubber fan and the outlet stack
750
Time of Test:
Begin
End
Elapsed time (min.)
11:06
12:06
60
2:01
3:0CL
60
w
3:la
-Usiil
60
Gas volume SCFM
Stack Temp. °F
Material Collected:
Grains /SCFM
Grains/SCFM 12$ CO2
Weight (grams) first thimble
second thimble
third thimble
813
70
.011
.026
.am
.002
oOOO
902
70
.009
.Oil;
.am
.001
.000
952
70
.010
.am
.am
.001
.000
Total
.016
.015
.015
Percent moisture in gases
2.8
2.8
2.8
Gas analysis (dry basis)



Percent CO 2
5.2
7.7
8.U
Percent O2
10m
9.6
9.6
Oxides of sulfur (as SO2)
2.2
2.3
3.2
Oxides of nitrogen (as NOg) ppn

(f&)
—
^Allowable standard only 5*0 PF®1
Battelle Labs Report to Congressman Vander jagt pm Tahoe Multihearth Incinerator
M81

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"Muskegon Plan for Managing Waste Water"
PUBLIC HEALTH ASPECTS
The capability of soil as a biological filtering medium for the removal of
bacteria is a long recognized principle utilized in septic tank disposal systems
and in the sand filtration of raw water supplies. Studies in conjunction with the
Santee reclamation project in California have demonstrated the great ability of a
biological soil system to also effectively eliminate viruses. The following find-
ings from this study as reported by McGauhey^" document this capability:
VIROLOGIC TESTS CONDUCTED IN THE
PERIOD 1962 - 1964 AT THE SANTEE PROJECT
(a)	Samples of raw sewage, primary effluent, and
activated sludge effluent were 100 percent
positive. (Thirteen different viruses were
identified.)
(b)	Effluent from oxidation pond (30 days detention)
showed 30 percent of samples positive.
(c)	Recreational pond influent, after 2,500 ft. in
soil system was 100 percent negative.
In 1964 a special study involving the introduction of attenuated polio virus
2
in the water reaching the spreading ground was conducted. Sampling wells were
located at distances of 200, 400, and 1,500 ft. down the wash. No virus was re-
covered at any of the sampling wells. These data provide effective documentation
that soil systems are capable of removing viruses.
^P.H. McGauhey, Engineering Management of Water Quality (New York: McGraw-Hill
Book Co. , 1968) .
2
Microbiological Content of Domestic Waste Waters Used for Recreational Purposes,
California State Water Quality Control Board Publication 32, 1965.
C-37 Document E - Study of Viruses
Study by Bauer Engineering, Inc., Chicago, 111. 60606
M82

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Gas Company
Limits Sales9
Cites Shortage
By William H., Jones	^
Washington Post Staff Writer
Washington Gas Light Co. announced yesterday that
new sales of gas, "for an indefinite period of time," will
be restricted to single-family residences.
Citing a.severe shortage of natural gas throughout the
nation, Washington Gas said the drastic new policy is
the only method by which it can assure adequate service
Jr present customers.	E ou a p
The ban on new sales ap-	spokeBsman) said the electric
lies to businesses, industry,	may ^ave t0 revised up-
overnment and apartment	d jts jected needs for
ouses. Washington Gas had	added electrieal outmit
aken action in April, 1970, to	Competition
^ Tcvv business turned away
ustomer pe'r day	? * ^hmgton Gas will likely
That earlier limitation af- 'b®K*£eS®, havp
ected onlv the bieeest Doten- Similar -gas limitations have
ial users of Ltifr!fias-an been imPosed by utilities in
partment project the Le of Penns*lva.nif' 0hi°^ N^. Jer'
he Watergate, for example, or	Michigan and Illinois;
huge government office f me firms have waiting lists
l t,	for all new customers. In New
[Tucuire	York State, the Public Service
Yesterday s decision affects commission recently ordered
lost apartment projects and uyjties to give residential
usinesses—from laundromats customers first claim.
3 department stores. Wash-	Shortage of gas supplies
igton Gas said it will main- j,as {jeen a source of sharp
a:n commercial customers controversy surrounding the
resent usage although there na[Ural gas industry for sev-
m be no expansion in such grai years. As Paul E. Reich-
;rvice.	ardt. Washington Gas presi-
The gas utility has made sig- dent) pointed qut yesterday,
ificant inrfrads in recent "here's plently of natural gas
ears into the electric utility's in ground."
ominance as the supplier of Producing the gas is an-
jel for apartments and of-
ces; for example, in 1970, 29 ,cther problem. Generally, na
er cent of new apartments Iural gas firms have taken the*
ere contracted for gas air	M
anditioning instead of elec-
position that they are not al-t
...	, . ,	lowed to make enough mone>
^ty, UP from about zero a from their output and hay£|
a a. the Americaj
r - conditioners. The rest of	^jas Association. But a con
le year, Pepco s expensive	sumer group the American
juipment is not used to full	pufoijc Gas Association, has
ipacity. With more efficient	charged ^ <.aileged.. shor.
se of generators, Pepco offi-	tagei are based on "unveri-
irs argue, rates for consum-
es can he kent lower.
fied" industry reportst and
that industry might have un-
derstated reserves by as much
as one-third in .some recent
rate cases.
In a series of major rulings
this year, the FPC has/raised
the rates . producers may
charge pipeline.companies for
natural gas^Jroduced in most
regions df the nation.
In a key July decision on
production in the southern
Louisiana area—a source for
some Washington^ area gas—
the FPC said there was a "crit-
ical shortage" and that the
higher rates were necessary to
encourage producers to find
and make ready gas reserves'
for sale in the U.S.
In any event, the major sup-
plier to Washington Gas—Col-
umbia Gas Transmission Corp,
—announced last month it
would be able to supply only
enough gas to serve present
customers and a "portion" of
normal growth. Another local
supplier, Transcontinental Gas
Pipe Line Corp., has been un-
able to deliver as much gas as
Washington Gas contracted
for, said Reichardt
"Faced with this situation,"
the gas company president
continued, "we're doing what
we consider the fairest thing
... commercial and industrial
buildings can more readily use
substitute fuels, and large
userg can better arrange for
the pollution control devices
which other fuels often re-
quire."
iUthough the limitation is
bound to have an "adverse"
impact on the utility's growth
projections, said spokesman
Jack Raymond yesterday, the
D.C. utility won't be affected
as much as gas companies in
industrialized centers since
some 80 per cent of Washing-
ton Gas volume is already
from residential customers.
Reichardt said yesterday
that in an "ecology conscious"
society, the "clean-burning
qualities of natural gas make
it a premium fuel ... ironi-
cally the big jump in demand
. . . has come at just the time
when new supplies are trend1
ing downward."
The reduced availability,
Reichardt charged, resulted
"largely because prices of nat-
ural gas in the producing
fields in the past have been
kept unreasonably low by reg-
ulation."
Last August, .Washington
Gas took another interim step
to discourage new business-by
declining to give a special rate
for commercial custodiers who
agree to forego us0 of gas
when demand from qther cus-
tomers is at a peak.
All sources of energy—oil,
gas, electricity, coal—in the
U.S. have faced increasing de-
mands in recent years, and
quite often demand has ex-
ceeded the supplj-~not always
because there is 9 lack of re-
sources but often because of
lagging production.
One result has been concen-
tration on the potentials of nu-
clear power as a future major
energy source. But fears of
the radiation effects of nu-
clear generating stations have
slowed development in that
sector. Electric utilities—
which halted long-term coal
purchase accords, severely
crippling that industry's fu-
ture plans—are now express-
ing more need for coal.
I"
*
£
t
£
M33

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7 December 1971
On paj:e 7 of Mrs. Apnew's statement of 10 November to the
Potomac Enforcement Conference is the following: "...I under-
stand froir. the Corps that there are several acceptable sites
well within the rar.pe of pumping capability and for which
technology is presently available.11
At a meeting at the Chesapeake Field Station, Annapolis, Md.
with Johann Aalto and others on 6 December 1971, Mrs. Af.new
stated that she had inside information that the Corps was
considerinp sites for spray-irrigation in the metropolitan
Washington area. She refused to pive the source of her
information.
SEE ATTACHED REGARDING THE ADOVE.
M84

