Letter on The Bay Park Sewage Treatment Plant 12-11-13 via The Nature Conservancy


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Letter on The Bay Park Sewage Treatment Plant 12-11-13 via The Nature Conservancy

  1. 1. December 11, 2013 Center for Conservation P.O. Box 5125 East Hampton, NY 11973 Tel (631) 329-7689 Fax (631) 329-0215 www.nature.org/longisland Uplands Farm Sanctuary 250 Lawrence Hill Road Cold Spring Harbor, NY 11724 Tel (631) 367-3225 Fax (631) 367-4715 www.nature.org/longisland Mashomack Preserve P.O. Box 850 Shelter Island, NY 11964 Tel (631) 749-1001 Fax (631) 749-1480 Worldwide Office 4245 North Fairfax Street Suite 100 Arlington, VA 22203 Tel (703) 841-5300 www.nature.org Honorable Judith Enck Regional Administrator Environmental Protection Agency Region 2 290 Broadway New York, NY 10007-1866 Honorable Mirza Orriols Deputy Region II Administrator HUD New York City Regional Office 26 Federal Plaza, Room 3541 New York, NY 10278-0068 Honorable Jerome Hatfield Region II Administrator FEMA Federal Regional Office 26 Federal Plaza New York, NY 10278-0002 Dear Regional Administrator Enck, Deputy Administrator Orriols, and Regional Administrator Hatfield, We are writing to seek your assistance with respect to one of the most serious outstanding post-Sandy environmental and human health issues: the redesign, reconstruction, and fortification of the Bay Park Sewage Treatment Plant and ancillary wastewater infrastructure in Nassau County, New York. There is an urgent need to address both the historic deficiencies and the future ability of this facility, which services more than 500,000 people, to withstand severe weather events. Along with this pressing need comes a unique opportunity to take action that will preserve public health, protect public safety, and profoundly improve the environment. The information outlined in this letter is intended to provide context that explains the need to replace the existing outfall pipe with an outfall to the Atlantic Ocean, consolidate treatment and outfalls to meet current and anticipated regional waste water needs, fortify the treatment plant compound and vulnerable assets to prevent damage in future storms, modernize to advanced treatment technology that reduces nitrogen and will readily accommodate future treatment for emerging contaminants, and transition to digital monitoring and compliance reporting with a community oversight board. For the reasons set forth below, we respectfully request that your respective agencies provide priority attention, effort, and funding support to achieve the significant public health, safety, and environmental quality benefits offered by this opportunity. As a key part of this initiative, The Nature Conservancy offers our assistance, and the assistance of the Western Bay’s Coalition, in organizing dialogs with the scientific experts, local community and civic groups, and/or local government elected leaders and agency heads, with the goal of facilitating a thorough and expedited path forward. To succeed we will need a strong, collaborative effort by your respective offices and the impacted communities, and that will only happen with your participation.
  2. 2. Page 2 of 10 Background As you know, the Bay Park Sewage Treatment Plant was inundated by nine feet of seawater in Superstorm Sandy. Plant failure resulted in raw sewage flooding streets and homes during and immediately after the storm and 2.2 billion gallons of raw and partially treated sewage being discharged into an environmentally sensitive estuary in the weeks and months that followed the storm1. Engineers have undertaken great efforts to put temporary measures in place. However, as of my most recent tour of the facility, the plant was still relying on backup generators that burn 5,000 gallons of diesel every 18 hours costing $700,000 per month in fuel. The result is that the adjacent residential community experiences noise and air pollution from these temporary generators 24 hours per day and components designed to capture and utilize sewage generated methane gas as fuel are not fully functional. In short, it is a continuing community health and environmental crisis. And should another storm come, we are just as vulnerable as we were pre-Sandy. The Western Bays Coalition of the South Shore Estuary Reserve Council has been working for over a decade to lay the groundwork to reduce the adverse impacts of waste water discharges to western bays of Nassau County. Through this group, over $1.64M has been directed towards studying issues related to the sewage outfalls in this area since 2008. As a consequence, today Nassau County leadership, civic groups, residents, scientific experts, and environmental advocates are largely united in their non-partisan vision with respect to moving forward to end decades of waste water discharge pollution and adding resiliency to Nassau’s coastal communities. The Bay Park Sewage Treatment Plant services 40% of Nassau County’s population (approximately 500,000 people). Adjacent to Bay Park there also are serious waste water treatment infrastructure needs required to support the 48,000 residents and hundreds of businesses on Long Beach Island. The aging and inadequate nature of the sewage treatment infrastructure in these areas was not caused by Superstorm Sandy. Based on recent scientific documentation linking waterway impairments to sewage effluent, a process to impose new strict treatment standard requirements and plant modifications was already underway before the storm. 1 Raw sewage from underground sewer pipes contaminated streets and adjacent homes and buildings during and immediately following Sandy. Newsday Photo Kenward A. et al. 2013. Sewage Overflows from Hurricane Sandy. Climatecentral.org Princeton NJ.
