The state of Maryland's plan to dispose of 18 million cubic yards of dredged material at a site just north of the Chesapeake Bay Bridge is sailing into rough waters.

Officials for two federal agencies reiterated this week that they have concerns about the proposed dumping of sandy soil cleared from the approach channels of the Baltimore Harbor into the open waters of the bay.

Earlier this month the U.S. Fish and Wildlife Service sent a blunt letter to the Army Corps of Engineers objecting to the use of the area, known as Site 104, for getting rid of dredge material. With Rep. Wayne T. Gilchrest (R-Md.) threatening to block federal funding for the project, the Maryland Port Administration is now facing its most serious challenge to a central aspect of the state's dredging program.

The latest objections to Site 104 were voiced by officials of the Environmental Protection Agency and the National Marine Fisheries Service at a July 6 meeting of the Chesapeake Bay Program, a tri-state commission that oversees efforts to preserve the bay. The federal regulators criticized the Corps of Engineers' Draft Environmental Impact Statement on Site 104 on several counts.

Thomas Slenkamp, acting deputy associate director of environmental programs at the Philadelphia-based regional office of the EPA, faulted the Corps for not comparing the impact of dumping at Site 104 with alternative sites. Like the Fish and Wildlife Service, Slenkamp cited the hazards of the nitrogen compounds that will be released from the muck as it disperses into the bay. These compounds, biologists says, contribute to algae blooms and fish kills.

"It is obvious to us that nutrient loading will result from alternatives, but we think those should be examined in the same detail," Slenkamp said.

John Forren, an EPA ecologist working on the review, said that the agency will rate the environmental consequences of the project and the quality of the Draft Environmental Impact Statement by July 31.

The Site 104 project, he said, will be given one of four grades: LO (lack of objections, which means approval); EC (environmental concerns); EO (environmental objections); or EU (environmentally unacceptable.)

The EPA also will give one of three grades to the Corps of Engineers' draft environmental impact statement, he said.

A grade of 1 means the report is judged adequate, providing all the necessary information and considering any other alternatives. A grade of 2 means that the report has insufficient documentation. A grade of 3 means the document is inadequate in the view of the EPA.

Forren said that Slenkamp's comments were part of the agency's efforts to advise the Army Corps of Engineers how to avoid an adverse rating, particularly an EU-3.

"It would be premature to conclude EPA is going to come out against the project," Forren cautioned. "The technical review is going on."

At the same meeting, Pete Colosi, from the northeast regional office of the National Marine Fisheries Service in Massachusetts, stressed that his agency had not reached any final position but said, "we feel that the impact on bay fisheries as it relates to this project would be significant."

Colosi said the nitrogen added to the bay by dumping, estimated by the Fish and Wildlife Service at 1.8 million pounds, would run counter to the long-term goal of reducing nutrients in the bay.

If the EPA issues an EU-3 grade, then the matter of Site 104 will be referred to the President's Council on Environmental Quality, which can overrule the Corps of Engineers and block the project. In its written objection to the draft environmental impact statement, the Fish and Wildlife Service also threatened to refer the issue to the council.

Gilchrest, who came out strongly against Site 104 in May, said that he would introduce an amendment in Congress to forbid the Corps of Engineers from spending any money on Site 104 if that is necessary to block the project.

"I don't want to do that," he said. "But if you're at the Alamo, you do what you have to do."

Frank Hamons, manager of harbor development for the Port Administration, defended the Site 104 plan.

"The site was selected by a working group composed of experts from around the bay and from some of the conservation associations. Fish and Wildlife, the EPA and [the Maryland Department of Natural Resources] all participated. You can't do a feasibility investigation on every site."

Doug Garman, a spokesman for the Corps of Engineers, said, "We are reviewing all comments from the public and the agencies and will be addressing and evaluating them in the final draft, which is due in the late fall."

The Corps of Engineers is accepting public comment on the Site 104 proposal until July 31. Direct any questions or comments to Wesley Coleman, Corps of Engineers (Attn: CENAB-PL-P), P.O. Box 1715, Baltimore, MD 21203-1715. E-mail to wesley.e.coleman@usace.army.mil or fax 410-962-4698.