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copy
DEPARTMENT Or THE ARMY
Baltimore District* Corps of Engineers
P.O. Box 1715
Baltimore, Maryland 21203
MA5PL-P	7 January 1972
Mrs. Elizabeth Hartvell
Board Member
7968 Boiling Drive
Alexandria, Virginia 22308
Dear Mrs. Hartwell:
Colonel Prentiss has asked me to reply to your letter of 7 Decem-
ber 1971 requesting information on site studies in the metropoli-
tan area of Washington, D.C., for waste water disposal systems
using the spray irrigation process.
I repret that I am not able to furnish you this information. The
Corps of Engineers is not involved in this activity, and I have
no additional knowledpe on these studies.
If I can be of further assistance, please feel free to call me.
Sincerely yours,
/s/ William E. Trieschman, Jr.
WILLIAM E. TKIESCHMAN, Jr.
Chief, Planning Division
M85

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COPY
COMMONWEALTH Or VIRGINIA
STATE BOARD OF AGRICULTURE AND COMMERCE
7968 Bollinp Drive
Alexandria, Va. 22308
January U, 1972
Colonel Louis V/. Prentiss, Jr.
District Enpineer
Corps of Engineers, Baltimore District
Departnent of the Army
P.O. Box 1715
Baltimore, Kd. 2170 3
Dear Colonel Prentiss:
I understand that the Corps of Enfineers is presently
conducting studies of sites in jurisdictions nearby or adjacent
to the District of Columbia for the purpose of determining
their suitability for the spray-irripation process connected
with the land-contained waste water disposal system. I further
understand that this process, if applied, would involve spray-
irrif-ation of farmlands.
I would appreciate your informing me of the location and
size of Virginia sites under consideration, the assessment value
of the land, whether or not the present owners have been contacted,
and if the sites are workinp, farms cr vacant land,
I would appreciate your sending me this information, and
any other pertinent data, as scon as possible.
Sincerely yours,
(Mrs.) Elizabeth Hartwell
Board Member
M86

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January 12, 1972
Re: rumored site study of spray irrigation of sewage effluent
in the Washington metropolitan area.
"There are no studies of this sort beinp conducted in the D.C. area
by the Baltimore District" of the U.S. Army Corps of Enpineers.
—Ronald Cucino, asst. to Col. Prentiss, District Chief
(301-962-46146)
Information obtained from Irwin Raisler, chief, Planning Division,
Office of the Chief of Enpineers, Forrestal Building: (OX-3-7251)
There are five studies of waste water management being conducted
throuphout the country which include spray irrigation as one factor,
but none are beinp conducted in the Washington metropolitan area and
none have anythinp whatsoever to do with Blue Plains. They are:
Cleveland, Detroit, Chicapo, San Francisco, and the Cadoras Creek
area of the Susquehanna River Basin.
These studies are being conducted in cooperation with the states
involved. Consideration is being piven to a combination of land and
water disposal methods. They are lookinp for a total system. This
is basically the message of S. 2770 (the Muskie bill), which states
no discharge of pollutants by 1985. Even with AWT, there is some
miniscule amount of contamination, so they are looking for a possible
method to eliminate it — "ASSUMING THE RIGHT KIND OF SOILS. It has
never been tried on a larpe scale, such as with the D.C. plant."
For more information, Raisler says to call Robert Gidez, asst.
chief, Planning Division, OCE, OX-3-0039.
At EPA, Ken Mackethum, chief of Applied Technolopy proup, says there
is no such study beinp conducted in the Washinpton metropolitan area.
M87

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7968 Boiling Drive
Alexandria, Va. 22308
February 13, 1972
Miss Linda Upton
Air £ Water Program Div.
Environmental Protection Agency
Region III
6th £ Walnut Sts.
Philadelphia, Penna. 19106
Dear Miss Upton:
I understand that you are preparing an Environmental
Impact Statement (102) on the District of Columbia's Blue
Plains treatment plant.
I feel sure you have seen the statement made on 10 Nov-
ember 1971 by Mrs. Marian Agnew, president of the Northern
Virginia Conservation Council, to the Potomac Enforcement
Conference, in which Mrs. Agnew proposed to stop construction
of the Advanced Waste Treatment upgrading and expansion of
Blue Plains and substitute instead the still-experimental
land-contained spray-irrigation wastewater disposal system.
Enclosed is rebuttal documentation to show that this proposal
is technologically, financially and politically infeasible.
I would be very happy to furnish you with any other infor-
mation I may have on Blue Plains, Dyke Marsh, etc. Please
feel free to call on me.
Sincerely yours,
(Mrs.) Elizabeth Hartwell
Enclosure
¦ ¦	f. • |\! .1
/-/' k" -V itY'
, - -v - '
M88

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Regarding the statement to the POTOMAC ENFORCEMENT CONFERENCE by
MARIAN K. AGNEW, President, NORTHERN VIRGINIA CONSERVATION COUNCIL,
of November 10, 1971:
FALLACIES IN MRS. AGNEWfS STATEMENT
(Summary - Documentation Attached)
A.	Removal of Viruses
No measurable viruses have been detected in treated effluent from
Lake Tahoe AWT plant.
B.	Incinerator Operating Costs
D.C. Department of Environmental Services states it would cost
$2.45 million (not $35.77 million as claimed by Mrs. Agnew)
annually to operate the incinerator, or a daily cost of $6,700.
C.	Air Quality Standards
There are no presently adopted Ambient air standards for NO., by
either the Federal government or D.C.	x
D.	Land Area Requirements
Total land area requirements at Muskegon are 10,000 acres - not
6,000. The 3 09 mgd generated at Blue Plains would require 7 3,600
acres or 115 square miles. The 1980 projected wastewater flows
for the metropolitan area (475 mgd) would require 113,100 acres
or 177 square miles - more than twice the area of D.C. and Arling-
ton County combined.
E.	"Primary capital investment in a land-based system is in land rather
than capital costs and plant construction. . ." Mrs. Agnew states.
Muskegon report states total cost of aerated lagoon plus irriga-
tion system is $34,654,000. Of this only $3.2 million is land
cost - or 9.3%.
F.	Failure to Acknowledge There are Other Treatment Plants in Metropoli-
tan Area
All of which increase land area required, size of pipelines, costs,
etc.
G.	Profits from Crop Production on Irrigated Land
Profits to whom - for what - how paid?
H.	Sludge Generated at Blue Plains
Amount of sludge will be 2,390 tons, not 4,920 claimed by Mrs.
Agnew
Water content will be 82%, not 60% claimed by Mrs. Agnew.
I.	What is the Land-Sewage Ratio of 130 Acres per MGD?
Source? Muskegon is a 42 mgd plant occupying 10,000 acres - 238
acres per mgd.
J. Assumption that the Federal Government, District of Columbia, Mary-
land and Virginia all would be willing to scrap years of negotia-
tions, planning, engineering studies, contractural agreements, etc.
and to "start in 1971" on a completely different concept to "have a
clean Potomac by July, 1976."
Present program calls for advanced treatment at Blue Plains in
operation by 1974-
M89

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DOCUMENTATION - Fallacies in Mrs. Agnew's Presentation
A.	Removal of Viruses
Mrs. Agnew said, Total elimination of viruses was considered
reliable only in the land based system."
Research is outdated - tests conducted in 1962-64.
Following is from a paper presented at the 1970 annual American
Water Works Association meeting. "Annual Capital and Operating
Costs for Advanced Waste Treatment," by David R. Evans, resident
engineer for Cornell, Howland, Hayes and Merryfield; and Jerry C.
Wilson, resident engineer for Clair A. Hill and Associates:
"Between 29 May and 2 Oct. 1969, nine sets of water samples (from
Lake Tahoe AWT plant) were collected and submitted to the Federal
Water Pollution Control Administration laboratory in Cincinnati
for virus examination under the direction of Dr. Gerald Berg.
Although viruses were found in the secondary effluent, all nine
tests of the reclaimed water after chlorination were negative
for virus. No virus has been recovered from the water being
exported to Indian Creek Reservoir in two summers of sampling."
B.	Incinerator Operating Costs
Mrs. Agnew has extrapolated from costs of Lake Tahoe incinerator,
directly relating them to Blue Plains.
The following figures were given by Paul Freese, D.C. Department
of Environmental Services:
incinerator operation Freese figures Agnew figures
annual	$2,459,000	$35,770,000
daily	6,700	98,000
Cost estimates for Lake Tahoe incinerator operation between
Battelle Laboratories (1971) and Evans-Wilson (1969) show gross
differences, which require careful research:
Daily Costs	Battelle	Wilson-Evans
electricity	$321.26	$189.73
natural gas	322.72	150.14
chemicals	273.99	94.12
total cost per day
per MG influent	$242.76	$137.59
C.	Air Quality Standards
Mrs. Agnew states several times that "the air pollution standard
of 5 ppm" for NO . We are unable to find any documentation for
this figure - either for stack emissions or ambient air standards,
which she seems to have confused. National ambient air quality
standards published by the Administrator of the Environmental
Protection Agency as prescribed by the 197 0 amendment to the Clean
Air Act are 0.053 ppm for primary standards. This national
standard refers to an annual mean or average in several cases (see
pp. 13 - 14, Virginia Air, published by the Virginia State Air
Pollution Control Board, Sept. 1971).
Mrs. Agnew refers to the 52 - 65 ppm stack emissions from Lake Tahoe
M90