  3. 3. Page 3 of 10 The impacts to people’s lives and the surrounding environment resulting from the failure of the treatment plant and the underground pipes during Sandy cannot be understated. As we think about rebuilding, however, it is essential to acknowledge that there were very serious pre-existing problems. Studies and planning efforts already underway are providing clear guidance on the appropriate way to rebuild and re-engineer these systems after Sandy. If the goal for the Sandy recovery efforts is for south shore communities of Nassau The plume from more than 50 million gallons per day of raw and County to be more resilient than partially treated sewage discharging from the Bay Park Sewage before the storm, then we cannot Treatment Plant Outfall Pipe into Reynolds Channel in close simply fortify and rebuild the proximity to densely populated bayside communities of Long Beach, Island Park, and Harbor Isle. Newsday Photo 11/14/12 sewage treatment infrastructure to the same specifications that were originally utilized in 1955 when the plant was first constructed. We must instead (a) take into consideration the significant impairments that pre-storm plant operations were causing, (b) incorporate all the information we have gained from recent studies and analyses, (c) anticipate the significant pending regulatory changes concerning sewage treatment discharge standards in this area as well as projected population increases, and (d) embrace modern rebuilding designs that will accommodate additional treatment add-ons and resource recovery opportunities over the coming decades. I am fully confident that the sewage treatment infrastructure of southern Nassau County can be reengineered and fortified in a way that addresses both pre-and post-Sandy environmental, quality of life, and human health impacts to the western bays and surrounding communities. In fact, improving conditions in the western bays and adjacent ocean beaches will most assuredly have positive economic consequences as natural resources recover and the quality of waterways become more compatible with aquatic recreation, rebuilding goals for depleted fisheries, and enhancing Nassau’s water dependent and water enhanced businesses. I am similarly confident that the level of coordination and cooperation that will be required of multiple federal, state, and local agencies needs to be extraordinary. It is the hope and expectation of all that are invested in this process to see hand-in-hand cooperation among agencies, so that plans are thoughtfully crafted, coordinated, funded, permitted, and expedited through to implementation in a time frame that matches the expectation for distribution and expenditure of Sandy related funding. Preceding Sandy In 2008 NYS DEC and US EPA added the Western Bays of the South Shore Estuary Reserve to its 303(d) list of waterbodies impaired by nitrogen pollution calling for the development of regulatory limits on nitrogen discharges (Total Daily Maximum Load – TMDL). This listing calls out excessive growth of the macro-algae Ulva (sea lettuce) as a primary impairment. Ulva is known to grow excessively in the presence of nitrogen, in this case from sewage. Recent scientific studies (Gobler and
  4. 4. Page 4 of 10 Wallace 20132) identify additional impacts of nitrogen loading of the western bay such as harmful algal blooms, hypoxia, and deterioration of the integrity of salt marsh islands that creates greater risk of wave and water damage for bayside communities. Managers at US EPA have access to the studies that are forming the scientific foundation for the pending Nitrogen TMDL so our intent is not to replicate details of those reports here. In general the very high year-round, persistent nitrogen loading to the western bays (2,800,000 kg of total nitrogen per year3) are coupled with long estuary residence times (poor oceanic flushing). Combined, these phenomena create a variety of environmental degradation problems that not only constitute use impairments in the bay (Swanson et. al. 20134), but also impact the ocean beaches, human health, quality of life, and the local economy. Noxious hydrogen sulfide gas originating from decomposing Ulva impacts communities, beaches, and seaside dining establishments with the odor of rotting eggs during the prime summer season. Seaweed gets so thick on some of the otherwise prime ocean facing beaches that the town of Hempstead must use public financing for manual removal from popular beaches on a daily basis. As the excessive algal growth decays at the bottom of the bay it smothers sea life and depletes oxygen from the waterways. Recent Stony Brook University studies confirm Bay Park effluent fuels Ulva growth Hundreds of millions of dollars are being spent to recover Long Beach after Superstorm Sandy. Yet without the proper re-engineering of sewage treatment and where it is discharged, Long