In the last issue of Headwaters [the newsletter of the West Virginia Rivers Coalition], we covered the proposed "alternative technology" sewage treatment plant for the Potomac Headwaters, to be designed and operated by Shaeffer International. This plant is supposed to take all of the sewage from Hardy County, the town of Moorefield, ConAgra’s food processing plant, and Wampler Foods (our big poultry company), and run it through a series of treatment lagoons and then land apply the waste.

These lagoons would be located just above the famous South Branch Potomac Trough along with its resident bald eagles and its great boating and fishing. The proposed land application fields are located nearby. Usually it’s a good thing to land apply waste and eliminate direct discharge to streams. So what’s the big deal?

The West Virginia Rivers Coalition (WVRC) hired Kathy Martin, a former Oklahoma Department of Environmental Protection engineer, to answer that question. WVRC met Martin in Washington, D.C. last year and asked her briefly about this.

The more she heard about the project the more concerned she became – the lagoons were some of the largest she had ever heard of. Martin agreed to study the proposal and a few weeks ago we got her final report. Some alarming facts came to light.

The proposal for this new technology bases its expectations of successful treatment of the wastewater on the waste flow at the Wynstone Country Club in North Barrington, Ill. Wynstone is a golf club that is closed for part of the year.

Martin’s professional opinion is that the two wastewaters would not be even remotely similar in volume or in pollutant concentrations. WVRC was shocked to find out that the success of a new, alternative technology treatment for this mega waste facility at the Headwaters of the Potomac was being based on a country club!

The 56-acre sewage storage reservoir design proposes a maximum operating depth of 23 feet plus the two feet of conservation pond and a "clay" liner thickness of one foot. Since the original proposal, Shaeffer has upgraded the liner due to the West Virginia Division of Environmental Protection insistence, but leakage issues remain. The leakage, or seepage, calculations indicate that the reservoir will seep 2,401 gallons per acre per day when the lagoon is full, or 134,456 total gallons per day. This equates to 49,076,440 gallons per year. This represents a volume of wastewater equal to 14 percent of the storage capacity of the reservoir. Yes, this proposal itself demonstrates 14 percent leakage!

Over the 20-year design life, this equals 981 million gallons of wastewater leaked! This leakage will enter the subsurface in the vicinity of the South Branch of the Potomac River. It is believed that there is a shallow groundwater system along the banks of the South Branch and that this leakage would travel to the groundwater and ultimately to the surface water via a hydrologic connection.

The Shaeffer proposal claims that the water quality of the South Branch will be improved because discharges will be eliminated. However, Shaeffer does not compare the concentration of nutrients in the permitted discharges against the concentration of nutrients in the reservoir leakage. Nor does Shaeffer compare the impact of run-off from the irrigation sites.

Another alarming fact from Martin’s report is that the accumulation of phosphorus in the lagoon system as sludge will cause a serious disposal problem at the end of 20 years.

The Shaeffer proposal assumes 90 percent of the phosphorus received will remain in the lagoon sludge. After 20 years, that equates to 4.7 million pounds of phosphorus. If the phosphorus were applied to cropland as a disposal method, it would take over 47,000 acres to dispose of all the sludge.

Using the land specifically set aside for the project, it would take 51 years to properly dispose of the phosphorous – 26 years longer than the agreement between Shaeffer, the poultry companies and the municipalities!

Once the storage lagoons are full, the proposal design includes provisions to land apply 3.4 million gallons of wastewater daily.

Since there is no redundancy in the system, if repairs, weather or other considerations prevent land application of the wastewater, the industrial sources, residents of Moorefield and Hardy County would have to store generated waste until the system could get up and running again.

There are many situations where the overflow of the lagoons during floods and the back up of waste when the system is "down" would mean that untreated waste flows directly into the South Branch of the Potomac.

Shaeffer also claims in their proposal that the nitrogen in the waste (a major component of municipal sewage and industrial waste) will be reduced by 75 percent. However, similar to the previous comparison with the Wynstone Country Club, in order to substantiate this claim, Shaeffer uses a business school’s method of waste disposal for comparison.

Again, the volume and composition of waste from a business school is far different from the sources that this plant is to treat. If standard EPA figures were used, twice as much land would be needed to dispose of the nitrogen waste through land application.

This proposal is the largest and most complicated Shaeffer has ever put forth. Their inexperience and numerous unsubstantiated claims throughout the report are un-nerving, particularly when considering the location of this proposal in the Potomac Trough.

On the surface this project may look to some like it will save money and clean up our rivers, but the proposal does not stand up to scrutiny.

WVRC will work with everyone involved to consider better alternatives. These may include simply upgrading existing conventional sewage treatment plants, or building a lagoon system based on sound, thoughtful science. Whatever the alternative, it must truly protect our water sources.