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as being "unbelievably dangerous levels of nitrous oxides. .
Letter from Whitman, Requardt and Associates, engineers-consultants,
to Paul Freese, Director, D.C. Water Resources Management Admin.,
Nov. 23, 1971:
"There are no existing or proposed standards on the emission of
oxides of nitrogen from either refuse incinerators or sludge in-
cinerators. . . We believe the reported 52 to 65 ppm emission
levels of oxides of nitrogen reported to you represent test data
from only the Lake Tahoe plant using multiple hearth incinerators
without the control refinements included in the D.C. design.
While data from most sludge incinerators in this country show less
than 5 0 ppm emission rates on the oxides of nitrogen, the 5 2 to
65 ppm is a reasonable range of values. These values are less
than the planned limit of approximately 100 ppm set by the recently
proposed federal emission standards for fossil fuel fired boilers
as previously indicated. It is our belief that stack emission
levels of 52 to 6 5 ppm will not exceed the ambient air levels on
oxides of nitrogen being considered by the District of Columbia."
Los Angeles has one of the strongest emission standards in the
country. For 1971 this standard for stack emissions was 325 ppm.
Upgrading, to be completed by 1974, will produce an emission
standard of 225 ppm.
A report prepared by Frank P. Sebastian of Envirotech Corp. for the
Air-Water Subcommittee of the Citizens Advisory Committee on Environ-
mental Quality, entitled "The World of Sewage as a Resource" (Nov.
16, 1970), gives a description of the Lake Tahoe tertiary process.
It states:
"A significant step forward in compatibility of thermal reclamation
processes used at Tahoe was the development of exhaust gas cleaning
devices that cool and clean the gases so effectively that particulate
matter is hardly measurable. No visible plume has been reported, and
it is well within the most stringent air pollution codes. Normally,
however, the exhaust gases are returned to the system to utilize the
carbon dioxide to neutralize the highly-limed effluent following
ammonia stripping. The final product water is of high quality and
meets the U.S. Public Health Standards for potable water. . .
"The only waste product is a sterile, odorless ash from sludge in-
cineration that can be used safely as fill and is experimentally
being used for concrete blocks and bricks. The ash contains about
7% phosphate which was removed from the water but is in an insoluble
form and even then is potentially available as fertilizer. . .
While in the U.S. such ash has been used for land and road fill,
similar material - without any phosphate content - from the Odai
secondary sewage treatment plant in Tokyo, Japan, is sold for $1.3 5/
ton to a fertilizer manufacturer. In the U.S., research indicates
that the waste lime content would aid the freeze-thaw characteristics
of road fill. Also experiments at FWQA, Cincinnati, indicate the
insoluble phosphate in the Tahoe ash is beneficial as a plant
fertilizer."
Therefore this can be returned to the soil as well as watered
sludge.
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D.	Land Area Requirements
Mrs. Agnew neglected to include the land required for lagoons and
other purposes in her extrapolation of acreage from Muskegon to
Blue Plains.
Muskegon requires 6,000 acres of land for irrigation PLUS two
lagoons, buffer zones, border areas, etc., for a total of
10,000 acres.
Muskegon is also planned for 42 mgd, not 35, therefore her scale-
up factor of 8.8 was wrong on two counts. Corect factor is 7.36.
Using EPA projected wastewater flows for the metropolitan area in
their "National Capital Region Water and Waste Management Report,"
the following acreages would be required for the land contained
system:
1980 - 475 mgd flow - 113,100 acres or 177 square miles
2000 - 860 " " - 205 ,000 " " 320	"
2020 -1340 " " - 320,000 " " 500
E.	"Primary capital investment in a land based system is in land rather
than capital costs and plant construction. . Mrs. Agnew says.
The primary savings in the Muskegon plant seems to be in annual
operating costs, which 
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2020 - 1340 mgd @ 238/acres/mg - 320,000 acres
320,000 acres @ $3,000 - $960,000,000 principal
504,000,000 interest"
TOTAL	$1 ,**64,006 ,000
average annual cost - $ 73,200,000
All of these above costs would have to be borne by the taxpayers
of the local jurisdictions.
COSTS OF SPRAY IRRIGATION SYSTEM
Title
Muskegon
factor
Blue Plains
Clearing (1)
$ 925,000
7.4**
$ 6,845,000
On-site improvements



(2 - 7, 11)
9,714,000
7.4**
71,883,600
Force main to site (8)
4,700,000
7 4 ft ft ft
296,000,000
Pumping station to site (9)
1,350,000
7.4**
9,990,000
Lagoons S treatment



facilities (10)
6,302,000
7.4**
46,634,800
Access pumping stations



S force mains (12)
5 ,373 ,000
7.4**
39,760,200
Land (13)
3 ,200 ,000
ftftftft
220,626,000
Engineering S administration



costs (14)
3,000,000
7.4**
r 22,200,000

$34,564,000

$713,939,600
* - interest figured for 2 0 years at 5%
** - scale upward from 42 mgd (Muskegon) to 30 9 mgd (Blue Plains
&fta _ factor of 7.4 for sizing, plus factor of 10 for distance
ftftftft _ see analysis elsewhere
COMPARATIVE COSTS FOR SLUE PLAINS
Treatment Principal Interest	Total
(20 yrs. at 5%)
conventional AWT $359,000,000 $188,475,000	$547,475,000
spray irrigation 713,939,600 374,818,290	1,088,757,890
The spray irrigation-land contained system for Blue Plains would cost
almost twice as much as precently planned AWT process now under con-
sideration.
FAIRFAX COUNTY COSTS
(supplied by County Executive George Kelley)
If construction plans for Blue Plains were changed today, and imple-
mented tomorrow Fairfax County would still be committed to the follow-
ing charges:
1.	Pimmit Run trunk - $8,000,000 plus
2.	Capital contribution to Dulles Interceptor - $240 per million
gallons
3.	Increased cost for chemicals over next four years - $528,000
annually
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STORAGE FACT8 AND FIGURES
The Muskegon plant allows for storage of total flow for up to 4
months (120 days) for periods when it would be impossible to spray
effluent - due to freezing weather, rain, etc.
Storage for Blue Plains flown
309 million gallons per day for 120 days - 37,080,000,000
1 gallon equals .1337 cubic feet
37,080,000,000 gallons equals 4,957,596,000 cubic feet
The Fairfax Tower Building (12-storey county administration
contains 1,920,000 cubic feet.
Therefore: It would take 2,5 82 Tower Buildings to hold the
for 120 days.
21.5 buildings would be required to contain one dayis flow.
Or:
Muskegon lagoons are 9 feet deep. Similar capacity at that
for Blue Plains:
550,844,000 square feet or 12,645 acres.
This is 31%. larger than the City of Alexandria.
Or:
Total storage of Blue Plains flow for 120 days would cover Fairfax
County's 400 square miles to an average depth of 5.3 inches.
F.	Failure to Acknowledge There are Other Treatment Plants in Metro-
politan Area
See documentation #6 in Major Problems.
G.	Profits from Crop Production on Irrigated Land
Major agriculture in Delmarva is foodstuffs - do state and local
health codes permit use of human wastes on food crops?
Closer agricultural lands are primarily tobacco and dairy pro-
duction - do these lands need further enrichment?
K. Assumption that the Federal Government, District of Columbia, Mary-
land and Virginia all would be willing to scrap years of negotiations,
planning, engineering studies, contractural agreements, etc., and
to "start in 1971" on a completely different concept to "have a clean
Potomac by July, 19 7 6."
The first session of the Potomac Enforcement Conference was held
in Aug., 1957, and the second the following February, The third
session was in April and May, 1969, 11 years later. Since this
third session it has met many times, and finally, primarily due
to the efforts of the Virginia State Water Control Board, the
involved jurisdictions signed a Memorandum of Agrcomcnt (Oct. 197 0)
and a year later an Interim Treatment Agreement which/begins a
cleanup of the Potomac River in earnest.	U&Jb&JlST*
It has taken 14 years for these jurisdictions to resolve their
differences and reach a first agreement starting us on the long
road to a clean river. Dare we risk scrapping this hard-won agree-
ment and attempt to reach an understanding on a type of treatment
that is still in the experimental stage?
gallons
building)
flow
depth
MQ A