Beach and the town of Hempstead will never realize the full economic potential of this island/city of 48,000 people because the water and shorelines will not meet their best-usage designations. Natural maritime resources and the recreational and the economic opportunities they provide were the prime reason that Long Island’s beach, fishing, and boating communities were originally Despite the town’s daily cleaning, masses of rotting sea established. If these communities are to lettuce, fueled by sewage, keeps people away from prime remain attractive and viable as the risks and beaches and kept many from enjoying the water at Point costs of living near the coast increase, than Lookout on this hot July day in 2013. Newsday Photo integrity of the marine and coastal natural assets needs to reverse from its declining trajectory. 2 Gobler,C. and R. Wallace 2013. Nutrient Assessment and Management in Shallow Coastal Waters of Hempstead Bay. Gulbransen T., et al 2013. Ecosystem Assessment and Nitrogen Management in Western Bays. NY. Report to NEIWPCC 4 Swanson L. et al. 2013. A Synthesis of Loadings, Monitoring, Information, and Impairments in the Western Bays. A Report to Battelle Memorial Institute and New York State Department of State. April 2013 3
  5. 5. Page 5 of 10 Natural infrastructure at risk puts communities at risk Nowhere in New York State are densely populated low-elevation communities more protected from wave energy and coastal erosion by salt marsh islands than along the south shore bays of Nassau County. Windy days are common along the south shore of Long Island, but in the western bays, the expansive marsh islands leave little fetch for waves to develop. In contrast, roughly 20 miles east in central and eastern Great South Bay there are no marsh islands and that area is well known for its ‘choppy’ wave energy. In fact, the frequency and magnitude of wave energy in central Great South Bay has dictated a completely different style of coastal development as compared to the western bays which are protected from wave energy by salt marsh islands. While bay front communities in the western bays are characterized by backyard finger piers that hold small boats – this type of construction could not withstand the chronic wind-blown waves that are common along open sections of bay to the east. AB Salt marsh islands along the south shore of Nassau County reduce the fetch from every direction, significantly reducing wave energy during windy days that are common along Long Island’s south shore. A, B, Bay Park and Long Beach STP outfalls in Reynolds Channel Unfortunately, the integrity of the salt marsh islands in the western bays is compromised by excessive nitrogen pollution that is largely originating from sewage effluent. As described in Deegan et al. 20125, salt marshes respond to high levels of nitrogen by reducing below-ground biomass (roots). As root density declines, marshes are more susceptible to collapsing along the edges. This phenomenon is already evident throughout the western bays. Expansion of below ground roots is an important mechanism for how marshes keep up with sea-level rise. Most bay-front homes and docks in the western bays are not constructed to withstand the kind of chronic wind-wave energy that is typical in areas to the east that do not have protection from extensive marsh islands. If the western bays marshes continue to erode at the edges and fail to keep up with sea level rise, built infrastructure along the bay will be in serious jeopardy. Damage from chronic wave energy will prevent tying up boats up along piers and bulkheads which has historically been a primary asset for the value and desirability of these coastal residential properties. Therefore efforts aimed at reducing the amount of nitrogen loaded to the 5 Deegan L., et al 2012: Coastal eutrophication as a driver of salt marsh loss Nature 490, 388–392
  6. 6. Page 6 of 10 western bays through improvements to sewage treatment and re-location of the sewage outfalls are essential steps for rehabilitating the natural infrastructure that protects and adds resilience to Nassau County’s bay-side communities. A B C A: Harbor Isle: example of existing bay-facing development along the western bays showing docks and piers that are only possible because of the wave energy protection afforded by marsh Islands B: Marsh calving in the western bays: a symptom of weakened root systems C: Choppy wave conditions: common in parts of Long Island’s south shore bays absent of the protection of extensive marsh islands. The case for an ocean outfall The western bays and area in which the Bay Park and Long Beach sewage treatment plant outfalls discharge to Reynolds Channel are now proven to be poorly exchanged with ocean water (Wilson and Yang 20136) and much more environmentally sensitive than previously realized. The combination of continuous high sewage