saEPA
          United States
          Environmental Protection
          Agency
          Region I
          JFK Feder
          Boston MA 02203
Environmental
Impact Statement
Final
          Wastewater
          Collection and
          Treatment Facilities,
          Nantucket,
          Massachusetts

-------
Appendix A
Synopsis of Public Hearing

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                  Synopsis of Nantucket Public Hearing
  The Public Hearing for the Nantucket DEIS/201 Facilities Plan was
  held at 7 pm, January 8, 1981, in the Nantucket Town and County
  Building.  Eight townspeople were in attendance and eight members
  of the 201/EIS team attended (see attendance list attached).

  A large public advertisement had been run December 4, a front-page
  notice was run on December 31, a related news article on the sewer
  grants was run on January 1, and a news article on the Hearing and
  the EIS cost-savings was run on January 8, the day of the Hearing.

  Robert Mendoza  Hearing Officer, opened the meeting with a brief
  statement explaining the events leading up to the Public Hearing
  and laying the ground rules as to how the hearing would be conducted.
  Mr. Mendoza then introduced Mr. Fred Roland, of the firm Shaeffer &
  Roland, Inc., the 201 Facilities Planning Engineer, who presented a
  brief overview of the treatment alternatives and recommended options
  contained in the Nantucket 201 Facilities Plan.  Bill Richardson,
  EIS Project Manager, then gave a slide presentation which reviewed
  the water sampling program, need for an Islandwide water resource
  management program, identification of future sewer service areas,
  recommended treatment process, impacts to groundwater at the filter
  beds and need for an ongoing monitoring program at the beds.  A
  clarification was made on the costs of the recommended alternatives
  and methods for calculating the actual user fees by both Richardson
  and Roland.

  Following the presentations, Mr. Mendoza opened the hearing up to
  the general public for comment.  (Note:  Response to comments raised
  at this hearing have been responded to in Chapter 5 of this Final
  EIS.)

  The following comments were raised:

A-l.  Mr. Walter Knott  representing the Board of Selectmen, wanted
      to know what percentage of nitrates was found in the groundwater
      of Madaket and if there was any danger to anybody's home.

A-2.  Mr. Knott asked if there was any saline found in Madaket
      groundwater.

A-3.  Mr. Knott asked if the use of chlorine or other chemicals at
      the Surfside and Siasconset filter beds posed any danger to
      drinking water in areas where a lot of, houses are being built.

A-4.  Mr. Knott asked how the proposed sewer user tax was arrived at,
      and if it would be possible to look at user fees from other

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                                   -2-
       communities in the State, comparable in size to Nantucket,  for
       comparison.

 A-5.  A question was asked from the floor as £o whether the sewerage
       system in Siasconset is going to  include the Codfish Park area.

 A-6.  Mr. Alfred Bornemann asked why a  cost credit was not assigned
       to the beneficial uses of wastewater and sewage sludge.

 A-7.  Ms. Ellen Powers asked how many tons of sludge would be produced
       annually and if it could all be utilized on Nantucket.

 A-8.  Mr. Michael Driscoll wanted to know how much sludge is presently
       generated at the existing filter  beds and what would be the
       advantage of removing solids from the wastewater, through
       primary treatment, prior to applying the wastewater to the
       filter beds.

 A-9.  Mr. Driscoll asked if the tidal action that exists at the
       present filter beds isn't the most effective way of promoting
       cleanliness of the soil and isn't that what keeps the filter
       beds clean.

A-lO.  Mr. Driscoll wanted to know what  the effect on the community
       would be if the emergency outfall to Brant Point were closed
       and main and emergency power goes out during a rainstorm.

A-ll.  Mr. Driscoll asked why all sewage is directed to the downtown
       pump station as opposed to diverting wastewater flow away from
       the downtown area and directly to the filter beds.

A-12.  Mr. Driscoll asked why the existing filter beds at Surfside
       have to be raised as they seem to be working fine now.

  A copy of the Public Hearing transcript is available for review  at
  the Nantucket Ttown and County Building.