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MAJOR PROBLEMS NOT ADDRESSED IN MRS. AGNEW'S PROPOSAL
(Summary - documentation on following pages)
1.	Water Supply for Metropolitan Area
The metropolitan Washington area is faced with constantly in-
creasing demands for water. EPA forecasts "Single day deficits
(of water) of some magnitude will become a common occurrence by
1980-85."
This predicated on the building of upstream dams proposed by
the Corps of Engineers.
2.	Salt and/or brackish Water Intrusion Farther Upstream
If 30 9 mgd are removed from the Potomac estuary, there would be
a change in salinity of the downstream water.
What effect on the fishing industry?
3.	Pipeline for Estimated 100 Miles
Estimated cost for 100 miles is nearly a BILLION dollars.
Siltation - massive environmental problems in laying the lines
themselves.
Pumping Stations - how many watersheds and subwatersheds must be
crossed? Such stations cause operating costs to skyrocket.
4.	Soil Characteristics
Soils in the metropolitan area are not permeable, witness septic
problems in Fairfax and Prince Georges counties. Muskegon soil
is permeable sand 25 to 100 feet deep.
How far must we go to find similar soils?
5.	The Muskegon Plant is Not Yet in Operation
Will it work as anticipated?
6.	Other Treatment Plants Now Operating in Metropolitan Area
At present there are 13 plants in the area between Chain Bridge
and Gunston Cove. The Potomac River cannot be cleaned up until
these problems are solved, along with Blue Plains.
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DOCUMENTATION - Major Problems Not Addressed by Mrs. Agnew's Proposal
1.	Water Supply for Metropolitan Area
The Environmental Protection Agency's "National Capital Region
Water and Waste Management Report," April 1971, says, "Average
water demand for 1970 was 381 mgd and is projected to rise to
600 mgd by 1980-85 and 1500 mgd by 2010-2020.V
Every responsible proposal for future water supplies in the metro-
politan area is based on usage of the Potomac estuary, even those
advocated by the people who feel the upstream dams are a necessity.
Therefore water quality standards within the region have been set
extremely high by the Enforcement Conference - with absolute
poundage limitations rather than removal percentages - so that
the estuary water will be usable for water supply.
Mrs. Agnew stated in oral testimony at the Enforcement Conference ,
that the acreage required for the land contained system could
easily "be a trade-off - 52,000 acres" for the Muskegon approach
traded for 50,000 acres estimated to be flooded by the upstream
dams. Her implication seems to be that if we do not have sewage
effluent from Blue Plains in the river, we will not require the
upstream storage dams.
Following from transcript of Enforcement Conference proceedings,
Dec. 8-9, 1970 (pp 240-241) between Chairman Murray Stein and
Dr. Johann Aalto, Chief, Chesapeake Technical Support Laboratory:
Stein:	. .in spite of all the dams you are asking for
authorized in the upper estuary, we are still going to have to
use or have available the water below Great Falls in the estuary
for water supply in the metropolitan area during critical
periods."
Aalto: "In spite of the fact that seven dams are constructed
it will be necessary to use the estuary."
(Please see additional statement at end of this paper.)
2.	Salt and/or Brackish Water Intrusion Farther Upstream
Following is from Report 92-414, Senate Committee on Public Works,
regarding Sec. 209 - Waste Treatment Management - of the Federal
Water Pollution Control Act Amendments of 1971:
"The present Federal water pollution control program does not con-
sider degradation of water caused by reduction in fresh water flows
which produce the intrusion of salt or brackish waters into
estuaries and rivers. Salt water intrusion, no less than point
sources of discharge, alters significantly the character of the
water and the life systems it supports. Salt water intrusion
often devastates the commercial shellfish industry. It must be
accounted for and controlled in any pollution control program.
It makes no sense to control salts associated with industrial or
municipal waste point sources and allow, at the same time, similar
affects to enter the fresh water as a result of intrusion of salt
water. Fresh water flows can be reduced from any number of
causes."
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Following is from "Summary and Conclusions From a Water Resource-
Water Supply Study of the Potomac River Estuary," April 1971, pre-
pared by the Chesapeake Technical Support Laboratory, EPA:
"Data from the chloride, total dissolved solids, and other simula-
tions where the estuary was used as a potable water supply source
indicate the following:
"(1) The position of the salt wedge with respect to intrusion
from the Chesapeake Bay is a function of (a) duration and
magnitude of any selected flow, (b) location of the waste-
water treatment facility discharges, and (c) consumptive
losses in the water distribution system.
"(2) Even with no water supply withdrawals from the estuary, for
comparable flow conditions, intrusion of chlorides and total
dissolved solids from the Chesapeake Bay will occur farther
upstream in the future as a result of the greater percentages
of wastewater discharged downstream into the salt wedge and
the projected increase in consumptive loss, with the latter
having the most pronounced effect.
"(3) The number of days during which the estuary can be used for
water supply depends upon (a) the position of the wedge prior
to the withdrawal, (b) magnitude of the withdrawal, (c)
fresh-water inflow during withdrawal, (d) location of the
wastewater discharges, and (e) the increase in chlorides
and total dissolved solids as a result of water use."
According to Johann Aalto, Director, Chesapeake Technical Support
Laboratory:
There is a substantial loss of water returning to the river in
a land-contained system.
Generally during the summer months 15% is lost by evaporation,
20% by transpiration, and 10% into ground water.
This means a total consumptive loss of approximately 45%.
With a conventional AWT system, consumptive loss is only 10 -
15% (approximate).
8 5% return of water to the river is necessary if we are to keep
the salt wedge from moving upstream and theretore destroying the
estuary as a potential water supplyl
3. Pipeline for Estimated 100 Miles
No cost estimates are included in Mrs. Agnew's paper, nor are they
adequately treated in the documentation she included.
The proposed Occoqaan regional tertiary treatment plant, to be
built in Fairfax County, will be a 92 mgd plant. It will in-
clude 11 miles of pipeline at an estimated cost of at least
$32 million EXCLUSIVE of pumping station costs.
We realize that direct extrapolations are always dangerous,
and usually unreliable. However, in the case of such long-
distance pipelines, we have been unable to acquire firm
figures on short notice. Bearing in mind that these may not
be particularly adequate:
Using a 3.3 scaleup (92 mgd vs. 309 mgd), a 100-mile pipe-
line would cost approximately $950 million - nearly a
billion dollars'.
M97