loads and poor flushing has led to a series of use impairments, the intensity of which radiate in severity around the outfall locations (Swanson et al. 2013). In addition to contaminants of emerging concern within secondarily treated sewage, the Bay Park and Long Beach sewage treatment plant outfalls contribute 94% (87.9% and 6.1% respectively) of the total dissolved nitrogen loaded to west bay (Swanson et al. 2013), and sewage is conservatively estimated to contribute 79.4 of the nitrogen to the entire western bays estuary complex (Gulbransen et al. 2013). This estuary is seriously impaired by nitrogen pollution. Degradation of the estuary has broad ranging impacts to the greater ocean ecosystem by negatively impacting potentially prime nursery and foraging area for economically and ecologically important fish and wildlife. In addition, excessive macro algae mats that accumulate in the bay eventually wash up and decompose on popular ocean facing public beaches such as Point Lookout. Experts testified at a Western Bays Education Forum in January 2013 that even if nitrogen reduction standards were imposed at the limit of technology, the location of the outfall pipe in the 6 Wilson R. and D. Yang. 2013. Quantitative Description of the Spatial Patterns in Residence Times within the Hempstead Bays Region. A Report to Battelle Memorial Institute and New York State Department of State. April 2013
  7. 7. Page 7 of 10 environmentally sensitive poorly flushed estuary in close proximity homes and businesses would still be a problem. Thus relocation of Bay Park STP outfall pipe to the ocean is the top recommendation of the scientific experts studying this issue (Swanson et al. 2013) and was the most highly scored alternative recommended by engineering consultants for Nassau County (CH2MHILL 2013)7. Hesitant of advocating for a project that might simply re-locate a problem from one location to another, members of the Western Bays Coalition seriously considered all other potentially viable options for an outfall location and/or resource recovery/beneficial reuse opportunities. What the Coalition has determined is that there is simply nowhere else in Nassau County to relocate over 50 million gallons per day of treated sewage. No other surface water body can handle this volume of flow. And $22 million dollars in experiments and pilot efforts to recharge aquifers in Nassau with sewage led to abandonment of this concept once results indicated that it was causing dangerous contamination of underground aquifers that represent the sole source of drinking water for almost 3 million Long Islanders (Wood 20068). Similarly, there is no-viable resource recovery option now or in the foreseeable future that could utilize anything remotely close to this volume of treated sewage. Documented disruptions at the sewage treatment plant in the last several years, not the least of which occurred during Superstorm Sandy, highlighted another very serious rationale for outfall relocation to the ocean. High volume sewage outfalls in close proximity to densely populated fishing and boating communities creates a significant human health threat under extenuating scenarios when plant operations fail to meet their discharge standards. While ideally future disruptions can be averted, history proves that failures do occur and we would be naive to believe they won’t occur again. If Sandy had occurred in the warm summer months, the discharge of raw and partially treated sewage in such close proximity to waterfront communities would have triggered serious human health crises at the exact time that residents and emergency response crews were already dealing with many other storm related crises. Installation of an ocean outfall is an additional safeguard for the health and safety of all waterside residents on the mainland, the bay islands, and on Long Beach Island because in the event of plant failure it is still possible to get sewage away from the most sensitive and populated areas. These facts provide the basis for The Nature Conservancy’s assertion that a new ocean outfall is an essential component of Sandy recovery projects associated with wastewater treatment failures in Nassau County. We believe that the regulatory requirements for a rigorous Environmental Impact Study for an ocean outfall should begin right away, and that careful consideration should be made to put the outfall in a location that has the fewest negative consequences, and construct it in a way that accommodates all of the anticipated sewage discharge needs of the region. Importantly, we assert that an ocean outfall will not negate the need to modernize Nassau’s aged waste water treatment and transport system through the additional components outlined below. The case for consolidation and expansion If Sandy taught us anything, it’s that valuable and critical infrastructure should not be located in highly vulnerable areas. This is the case for the two sewage treatment plants on Long Beach Island (Long Beach STP and the smaller Atlantic Beach STP). The treatment capacity at Bay Park STP should be expanded to include the processing of sewage from these two districts as well as continue with pre7 CH2MHILL. 2013. Nassau County Bay Park Sewage Treatment Plant Report for the Conceptual Study of Alternatives to Meet Future Nutrient Limits. Prepared for NCDPW. 8 Wood, C. 2006. Recharge for a Sole-Source Aquifer: The Successes and Failures of Cedar Creek Treatment Facility, Nassau County, Long Island. Hydrogeology: Wastewater Reclamation and Groundwater. Dartmouth Undergraduate Journal of Science