-------
ATTANDANCE



NANTUCKET EIS/201 HEARING



January 8, 1981






NAME



Fred Roland



Bill Richardson



Chet Janowski



Alan Slater



Paul Pinault



Mark Thompson



Jerry Potamis



Bob Mendoza




C. Pearl



Deborah Nicholson



Robert Wareham



Walter Bassett



Walter Knott



William Klein



Michael Griswold



Ellen Powers
ADDRESS



Sheaffer & Roland, Chicago



A-N, 150 Causewat St., Boston



U.S. EPA



Mass. D.W.P.C.



U.S. EPA



Anderson-Nichols



U.S. EPA



U.S. EPA




Siasconset




Monomoy



25 Hussey, Nantucket



20 Fair St., Nantucket



15 Hussey, Nantucket



Broad St., Nantucket



22 Broad St., ACT



Channel 3 Cable TV

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Appendix B
Agency Comments

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                                                                               B-1
                    DEPARTMENT OF THE ARMY
                 NEW ENGLAND DIVISION. CORPS OF ENGINEERS
                            424 TRAPELO ROAD
                      WALTHAM, MASSACHUSETTS O2254
  REPLY TO
  ATTENTION OF:

NEDPL-I
30 January 1981
Mr. Robert Mendoza
Environmental and Economic Impact Office
EPA Region I
JFK Federal Building
Boston, Massachusetts  02203
        FEE ' 3 198V
Dear Mr. Mendoza:

We have reviewed your Draft Environmental Impact Statement  (EIS)  for
the Wastewater Collection and Treatment Facilities on Nantucket Island,
Massachusetts.  The information presented is sufficient for our public
interest review.  We generally support the nonstructural Madaket  "M-3"
alternative which is less costly and has no impact on the Madaket Creek
wetlands.  If any of Alternatives "M-1A", "M-1B", "M-1C", or  "M-2" is
chosen to meet future needs, a Department of the Army permit  will be
required under Section 404 of the Clean Water Act.  There would be no
Corps of Engineers involvement with any of the Nantucket Center or
Siasconset Alternatives.

Thank you for the opportunity to comment on your Draft EIS.   If you
have any questions, please call Mr. David Tomey, of my staff, at  (617)
894-2400, extension 234, or Mr. Ralph Atkinson, of our Regulatory
Branch, at extension 332.
                                           Sincerely,

-------
   FEDERAL ENERGY REGULATORY COMMISSION
               WASHINGTON  20426
                                        IN REPLY REFER TO:
                                                         B-2
<6
                   December 3,
                                 RECEIVED

                                    OtC - n ix^o

                                      REGION I
                                    OFFICE OF THE
                                REGIONAL ADMINISTRATOR
Mr. William R. Adams, .Jr.
Regional Administrator
U.S. Environmental Protection Agency
Reg ion 1
J.F. Kennedy Federal Building
Boston, MA  02203

Dear Mr. Adams:

     I am replying to your request of November 18, 1980 to the
Federal Energy Regulatory Commission for comments on the Draft
Environmental Impact Statement on the Wastewater Collection and
Treatment Facilities, Nantucket, Massachusetts.  This Draft
EIS has been reviewed by appropriate FERC staff components upon
whose evaluation this response is based.

     This staff concentrates its review of other agencies' en-
vironmental impact statements basically on those areas of the
electric power, natural gas, and oil pipeline industries for  .
which the Commission .has jurisdiction by law, or where staff
has special expertise in evaluating environmental impacts in-
voled with the proposed action.  It does not appear that there
would be any significant impacts in these areas of concern nor
serious conflicts with this agency's responsibilities should
this action be undertaken.

     Thank you for the opportunity to review this statement.

                              Sincerely,
                  "Ja'dk M. Heinemann
                  Advisor on Environmental Quality

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a *
°%
  \        DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT                   B~3
!y * 5
                               BOSTON AREA OFFICE
                      BULFINCH BUILDING, 15 NEW CHARDON STREET
  -'3oa *•-               '      BOSTON, MASSACHUSETTS 02114
 REGION I               '
                                                                  IN REPLY REFER TO:
 Mr. Robert Mendoza
 Environmental and Economic
   Impact Office                              rC   -qT;
 EPA, Region I                             CI --' v
 J.F.K. Federal Building
 Boston, MA  02203

 Re:  Draft EIS, Wastewater Treatment Facilities,  Nautucket,  MA

 Dear Mr. Mendoza:

 The above draft EIS which was sent  to HUD Regional  Office has been
 referred to the Boston Area Office  of HUD for review and comment.