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- 3 -
According to Virginia State Water Control Board Chairman Woman
Cole, the Muskegon land-contained system costs are very sensitive
to:
1.	The cost of land since it is required in great quantities. In
Muskegon land was $320 per acre, and 10,000 acres were re-
quired for a 42 mgd plant.
2.	The distance and land and elevation between the source of the
sewage and the area where it is to be sprayed. This distance
sets the length of force main transmission lines. The elevation
and distance will set the number of pumping stations required.
Muskegon's force main is only 11 miles long (over very flat and
sandy land, no hills or rivers) and only one major pumping
station (elevation in order of 25 feet). The cost of land will
also affect the pipeline right-of-way costs,
3.	The number of pumping stations and elevation of the lifts will
have a major impact on operation costs, which are very sensitive.
It is imperative we know how many watersheds and subwatersheds must
be crossed (each requiring at least one pumping station) before the
land to be irrigated is reached.
Pipelines are sized for peak flows, not just average flows.
150 feet is generally considered the maximum practicable lift for
standard sewage pumps (Metcalf 5 Eddy, 18 Mar 1971).
Siltation - one hundred miles of pipeline would be environmentally
damaging in reference to the tremendous amount of siltation pro-
duced by such construction.
Especially in rural areas where there are few or no erosion con-
trol guidelines or ordinances.
5.	The Muskegon Plant is Not Yet in Operation
Will a similar approach work in the metropolitan area?
More than one quarter of the Muskegon flow originates from a
a paper mill, with types and amounts of organic wastes accurate-
ly calculated. This would not be true of a system handling
municipal wastes such as Blue Plains.
6.	Other Treatment Plants Now Operating in Metropolitan Area
The following all empty effluent into the Potomac River at this
time: Pentagon - Arlington - District of Columbia - Alexandria -
Andrews Air Force Base (2 plants) - Ft. Belvoir (2 plants) -
Lower Potomac.
Although some of these are scheduled to be closed, their
effluent will merely be piped elsewhere and still flow into
the estuary after treatment.
There are also municipalities throughout the Potomac basin with
primary or secondary treatment only - or no treatment at all.
WATER SUPPLY - continued
Mrs. Agnew's statement on page 3, purportedly quoting from an
unidentified Senate Public Works Committee report (actually a quotation
M98

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from EPA's 1971 report on "The Cost of Clean Water," Vol. II), says:
"The ground disposal systems have the great virtue of recycling the
material so disposed both the replenishing water tables (emphasis ours)
and by converting and utilizing organic waste matter in natural life
processes of decay in growth."
We will leave aside at this point the fact that the Senate Committee
took this sentence out of context and therefore altered the entire
thrust of this segment of the EPA report which deals with "Diseconomies
in Public Waste Management Activities."
While there might be some ecological validity to the proposition
that organic waste matter should be recycled into the local ecosystem,
the implication that a land-contained system would replenish water
tables in the metropolitan Washington area simply is not true. It
would do so only if a major portion of the region's water supply were
obtained from deep wells, thereby depleting the area's underground
water supplies (aquifers). This is not the case.
The April 1971 EPA "National Capital Regional Water and Waste Manage-
ment Report" states that about three-fourths of the water for the region
is taken from the Potomac, and one-fourth from Patuxent, Occoquan and
Goose Creek reservoirs and from wells. The Occoquan and Goose Creek
are both tributaries of the Potomac River. An examination of the Fair-
fax County Water reports reveal that the proportion of its water supply
from wells is statistically insignificant.
It is therefore apparent that a major portion of the region's water
supply comes either from the Potomac River or its tributaries. Under
present wastewater management practices all of this withdrawal of water
is returned to the estuary at or above the confluence of the Potomac
and the Occoquan.
In effect, this is a closed hydrologic cycle. A large quantity of
water is withdrawn from the river, used by consumers (primarily resi-
dential) and returned to the river in the form of treated effluent from
sewage plants. The small proportion of water table drawdown represented
by deep well sources in public systems and by private users of wells is
probably counterbalanced by those water uses which are returned to the
water table; e.g. lawn watering, agricultural irrigation, and storm
water drainage.
This existing natural balance of both river flow and aquifers would
be completely upset by Mrs. Agnew's proposal. While not implicit in her
written statement, her public answers to questions regarding the land-
contained system proposal and a consideration of land use factors in the
metropolitan Washington area make it clear that what she is proposing
is the EXPORT of the region's wastewater to somewhere else. In response
to questions as to where this somewhere else might be, she has responded
that Corps of Engineers' studies indicate that the Delmarva Peninsula
would be a suitable location for this enormous septic field.
In other words, 309 mgd of Potomac River flows - or considerably more
than that if we are to be consistent and apply this proposal to every
wastewater treatment process in the region - are to be exported out of
the Potomac basin to the eastern shore of Maryland, Delaware, Virginia,
or to York, Penn. All have been mentioned by the proponents of this plan
as potential depositories for our sewage.

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COPY
CITIZENS COUNCIL TOR A CLEAN POTOMAC
P.O. Box 197? - toheaton Station - Silver Sprinp, Md. 20902
WHEREAS, the political jurisdictions in the Washington metro-
politan area have apreed on a program to upgrade and expand the
Blue Plains sewape treatment plant in the District of Columbia
with the objective of providing a hiph level of water quality in
the Potomac Fiver; and
WHEREAS, expansion of primary and secondary facilities and
addition of advanced waste treatment to the plant promise much in
the way of abatinp pollution in the Potomac from the Washington
metropolitan area; and
WHEREAS, construction of advanced waste treatment facilities
at other plants in the Washinpton metropolitan area is either
planned or underway, promising the same benefits to the Potomac
River as does the Blue Plains plant; and
WHEREAS, the use of the laternative disposal methods involving
spray irripation of effluent or land disposal is impractical both
from a cost and technolorical standpoint for the Blue Plains
service area due to the volume of waste water generated and the
particular physical conditions in the area; now, therefore, be it
RESOLVED, that the Citizens Council for a Clean Potomac
stronply urpes the U.S. Conpress and the political jurisdictions
in the Washinpton metropolitan area to continue the Blue Plains
expansion and uppradinp proprai'i. The Council also resolves itself
to an effort to ensure continued funding for and support of the
Blue Plains propram.
Adopted unanimously by the
Steerinp Committee
18 January 1972
M100

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THE WASHINGTON POST - 16 January 1972
("Letter to the Editor]
The Potomac Basin Inter-Leapue Committee of the Leapue of Women
Voters is composed of representatives from the 21 state and local
Leapues in the Potomac Basin. For almost seven years this committee
has concentrated on the Potomac River and its myriad problems—with
particular attention focused on the Metropolitan Washington portion
of the river where the need for action is most crucial.
After months of discussion and political maneuvering, an agree-
ment has finally been reached by the local jurisdictions and the
states of Maryland and Virginia to take immediate interim measures
to reduce the pollution to the river from both the overloaded regional
plant at Blue Plains and the Georgetown Cap where raw sawape has
poured into the river.
However,, as important as these interim measures are, the river
will not be really "cleaned up" until the plant at Blue Plains is
expanded and upgraded to provide both secondary treatment and nutrient
removal for the almost 300 MCD (million pallons per day) that flow
thrcuph this facility from the Maryland suburbs, the District of
Columbia, and the Dulles interceptor in Virginia. An agreement to
upprdde Blue Plains was also reached after many agonizing months of
intergovernmental negotiations, and construction has now bepin on
what will be one of the most technically advanced phpsical-chemical
waste treatment facilities in the United States, The Potomac Basin
Leagues have supported this construction - and its financing - as we
believe it is an imperative step in achieving a clean rotomac.
we are therefore dismayed that at just this point in time - when
after years of talk there is real accomplishment - the Northern
Virginia Conservation Council has launched an attack on this physical-
chemical plant now under construction. We feel this group's alterna-
tive of a spray irripation-land disposal system is unrealistic for
the following reasons:
*	The peopraphical suitability of this region for land disposal
is questionable, especially for larpe amounts such as the 309 KCD
which will be the flow to Blue Plains by 197S.
Althouph the cost cf the advanced treatment planned for Blue
Plains is hiph, the cost of transporting 309 MCD of sewage to a dis-
posal site - if a suitable site could be found - would be much more
expensive.
*	The land area required would be more than 100 square miles,
larper than the District of Columbia itself,
A 309 MCD would be removed from the estuary where it is needed
in times of low flow to prevent a salt wedpe in the lower estuary
from rnovinp upstream to the Washington area. If this salt wedp.e
moves upstream it would preclude the emergency use of the estuary
for water supply in an extended period of droupht.
The federal povernment, the states and the local jurisdictions
have agreed to the financinp for the construction already underway.
If the type of treatment was chanped at this time it would be many
more months before another financial apreement could be reached, and
the depradation of the river would continue.
MlOI

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The question of possible air pollution from the kludge burning
process which will be incorporated into the uppraded facility has
also been raised. It is the opinion of Whitman, KeouarcJt and Associa-
tes, Engineering Consultants, Baltimore, Md., that this would not be
the case. A further study of the specific decipn configuration of
the Blue Plains plant from the standpoint of the effect of the sludge
burning on the ambient air quality of the metropolitan Washington
area is now beinr. conducted. The Leapue of Women Voters would of
course support any desipn modifications - if they are shown to be
needed - for the plant to meet air quality standards.
Blue Plains will handle only a part of the total sewape load of
the Washington metropolitan area. More facilities are needed in
both Maryland and Virginia, and WSSC has agreed to bep.in immediate
planning for an additional regional plant for the Maryland suburbs.
Our committee feels that an examination of the alternatives for
these future facilities would be more productive than proposinp an
alternative for one that is already under construction. The Potomac
River can no lonper afford to wait - it will become another Lake Erie
if we continue to talk and do not act.
HESTER KcNL'LTY,
Potomac Easin Tnter-Leapue Committee,
League of Women Voters
Falls Church
M102