  8. 8. Page 8 of 10 Sandy plans to redirect sewage from Cedarhurst and Lawrence to Bay Park via a pumping station at Inwood. A pumping station that delivers untreated sewage to Bay Park STP could be located at the site of the current Long Beach STP and consideration should be made towards rehabilitating and repurposing Bay Park’s existing under-bay outfall pipe into a sewer main that delivers sewage from Long Beach to Bay Park for treatment. Thus all of the sewage from Long Beach, Atlantic Beach, Cedarhurst, Lawrence, and Bay Park Sewer districts would be treated at a single centralized plant that is re-engineered with state of the art sewage treatment technology and a new outfall pipe to the Atlantic Ocean. If it turns out that it is unfeasible to discontinue treating sewage on Long Beach, then the outfall from that facility should still be tied into the new ocean outfall at Bay Park. In addition to assuring that the re-engineered Bay Park can handle the expansion to cover the existing sewage districts, the plant should also prepare for eventually connecting the remaining pockets of un-sewered areas within and adjacent to these sewer districts, (such as Point Lookout). Projections should also factor in anticipated population growth in the Nassau County. Even if additional connections are phased in over time, it will be more cost effective to include these forecasted needs as part of the re-engineering and reconstruction now. Economy of scale will make it more efficient and more practical to have higher treatment standards, implement modern resource recovery techniques, and manage operations at one centralized plant. The open space surrounding the Bay Park Sewage Treatment Plant compound provide fortification and expansion options. Newsday Photo looking south The case for fortification By all accounts the low elevation and bay-side location of the Bay Park Sewage Treatment Plant requires that it be fortified for storm surge protection. To avoid potential damages in future storms at
  9. 9. Page 9 of 10 least some of this fortification needs to take place in advance of expensive re-construction of the plants’ electrical system which was completely destroyed when it was flooded with sea water during Sandy. It is my opinion that in its recent conceptual study of Bay Park Sewage Treatment Plant alternatives, CH2MHILL unnecessarily disregarded all re-engineering and advanced treatment/capacity options that would require additional facilities or an expansion of the footprint of the existing plant compound. Serious consideration should now be given to what, if any of the open land around the plant should be contained within the first level compound fortification and what if any could be re-purposed to achieve all the objectives laid out here. While a proposal to re-purpose any open space would most certainly require a thoughtfully facilitated dialog with the adjacent community, it is our impression that the community would be open to solutions that met their demands for noise and odor reduction and cleaner water. It’s probable that a high vegetated berm constructed around the compound would be perceived positively. Some of the owners of Sandy damaged homes immediately adjacent to the north side of the compound may even welcome conversations about voluntary acquisition options. Now is the time for all serious options to be on the table. The case for modernization There was a time when Nassau County residents were very proud of their state-of-the-art sewage treatment plants and school students would take field trips to learn about modern sewage treatment. The re-engineering of Bay Park STP provides an opportunity to once again utilize modern treatment techniques that improve the quality of the effluent, reduce noise and odor in the adjacent community, and recover and utilize resources such as but not limited to methane gas. Recovery of latent heat from generators has the potential to be used to accelerate biological nitrogen reactions in winter while modernization that increases energy efficiency or resource recovery may be eligible for assistance from US DOE or NYSERTA. Ultraviolet treatment should be used rather than chlorine to