by David Jonas Bardin
Ten years ago, when I served on its board of directors, DC Water started focusing on aging, gravity-flow sanitary sewers laid in beds of creeks. DC Water gave sewers in Soapstone Creek a high priority.
To inspect those sewers and assess their condition, DC Water turned to a pair of engineering firms it often consulted (Delon, Hampton & Associates and Greeley and Hansen). In March 2011, DC Water issued their assessment.
DC Water gave me a copy in 2013 when they met with ANC commissioners and other neighbors to discuss the information. It is a rich, thoughtful document with data, context and analysis. And it is quite unlike the environmental assessment (EA) for the Soapstone Valley sewer rehabilitation project. DC Water prepared the EA for the National Park Service to issue to the public on June 4th this year.
The 2011 report said a subcontractor had inspected the insides of 4,519 linear feet of pipe using closed-circuit television. It gives a wealth of backup detail to check out. For example, adding up details one can learn that 2,468 linear feet of inspected pipe are on NPS land.
Not so this 2019 EA. It swells up DC Water’s project to “approximately 6,200 LF” and gives you no way to check or analyze that mysterious, much-repeated number.
The 2011 report described each of six stream crossings separately, carefully. This 2019 EA lumps them together. It puts on its cover our worst situation: Crossing #1 where a once-buried, concrete-encased pipe was entirely exposed by erosion to the point that creek water flows underneath. It withholds any facts about five other crossings, which the 2011 report taught are still buried or have only their casing top exposed.
EAs are supposed to provide information which decision-makers later use. If this EA won’t disclose that an encased pipe is still buried at a stream crossing, how do we strike an informed balance? How does anyone weigh whether it is appropriate to cut down more trees so heavy equipment can move in with rocks and soil to bury that pipe a little deeper?
Both the 2011 report and EA recommend lining the old sewer pipe trenchlessly, using cured-in-place-pipe (CIPP) technology, but with quite a difference. The 2011 report recommended: “Rehabilitate approximately 4,000 ft of the buried 18” sanitary sewers … with UV CIPP or similar trenchless method.”
This 2019 EA supports rehabilitation of approximately 6,200 feet with CIPP – but it only supports hot water or steam curing technology. It never mentions UV, or ultraviolet, curing technology which may have environmental advantages and not need heavy equipment. UV was at the head of the line in DC Water’s 2011 report. Yet this 2019 EA hides it as a possibility to consider. Why?
Because some 955 linear feet of sewer are already lined, DC Water has at least six separate and possibly unconnected lining sub-projects for which it seeks EA blessing. For example, with details available only from the 2011 report one can see that DC Water will separately line 1,391 linear feet of 10-inch and 15-inch pipe under Audubon Terrace NW, which emergency CIPP lining in 2015 isolated, so to speak, from DC Water’s backbone 18-inch system. Here UV curing, akin to what my dentist uses for resin fillings, might be superior to hot water or steam for some or all.
This EA doesn’t even list DC Water’s 2011 assessment report in its bibliography. In my formal comments to NPS, I call that a serious mistake.
I’ve given them the text only of DC Water’s 2011 assessment report and ask that DC Water post it online in full – including graphics, tables and appendices – and that NPS add a link to its EA Documents list.
I also ask NPS to modify the EA to reflect that 2011 report and face up to discrepancies.
Public comments raising the issue of these discrepancies and asking for modifications in the EA could push DC Water and NPS to do just that.
NPS is accepting public comments on the Soapstone Valley Park Sewer Rehabilitation Environment Assessment through August 2nd.
David Jonas Bardin is a retired member of Arent Fox LLP. He served on DC Water’s Board of Directors from 2001 to 2011 and as an ANC Commissioner from 1999-2004. From 1974-1977 he led New Jersey’s Department of Environmental Protection. He did active duty in the U.S. Army from 1956-1958.