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COPY
WASHINGTON ECOLOGY CENTER - December 1971
Blue Plains' Sewage Effluent Lands in Controversy
Advanced sewage treatment, a physical-chemical process which
removes nutrients from sewage after conventional treatment, has long
been billed as the answer to the pollution problem of nutrient loadings
to streams and riverways. It promises to curb, at least, the eutrophi-
cation process, through which waterways are "killed" (like Lake Erie)
through strangulation by growths of algae.
A.dvancedvtf waste treatment facilities are now under construction
at Washington's sewage treatment plant at Blue Plains, due to be
finished in late 1974-, and designed to remove up to 98 per cent of
the pollutants from sewage. Anyone who has seen the summer algal
growths in the Potomac Estuary holds out hope for this process.
With construction well under way at Blue Plains and benefits
soundly promised, the Northern Virginia Conservation Council has
questioned the entire theory of advanced sewage treatment, claiming we
can put the effluent (treated waste) on the land, use it to enrich the
land, and keep the rness out of the Potomac River. They would scuttle
the advanced waste treatment process in favor of spray irrigation of
the sewage effluent, and have taken their case to the U.S. Congress,
presenting each Congressman with a case for land disposal with projec-
tions for Washington basedriri on a much smaller system used in Muskegon
County, Michigan.
The primary merit to be seen in the NVCC position is that it
raises the question of what should be done with the hundreds of tons
of sewage sludge produced each day. The burning of sludge, as now
planned, will emit some 50 to 65 parts per million of nitrous oxides
into the air - a fact which even D.C. officials admit.
But also to be considered is the ecological damage to the Potomac
Estuary if we stop the flow of treated sewage effluent into the estuary
Blue Plains will discharge about 310 million gallons of treated
waste water each day to the Potomac. If we spray irrigate this effluen
the discharge will be lost. Bear in mind, 310 million gallons a day
(rngd) is fairly close to the summer low flow of the river at "Washington
once as low as 38 8 mgd. Were we to have another drought year, theo-
retically we could have a sea of salt instead of the fresh-water Potoina
Estuary.
Without the inflow of the waste waters from Blue Plains, the
saline water, during low flows, could move upstream from the Route 3 01
bridge as far as the southern suburbs of Washington and eventually as
far as Key Bridge.
All of this would, perhaps most importantly, preclude the future
use of the Estuary as a water supply source. Once the people of the
Washington area accept the concept of using recycled water, and ene-the
once the question of how to kill viruses is cleared up, the Potomac
Estuary, now Washington's sewage effluent receptacle, could become a
vila viable source of water. But not if we stop waste water discharges
altogether.
M103

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All of this does not take into account the geological suitability
of the Washington area and many outlying areas for spray irrigation
of waste water. Some experts say the suitability is nonexistent. In
addition, estimates are that it would take a land area the size of
the District plus Arlington County.
The Northern Virginia Conservation Council did a good deal of re-
search on the Muskegon County system, but that system was only designed
for 35 rngd. Projections to Washington's 309 mgd are dangerous. They
raise a good point in the problem of air pollution from incineration
of sludge, but the benefits seem to weigh heavily in favor of continuing
A/ith advanced waste treatment at Blue Plains, despite it. If we stop
construction of advanced treatment facilities now for a lengthy study
of land disposal, Washingtonians may never see their environmental
Dbjective: a clean Potomac River.
M104

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CENTRAL ATLANTIC ENVIRONMENT NEWS - 30 Nov 71
..~Finally, further confusing the situation, the Northern
Virginia Conservation Council—in a statement given wide distri-
bution on Capitol Kill—suggested in mid-November that the current
Blue Plains expansion program be replaced by a new waste treatment
system for the metropolitan area utilizing the spray-irrigation
process. Basing its case in large part on spray-irrip.ation facili-
ties now under construction (not yet operational) at Muskegon,
Michigan, the Council claimed a similar system at Washington would
be cheaper to operate and have less environmental impact than the
present Blue Plains plan. (Our own preliminary inquiry—including
contact with the Muskegon consulting firm--indicates that the
Council's position paper contains material the validity of which
is open to question.)
CENTRAL ATLANTIC ENVIRONMENT NEWS - 30 Dec 71
...Is there a better sewage treatment system for the Washington area?
A proposal promoted by Marion A^new, President of the Northern
Virginia Conservation Council, to phase out the Blue Plains sewage
treatment system, which is described as a physical-chemical process,
and replace it with a spray-irrigation land disposal process alonjs
the lines of one now being engineered for Muskegon, Michigan, has
received much attention recently. There is appeal in the idea that
nutrients should be used on the land where they can be recycled,
rather than spilled into our waters where they pollute. Much re-
search would need to be done, however, to adapt the Muskepon plan
to the Washington metropolitan area, for the two areas are quite dis-
similar in certain essential ways. Muskegon's system depends on
many acres of very porous soils which are not available near the
Washington area, and it is designed to handle relatively small
quantities of effluent compared to the hundreds of mgd produced here.
The principal difficulty with the Muskepon system, however, if
applied to the Washington area is that 309 mgd, more or less, of
effluent would be lost to a river whose flow was recorded in 1966
at 388 mgd—in other words, the Potomac River cannot spare 309 mgd.
Such loss could mean salt water intrusion into the upper estuary as
a future source of water supply. Conceivably, some aspects of the
Muskegon system could be redesigned and adapted for future disposal
systems here-particularly if effluent could be treated in a land
disposal system upstream, where it would drain back into the Potomac
River. Unfortunately, the Delmarva peninsula i3 the only land area
that appears suitable for application of this system at present, and
the dollar costs of piping, the effluent as well as the water lost
prohibit such a scheme.
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POTOMAC BASIN REPORTER
- November-December 1971
Newsletter cf the Interstate Coir.jnissi.cn on the Potomac River Pasin
Editorial
The massive improvement program new underway at the P.C. Water
Pollution Control Plant at Blue Plains promises to produce one of
the finest waste treatment facilities in the nation, if not the
world. It offers the first opportunity in many years for the people
of the Washington metropolitan area to enjoy a comparatively clean
Potomac Fiver.
At this late date, with construction well under way and benefits
soundly promised, the Northern Virginia Conservation Council has
seen fit to question the entire theory of advanced seware treatment,
claiming that physical-chemical treatment will not solve the urben
water pollution problem and may transfer it to the air, They weald
scuttle the advanced waste treatment ('recess in favor of spray irri-
pation of waste water.
While the Interstate Commission on the Potomac Kivcr Bar-in has
endorsed spray irrigation for use where it is feasible, the Washing-
ton area does not lend itself to such a process.
Many problem,s stand in its way:
1)	309 million gallons of water (the daily effluent discharge
to the river) would be lost. This amounts to nearly the total flow
of the river in the summertime.
2)	Without this inflow, the saline wed^e would move rapidly
upstream.
3)	Such a procedure would preclude the future use of the
Potomac Estuary for water supply.
These three problems relate only to the actual effects of
eliminatinn an effluent flow to the river after a spray irrigation
or other land-contained process were instituted. There also are
severe problems in the rjractical application of such a process in
the Washington metropolitan area:
1)	The pecloj-ical suitability of the area to spray irriga-
tion is in serious question.
2)	The costs cf transpcrtinr the sewape effluent or sludre to
an area which is suitable for land disposal would be prohibitive
and cannot be projected from the cost studies done of the Kuskepcn
County, Mich., system, which involves a fraction of the load at
Blue Plains.
3)	It has been estimated that land disposal cf sewage effluent
from Blue Plains would require a land area the size of the District
of Columbia plus Arlington County.
The Commission feels these are sufficient reasons to discredit
spray irrigation in this type of settinp.
We take the position that to halt construction at Blue Plains
of advanced waste water treatment facilities would be sheer folly.
While we concur, as do officials within the P.C. povernment, that
burning of advanced waste treatment sludjre may pose an air pollution
problem, we believe that the {.-enefits weiph heavily on the side of
advanced waste water treatment.
Carl Johnson
Executive Director, ICPRB
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7 9S8 Bollinp Drive
Alexandria, Va. 22308
March 5, 197?
Mr. Edward W. Furia, Jr.
Repional Administrator
Environmental Protection Apency
Curtis Buildinp
6th S Walnut Sts.
Philadelphia, Pa. 19106
Dear Mr, Furia:
The enclosed material repardinp the District of Columbia's
Blue Plains sewape treatment plant is for vour information.
I hope you will note in particular the Northern Virginia
Conservation Council's Blue Plains resolution. The Board of
Directors endorsed Advanced Waste Treatment upgrading and ex-
pansion of Blue Plains on January 12, 1972, the membership on
January 26, 1972.
I can assure you that citizens of the metropolitan Washinp
ton area, with the exception of a very few, support AWT upp-rad-
inp and expansion of Blue Plains.
Questions and criticisms repardinp the incinerator could
certainly be ironed out by open discussion of all concerned.
It is not too late to chanpe the desipn of the incinerator, if
necessary.
Sincerely yours,
(Mrs.) Elizabeth Hartwell
Enclosures
M107
MAR -3!
FWQA