disinfect pathogens which will save in chronic chemical costs and be better for the environment. It is fully anticipated that over the coming decades there will be a need or desire to add on emerging treatment technology and/or separate portions of the effluent for beneficial re-use. The re-engineered plant should be designed with this in mind to facilitate future upgrades and additions. The case for stricter discharge standards and advanced treatment The installation of an ocean outfall is in no way intended to simply relocate environmental problems from the bay to the ocean. Although dilution will most certainly be greater in the ocean than it is in Reynolds Channel, the ocean beaches of western Long Island are prime recreation areas that are heavily utilized. It is likely that hundreds of millions of dollars will have be spent to rebuild the beach economy on Long Beach Island after Sandy. The days of permitting sewage discharges into any surface waters without strict treatment standards are at an end. As regulators formulate the precise level of treatment based on the location and volume of flow from this new ocean outfall it is important to recognize the potential for cumulative impacts of this outfall with the other two Long Island ocean sewer outfalls (Cedar Creek and Bergen Point). In addition, it is important to acknowledge that to the east 70% of Suffolk County is still relying on more than 400,000 septic systems and those systems need to be phased out as they are polluting drinking water supplies and near shore waterways. As waste-water treatment becomes centralized, at least for high density areas in western and eastern Suffolk County, there will be pressure to discharge more sewage effluent to the ocean either through Bergen Point or new locations. Simultaneously to the west, there are serious environmental issues surrounding the aging New York City sewage treatment plants that currently discharge into Jamaica Bay. Thus overtime it is likely that there will be additional ocean sewer outfall proposals from NYC. The importance of near shore ocean natural resources, the high value of the ocean beach, fishery, and recreation based economy of the area, and the potential for cumulative impacts among existing and anticipated ocean discharges should all factor into
  10. 10. Page 10 of 10 setting strict standards for the discharge of nutrients and other potentially harmful components of sewage effluent through the new ocean outfall. The case for professional operators with community oversight When Nassau County officials first proposed bringing in private companies to operate the County’s sewage treatment operations, many of the members of the Western Bays Coalition were uncomfortable with the idea and feared there would be a loss of oversight. After working on these issues for the last several years, however, the Coalition has come to recognize that an established, exceedingly experienced, qualified, professional contractor specializing in waste water treatment and management is an essential component to this solution. Another part of the solution is a community oversight board and digital real time dashboard for monitoring key parameters of discharged effluent. This kind of oversight will not only help achieve local goals, but can also facilitate an expedited and simplified process for meeting the plant operators and County’s reporting requirements to the state and federal regulatory agencies. If done correctly the monitoring dashboard could feed information directly to New York State in a way that is compliant and consistent with the Sewage Right to Know Law passed by Governor Cuomo in August of 2012. Conclusion The time to re-build, modernize, and storm proof the aging Bay Park sewage treatment plant is now. I urge the leaders at your agencies to assist Nassau County in securing the necessary federal aid to address all of the issues outlined above. Our communities and bays deserve a fully functioning state of the art sewage treatment facility. Superstorm Sandy has exposed the weaknesses of the Bay Park STP while offering a unique opportunity to repair failing infrastructure, upgrade inadequate treatment, and simultaneously increase resiliency and quality of life in the coastal communities in southern Nassau County. I recognize that to achieve these goals in a reasonable timeframe will require unprecedented cooperation and communication among federal, state, and county agencies. To the extent that it is helpful I offer assistance moving forward. Thank you very much for your attention to this very important issue. Sincerely, Carl LoBue Senior Marine Scientist The Nature Conservancy on Long Island 250 Lawrence Hill Rd, Cold Spring Harbor NY 11724 clobue@tnc.org, (631) 367-3384 ext 113 cc Honorable Shaun Donovan, Secretary HUD Honorable William Fugate, Administrator FEMA Honorable Gina McCarthy, Administrator EPA