DC’s environmental agency will not require an air quality permit “at this time” for DC Water’s sewer pipe relining project in the Soapstone Valley.
The reason, ANC 3F commissioners were told at their May 17th meeting, was that the DC Department of Energy and the Environment (DOEE) did not have the information it needed about the cured-in-place pipe, or CIPP, process to write a permit.
“Our permits are fairly detailed. We establish emission limits. And when we don’t have sufficient information to do that, we can’t reasonably write an air quality permit,” said Stephen Ours, the head of DOEE’s Air Quality Permitting Branch.
What DOEE will do is require continuous air quality monitoring and testing of emissions from the pipe curing process as the work is being done, making the Soapstone Valley, in effect, a field laboratory for regulating CIPP.
DOEE and DC Water sought information from other agencies around the U.S., but found “no one else in the country… obtaining air quality permits for this kind of work,” said Will Elledge, a DC Water project and design manager. Elledge and Ours said other jurisdictions and regulators are interested in what they find.
DOEE and DC Water’s explanations and reassurances did not satisfy ANC 3F Commissioner Dipa Mehta, or Mitch Baer, a Park Van Ness resident and air quality expert with 50 years of regulatory experience at the federal, state and local level.
“So it’s possible that you’re going to allow DC Water to start the CIPP process, proceed to use it, and wait until you have information that is of concern to you before you even consider an air quality permit,” Baer said.
“I think that you’re putting public health and welfare, especially in the homes and schools and buildings that are adjacent to the lateral sewer lines, in jeopardy by not knowing enough about the process and its impacts on the both ambient air quality and the indoor air quality. And I for one am not comfortable with how you’re proceeding.”
Soapstone Valley neighbors and ANC 3F have been expressing concerns about emissions from thermal CIPP processes and urging DC Water and the National Park Service to undertake further studies for some years. At the end of the May 17th ANC meeting, the commissioners voted 6-0 to approve a resolution urging DOEE to require an air quality permit. “I frankly was hoping that we wouldn’t actually need to put forward this resolution,” said ANC Commissioner Mehta, “but… I for one am very deeply troubled that an air quality permit is not in the works because there is not enough information to write an air quality permit.”
As recently as April 12th, DOEE was still reviewing whether an air quality permit was required under DC regulations. It stated in a letter to DC Water that it was “unable to make a determination based on available information.” On April 19th, DC Water provided DOEE with an outline of its monitoring process and stated that it would follow up with more details. Those details were provided to DOEE on May 17th, the date of the ANC meeting. Ours said DOEE had not yet had a chance to review them.
DC Water’s plans for emissions monitoring and testing do not include air quality testing inside individual buildings. In its April 19th letter to DOEE, it said the effort to block any sewer gases from escaping would include advising homeowners on how to make sure their P-traps are filled, and plugging any lateral sewer lines that connect directly to the main sewer.
Baer said a permit “should detail the monitoring of ambient air quality in the vicinity of the process machinery in and around the main sewer lines and the lateral sewer lines extending into the surrounding neighborhoods. The permit should also include provisions to maintain and protect indoor air quality in homes, buildings, stores, schools and apartments. The permit should set standards for ambient and indoor air quality impacts from the operations, require real-time monitoring and data handling, and procedures when exceedences of the standards are measured.”
DC Water previously agreed to use hot water instead of steam to cure the plastic liner, which “virtually eliminates any emissions,” Elledge said. “We’ve gone to a non-VOC resin. We are monitoring. All three of those are above and beyond what the standard in the industry is. Because of the monitoring plan, we will know if those VOCs reach action limits. And we will have plans in place to respond to that.”
Elledge said the CIPP work would begin in July, at the earliest.