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Northern Virginia Conservation Council
Box 304, Annandale, Virginia 22003
February 23, 1972
DEAR M£"M6£R OF c.onG&£SS:
Enclosed is a new resolution adopted on January 26, 1972 by the
NORTHERN VIRGINIA CONSERVATION' COUNCIL Board of Directors and
membership in regard to its position on the BLUE PLAINS SEWAGE'
DISPOSAL CONTROVERSY.
This resolution represents a change in the Council's: earlier
position.
Yours truly
IWUJ-O l_J.l-lJ._y,
Caroline W. Peters
m108 Secretary

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Northern Virginia Conservation Counci
Box 304, Annandale, Virginia 22003
BLUE PLAINS RESOLUTION
Be it resolved by the Northern Virginia Conservation Council that:
1. As a general principle to follow in dealing with environmental problems, we
favor the recycling of natural resources and the use of natural biological processes
wherever feasible, in preference to elaborate, highly technological methods
that may involve risks of harmful side effects, physical breakdown or human error;
2. Within the context of the above statement of principle, but also in recognition
of the achievements of the Potomac River - Metropolitan Area Enforcement
Conference, we should like to modify our position presented to the Conference on
November 10, 1971, as follows:
a.	We endorse the proposals of the Conference to expand the capacity of
the District of Columbia's Blue Plains sewage treatment plant to 309
MGD by December, 1974, and upgrade it to advanced waste treatment
(AWT), as partial steps toward solution of the area's waste water
treatment problems;
b.	To the extent that the requirements of Sec. 102 of the National Envir-
onmental Policy Act have not yet been complied with, with reference to
the questions of effluent quality, sludge removal and incineration at Blue
Plains, we request that additional statements be completed;
c.	We urge all concerned agencies in the area to foster continuing studies
between now and December, 1974, of the feasibility of alternative methods
of sewage treatment, with particular attention to land-contained systems
within the Potomac River Basin and methods of sludge disposal;
d.	We urge that the results of such studies be applied where feasible in
the area, so as to spread the treatment load more evenly, to avoid
possible overloading of the Blue Plains plant, to avoid too heavy reliance
on treatment methods that could cause unwarranted environmental hazards,
and to conserve the Potomac River Basin's fresh water resources to the
optimal degree.
3.	We commend the Virginia State Water Control Board for its constructive role
in working toward a solution to the area's wastewater problems.
4.	The secretary is instructed to supply copies of this resolution to all
Conference participants and to all others who have been provided with the Council's
previous position paper, urging their support of the concepts set forth in this
resolution.
(Passed on January 26, 1972)
M109
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ENVIRONMENTAL
DEFENSE
FUND
1712
XMKN STREET, N.W., WASHINGTON, D.C. 20036/202 833-1485
February 8, 1972
Edward Furia, Jr.
Regional Administrator
Environmental Protection Agency
Curtiss Building
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Furia:
We want to thank you for the excellent meeting held in your
office last week. Your willingness to take a fresh look at the
Blue Plains project and your openness to the alternative land-
contained sewage treatment system were very encouraging to us.
As you now know, the advanced waste treatment system and
the sludge-incinerator planned for Blue Plains have been rushed
through the administrative review process. They have been
approved on the basis of scanty planning, inadequate information,
and without the legally required environmental impact statement
or the necessary public involvement. Consequently several very
controversial questions about the process being installed and
the potential alternatives remain to be answered. It is hard
for us to understand why these were not brought to your attention
sooner, as they should have been. However, now that you are
fully aware of the situation, we are confident that your staff
will investigate thoroughly the Blue Plains project and the
available alternatives. Blue Plains has become such an emotional
issue here in Washington that it is essential that someone from
the outside like yourself undertake an objective assessment of
the situation before proceeding any further.
Thus far, the flow of information has been from the public
to the government. We hope, however, that as a result of our
last meeting this flow can now begin to be reversed and the public
begin to learn more precisely what EPA has invested its dollars
in at Blue Plains and what will be the consequences. As stated
in EDF's letter to you of January 24, 1972: "Our sole concern
MHO
OFFICES IN EAST SETAUKET, NY (MAIN OFFICE), NEW-YORK CITY (PROGRAM SUPPORT OFFICE), WASHINGTON, DC, BERKELEY. CALIF
This paper /s recycled to protect the environment

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here is to insure that the decision on Blue Plains receives the
careful analysis and public involvement required by the National
Environmental Policy Act of 1969, before any irreversible commit-
ments of resources are made."
We are therefore enclosing a list of questions which we
hope will help to focus your investigation. This list is not
complete but merely suggestive of the kinds of information
needed before a rational decision can be made. It is our
expectation that when we meet again this Friday we can begin to
discuss the answers to some of these questions.
Sincerely,
£»f -"7 -£•'/ " '
/
Scott H. Lang
Washington Counsel
Marion Agnew
Chairman, Northern Virginia Con-
servation Council
Enclosure
Mill