 This office has reviewed the draft  EIS  and  finds  no conflicts with HUD
 goals and objectives.

 Thank you for the opportunity to  review and comment on the draft EIS.

 Sincerely,
 idwarfMachado
 Environmental Officer

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                      U.S. DEPARTMENT OF TRANSPORTATION
                           FEDERAL HIGHWAY ADMINISTRATION
                                     REGION ONE
                           31 St. James Avenue-Room 211
                           Boston, Massachusetts  02116
                                                                                     B-4
Draft Environmental Impact Statement
Wastewater Treatment Facilities
Nantucket, Massachusetts
                               HEV-MA
                                      January 28, 1981
Mr. William R. Adams, Jr.
Regional Administrator
EPA Region 1
John F. Kennedy Federal Building
Boston, Massachusetts   02203

Dear Mr. Adams:

We have reviewed the subject Draft EIS and have no comments. Thank you for the
opportunity to review this document.

                                      Sincerely yours,

                                      N. J. Van Ness
                                      Division Administrato
                                By:
Edwin P. Holahan, Assistant
Division Administrator
cc: Mr. Robert Mendoza
Environmental and Economic Impact Office
EPA Region 1
J.F.K. Federal Building
Boston, Massachusetts  02203

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                     DEPARTM ENT OF TRANSPORTATION                          B- 5
                        FEDERAL AVIATION ADMINISTRATION
                                NEW ENGLAND REGION
                              12 NEW ENGLAND EXECUTIVE PARK
                                BURLINGTON. MASS. O18O3
January 16, 1981                                       Tel:  (617) 273-7233
Mr. William R. Adams, Jr.
Regional Administration
U.S. Environmental Protection
 Agency
Region I
JFK Federal Building
Boston, MA  02203
Dear Mr. Adams:    ,

In response to your letter of November 18, 1980, we have reviewed the
Draft EIS for waste water treatment facilities, Nantucket, Massachusetts,
in coordination with the Nantucket Airport Commission.

We would like to point out that the Site #5 listed as a possible treatment
site in Figure - R, "Alternate Land Disposal Sites" (following page 2-6)
has severe constraints in terms, of financial implications and future
operations and development of the Nantucket Airport.  In this regard the
Nantucket Airport Commission has directly communicated with your office
(copy enclosed).

We do realize that the alternative Site #5 is not the recommended site,
but nevertheless, we consider it important to inform you that this site
has important implications for the future development of Nantucket Airport,
and therefore should be dropped from any further consideration.

We appreciate the opportunity to review the potential impacts of the proposed
project on aviation activities, and should you have any further questions,
please contact us.

                                        Sincerely,
                                        VINCENT A. SCARANO
                                        Chief, Plans/Programs Branch
Enclosure

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                                                                                 B-6
              United States Department of the Interior
                           OFFICE OF THE SECRETARY
                               Northeast Region
                               15 State Street
ER80/H»22                  Boston, Massachusetts  02109
        Mr. William R. Adams, Jr.             January 14, 1980
        Regional Administrator
        Environmental Protection Agency
        Region I
        J.F.K. Federal Building
        Boston, Massachusetts 02203

        Dear Mr. Adams:

        This letter represents the Departmental comments on  the draft environmental
        statement for wastewater collection and treatment facilities in Nantucket,
        Massachusetts.

        Impacts resulting from treatment facilities  and disposal  sites as well
        as proposed mitigation have not received adequate discussion in the
        draft statement.  Discussion of impacts should include those resulting
        from any ground disturbing activities and visual impacts  and should be
        related directly to specific sites or structures.  For instance, it is
        noted on page 4-12 that a spray irrigation system near Miacomet Pond
        could have significant effects on archeological sites.  What sites would
        be affected, and what is the significance of these sites? What are the
        impacts to the sites, and what measures are  proposed for  mitigation?