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QUESTIONS
The Incinerator
1.	Is the engineering design for the incinerator completed?
2.	Is the engineering design available to the public?
3.	What is the design capacity of the incinerator?
4.	What combustion process will be employed?
5.	What pollutants will be emitted into the air?
6.	What are the predicted stack emission levels for particulates,
sulfur oxides, oxides of nitrogen, mercury, lead, and other
pollutants? How many pounds of each?
7.	Upon what data and what empirical studies are the predicted
stack emissions predicated?
8.	What control technology will be employed to control each of
the above pollutants?
9.	Is this control technology proven to be reliable? Based on
what data and studies?
10.	What impact will each of the above pollutants have on ambient
air quality?
11.	Are there data and studies available to show what impact the
incinerator will have on ambient air quality?
12.	What are the stack emission standards for each of the above
pollutants ?
13.	Will all of these standards be complied with? Based on what
information?
14.	In particular, are these stack emission standards for oxides
of nitrogen, and if not, how has it been determined what
degree of pollution control is required?
15.	Have the stack emission levels of all other point sources
of oxides of nitrogen been considered, including other in-
cinerators in the Washington air basin which are still in
the planning stage?
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16.	In light of the Washington, D.C. air pollution implementation
plan which requires a one-third reduction in automobile
traffic entering the District in order to reduce oxides
of nitrogen, what impact will operation of the Blue Plains
incinerator and other point sources of nitrogen oxides
including those planned but not yet constructed have on the
Washington air pollution program?
17.	What provisions have been made in the event the incinerator
must be shut down because of malfunction or an emergency air
pollution episode?
18.	What will be done with the sludge processed at Blue Plains
which cannot be burned during periods of incineration
breakdown or shutdown?
19.	How much fly ash will the incineration process produce
each day?
20.	What are the chemical and biological ingredients of the ash?
21.	Where will this ash be disposed?
22.	When is construction of the incinerator scheduled to begin?
When is it scheduled to be completed?
23.	Have any contracts been let for construction of the incinerator?
24.	What is the total capital investment in the incinerator?
25.	How much will it cost to operate the incinerator per year?
Per day?
26.	What are the alternatives to incinerating sludge?
27.	How much will the alternatives cost? Capital investment?
Operating expenses?
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Dredging and Filling
1.	What are the chemical contents of the sediments being dredged
near Blue Plains and deposited in Dyke Marsh?
2.	Has a study of the long-range toxic effect of the heavy
metals in these sediments on the biota of the Potomac Estuary
ever been undertaken? What are their redox potentials?
3.	Has a study of the potential toxic effect on the biota of
Dyke Marsh ever been undertaken?
4.	What criteria does the Environmental Protection Agency use to
determine whether dredged materials are safe for open water
disposal?
5.	Are these criteria being exceeded in disposing of the Blue
Plains sediements in the open waters off Dyke Marsh?
6.	Why is the channel being dredged at Blue Plains necessary?
7.	Are there alternative methods of constructing the Blue Plains
additions which would not require dredging, such as rail or
truck hauling?
8.	What are the economic factors which justify dredging as
opposed to these other alternatives?
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Advanced Waste Treatment
1.	Is the engineering design for the Advanced Waste Treatment
System (AWT) completed?
2.	Are there any engineering designs available to the public?
3.	Is there a detailed description available of the nature and
quantity of the chemical and biological processes to be used
at Blue Plains? For instance, do the plans call for chemical
de-nitrification or biological de-nitrification?
5.	What assurance is there that the AWT process is a reliable
and workable system on the scale proposed at Blue Plains?
6.	Is Blue Plains AWT modeled on the AWT plant at Lake Tahoe?
What changes or variations have been made from the Lake Tahoe
mode1?
7.	Has the Lake Tahoe model proven reliable?
8.	What percentage of the time, if any, has it been out of opera-
tion, and why?
9.	Assuming that it takes about 18 hours for sewage to go through
the AWT process, what provision has been made in case of
excess capacity?
10.	Is there a way for sewage to by-pass the AWT process, and
if so what will happen to it?
11.	Is there provision for on site storage of sewage in excess
of the AWT capacity? Or will excess sewage have to be
stored in the Washington sewers?
12.	What are the average daily and yearly operating and maintenance
costs of operating the AWT plant?
13.	What are the fixed capital investment costs for constructing
the AWT plant?
14.	What quantities of chemicals will be used in the daily
operation of the AWT process?
15.	How much sludge will the AWT process produce daily? Yearly?
M115

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16.	How will viruses and bacteria be controlled at Blue Plains?
17.	Will chlorination be used to control viruses and bacteria?
How much per day?
18.	Where will chlorine be used in the water renovation process?
19.	What impact will the chlorination have on the biota
of the Potomac?
20.	What consideration, if any, has been given to the report of
Dr. Vinton Bacon published in the "Proceedings of the Poto-
mac River Pollution Control Conference," May 21-22, 1970 at
page 240E?
21.	Upon what data did Dr. Bacon justify his position that the
Blue Plains plant should be upgraded only to 240 MGD, primary,
secondary and AWT, with no sludge incinerator?
22.	Is the supportive data for Dr. Bacon's report available
to the public?
Ml 16

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Land-contained systems
1.	What consideration has been given to a land-contained system
for sewage from the Washington area?
2.	How does the land-contained system compare with the AWT
system in terms of:
operating cost
capital investment
air pollution
water pollution
virus control
reliability
capacity
construction time
versatility, i.e., potential for an integrated total
waste management system.
3.	Is there sufficient suitable land available in the Washington
area for a land-contained system.
4.	What adverse environmental impacts, if any, will a land-con-
tained system cause?
5.	Will there be any danger of disease spreading from the spraying
of treated sewage onto land?
6.	Will there be an appreciable loss of water from the Potomac
Basin if a land-contained system is implemented?
7.	What is the potential for using treated sewage to reconstitute
strip mines, gravel pits, other reclaimable lands?
8.	What is the potential for using spray-irrigated lands to raise
crops and livestock?
9.	Is it economically and technologically feasible to adapt
the Blue Plains facilities as well as other treatment plants
in the area to a land-contained system?
10.	How long will it be before a land-contained system capable
of handling the Washington area sewage could be in operation?
11.	Upon what basis are the answers to questions no. 9 and no. 10
above made?
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What additional information is necessary to adequately
answer questions no. 9 and no. 10?
What efforts are being made to obtain this information
M118

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Plant Capacity
1.	What is the projected design capacity for Blue Plains when all
improvements are completed?
2.	What is the projected UOD, P, and N loads for Blue Plains
when all improvements are completed?
3.	How will any overflow at Blue Plains be processed? Will
they be bypassed? Stored?
4.	Is storage and pre-treatment of storm water runoff from the
combination sewers part of the present construction plan?
5.	What are the future projected capacities of the following
waste treatment plants when all improvements to these plants
are made: Piscataway, Arlington, Alexandria, Lower Potomac
(Pohick), Anacostia, Montgomery County, Upper Fairfax County?
6.	What are the projected UOD, N, and P loads for the above
plants when all projected improvements are completed?
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Interim Treatment
1.	What provisions have been made for interim treatment during
the period Blue Plains is being constructed?
2.	Where is the undigested sludge from the Interim Treatment
Program being disposed?
3.	If there is difficulty disposing of this sludge, what will
be done with the sludge from Blue Plains? Can it all be
incinerated?
4.	What additional flows are allowed under the interim agree-
ment? From which sewer lines? Where do these sewer lines
now terminate?
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BLUE PLAInS VlESOLU'i'IOii
March 7, 1972
Page 2
EE IT FURTHER RESOLVED that the Loudoun County Board of Supervisors
opposes at this time, the proposal that a spray-irrigation system
cf wastewater treatment be applied in this metropolitan area, as a
replacement for Blue Plains.
BE IT FURTHER RESOLVED that the Executive Secretary is hereby
authorized and directed to transmit certified copies of this reso-
lution to the Virginia members of the U. S. Congress, the Inter-
state Commission on the Potomac River Basin, the Federal Water
Quality Office, and the Metropolitan Washington Council of Govern-
ments, the Government of the District of Columbia, Eighth Planning
District and the Governor of the State of Virginia.
Voting on the motion: Messrs. Walstad, Raflo, Brownell, Arnold
Lo, Stowers and Crossman--Yes.
Costello,
A COPY TESTE:
Executive Secretary
Loudoun County Board of Supervisors
March 10, 1972
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COPY
Commonwealth of Virginia
COUNTY OF LOUDOUN
Board of Supervisors
18 East Market Street
Leesburg, Virginia 22075
Telephone: 777-2660
Extension 20
At a meeting of the Board of Supervisors of Loudoun County, Virginia,
held in the Meeting Room of the County Office Building, Leesburg,
Virginia, on Tuesday, March 7 , 1972 at 10:00 a.m.
' "' V ' i : . , . ; . L ; i'; i \
° / .	w l;> }T- !
's.* L '¦ fc
Jwl mad _qi 1Q79 ^
PRESENT: William C. Crossman, Jr., Chairman
Paul J. Walstad
James F. Brownell	MAR 31 1972
James E. Arnold
John A. Costeilo
henry C. Stowers
Frank Raflo	^ f
IN RE: BLUE PLAINS TREATMENT PLANT--UPGRADING AND EXPANSION
Upon motion of Mr. "Walstad, seconded by Mr. Faflo, the following
resolution was adopted:
I\
ESOLUTIO N
WHEREAS, the Government of the District of Columbia has taken the
necessary steps to develop plans for the upgrading and expansion
of its Blue Plains Waste 'Water Treatment Plant; ana
'WHEREAS, the construction for the. said upgrading and expansion of
the Blue Plains Treatment Plant has commenced and is well underway;
and
WHEREAS, the said plans were developed in accordance with and
approved by the Washington Metropolitan Area Enforcement Conference;
and
WHEREAS, the proposed method of effluent disposal from The Blue
Plains Waste 'Water Treatment Plant has been approved by tne repulatory
agencies having jurisdiction over such construction.
NOVi, THEREFORE, BE IT RESOLVED that the Loudoun County Board of
Supervisors goes on record as supporting the present schedule of the
Potomac River - Washington Metropolitan Area Enforcement Conference
for the expansion and upgrading of the District of Columbia's Blue
Plains Sewage Treatment Plant to conventional advanced waste treat-
ment capability, at a design capacity of 309 mga, by December 1974.
Ml 21

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