        We concur with the recommendations cited in  the Historic  Archeological
        Analysis (Appendix B), that further studies  be conducted  in undisturbed
        areas and in areas near known archeological  sites.   Results of these
        studies should be addressed in the final statement.   The  State Historic
        Preservation Officer (SHPO) should be afforded an opportunity to review
        and comment on the historic-archeological analysis,  on any future studies
        conducted, and on impacts and proposed mitigation.   These comments
        should be documented in the final statement.  The SHPO for Massachusetts
        is Ms. Patricia L. Weslowski, Executive Director, Massachusetts Historical
        Commission, 294 Washington Street, Room 516,  Boston,  Massachusetts 02108
        (617-727-8470).

        The proposed plan will have no significant impact on the  mineral resources
        of the area.  However, the draft includes no statement in this regard.
        We recommend that a subsection concerning mineral resources be included
        in Chapter 4, Environmental Impact Evaluation.

                                           Sincerely,
                                           William Patterson
                                           Regional Environmental Officer

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                                    B-7
   DATE:  December 12,  1980
SUBJECT:  Nantucket:  Draft EI3 Review
   PROM'
         Steven J.  Koorse,  Environmental  Engineer(
         Drinking Water Branch

         Chester L. Janowski,  Jr.,  Environmental  Engineer
         Environmental Impacts Office
         The draft Environmental  Impact  Statement  for  Nantucket, Massachusetts
         has been reviewed within  this branch.  With the exception of  our concerns
         over Madaket, previously  expressed in  a memo dated February  5, 1980 from
         myself to Wallace  Stickney,  we  have no  further  comments  to  offer.

         Should you  have  any  questions,  feel free  to  contact  me  at  x6486.
 PA Form 1320-6 (Rev. 3-76)

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                          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   BJate:  January 19, 1981

Subject:  COMMENTS ON NANTUCKET DRAFT EIS

   From:  Paul Pinault, Project Engineer
          MA Engineering Section
     To:  Chet Janowski, Project Officer
          EIS Office
   Thru:  Anthony V. DePalma, Chief
          MA Engineering Section
\l
JAN 261931
                                                    B-8
          We offer the following comments on the above referenced document:

          1.  The Table  of Contents  has many  errors  (some sections  do  not match  up
          with page numbers)

          2.  There  are  numerous  typographical errors  throughout the  document,  ex.
          page 13 should read 10 mg/1 nitrate not 20.

          3.  The EIS must  not  only address  the impacts  of  the treatment  facilities at
          Surfside and Siasconset  but must  also address the impacts  of the  proposed
          sewer rehab, work in  Nantucket Center and the proposed sewer extensions  for
          the Center and Siasconset.
          4.  Page 1-19,  Section 1.4.4, paragraph two  states that  "primary  treatment
          which removes all  solids".   This is  not true,  only  gets  30-40% removal  of
          suspended solids and little or no removal of disolved solids.

          5.  Based upon the previous Region I  legal  opinion  the  facility plan and the
          EIS must evaluate .secondary treatment with  discharge to the ocean,  at  least
          on a preliminary cost basis.

          6.  Page 2-5  states  the  average  concentration  of  septage is 600 mg/1.  But
          of what BOD, SS?

          7.  Figure R should show the  Siasconset well field  also.

          8. • Table 8 should have an index  which explains  all of the numerical headings
          and factors, without this the Table is useless.

          9.  Page 2-11 Section  2.3.5 - No Action - the only  reasons given not to  keep
          the status quo  is that if the town does not  improve the  level  of treatment,
          the State and EPA will not  fund anything.  This  is not true, there  should
          also be a discussion on the environmental reasons  i.e.  minimize  bed area and
          maintenance, minimize potential odor  problems,  better control of the O&M  of
          the facility, restricted  access  to   beds,  production  of a  useful  compost
          byproduct,  monitoring  of  groundwater  movement and quality, ownership of the
          site, etc., etc.  This same comment applies  whenever the proposed alternative
          is discussed in  the document.

          10.  On Majjiaket,  which alternative has the Town  selected?   Will  or  should
          EPA require the  Town to do  anything  in this area in the record  of  decision?

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                                   -2-
                                                                                    B-8

11.  Page 2-14 No Action - statement does not make sense.

12.  Page 2-15  Section 2.6,3.1  - wording  very confusing  on cost of  N-l
vs. N-2.

13.  Page  2-16  Section  2.6.3.3  -  Alternative  M-2  should  be  defined.

14.  On table 12 - Is the total flow in mgd, gpd?

15.  Section  2.7.3  - is  extremely confusing and difficult  to  understand.
I thought that an EIS was  supposed to  be easy to read for an average person.

16.  Page 2-25  paragraphs one  through four gets to  the main reasons  for
justifying the  proposed  pretreatment   systems and this should be  expanded
and highlighted  whenever  the  proposed  alternatives   are  discussed.   See
comment No.  9.

17.  Page 2-27  sludge composting  with woodchips  is proposed but  how much
bulking material is  needed?   is it available?   if not how does  this affect
user costs?   Composting area  should be located  on site map and  all impacts
of the operation should be discussed.

18.  Page 2-27  Mitigation -  this section is totally  inadequate.   The  new
NEPA regulations  are very  clear that  an EIS  should  outline  all of  the
mitigation measures  needed  to  minimize  impacts.   This includes  standard
mitigation measures  like  scheduling  of  construction  and  control  of dust
and noise to  special  measures  such as conducting  a Phase II Archaeological
surey prior to  construction, prohibiting  sewer  hookups  in  sensitive areas,
burying of existing sludge piles, etc., etc.
             r
This section  notes that the  State and EPA will determine  what  buffer zone
is eligible, but the  EIS  should recommend  from an  environmental  point  of
view what the minimum buffer zone should be for each site.

19.  Page 3-8,  for  Siasconset it states that the  limit of the plume is two
times the calculated  value which was  80  ft.  Therefore, this would be 160
ft. but  it  states its equal  to 250  ft.  Which is  it?  Also, what is the
lateral extension of  the  plume?  The  site plan does  not indicate what the
plume extent  is at Siasconset.

20.  Chapter  4  -  Impacts -  NEPA  requires that  the  following  items  be
addressed - environmentally significant agricultural lands, wild and scenic
rivers, conformance with CZM, and endangered species.

21.  Water Quality  Impacts -  wherever this  topic  is discussed there should
also be  a  section   on  the  proposed  impacts  on   surface  water  quality.

The impacts  of a  Case  III   zone on  groundwater  quality  should  also  be
elaborated on i.e.  zone  is  non-potable  and  Town  will  be  responsible  to
ensure that this  area is not  used for water  supply  in the  future and if
there are wells within the zone  how  they will have  to be  eliminated  and
put on an alternate water supply, etc.

It should also  be mentioned  that the  State  will  permit each facility and
require periodic monitoring of groundwater quality.

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                                     -3-
                                                                                    B-8

22.  Page 4-5 - it is stated that the access road will be paved.   This should
be clarified to note  that the road within  the  treatment site will  be paved
and not the whole length of Sewer Bed Road.

23.  Page 4-6  and 4-17 Does  the $45/yr. and $52/year  figures  include debt
service plus O&M?

24.  The  facility plan states  that  chlorination  is  not  needed  for  disin-
fection.  The EIS should access whether or  not  disinfection is needed and if
it is what the impacts are.

25.  Under the  No Action Alternatives the  draft  EIS frequently refers back
to the proposed alternative as having the same impacts, and this is not true,
because in general the proposed alternative  involves construction and general
improvements and the No Action does not.

26.  In the discussion  of Coastal  Zones  and Wetlands and  Floodplains EPA's
policies should also be discussed i.e. prohibition of future growth in sensi-
tive areas from using any facilities that we participate in, etc.

27.  Page 4-16  Land  Induced Growth  - I  disagree  with the  statement that
increasing the  size  of the  sewer  system  in  Siasconset will not  have  any
affect on growth.

28.  Page 4-29 Water  Quality  impacts of alternative M-2.   It  states ground-
water conditions  would  not change  by extending a  public  water supply into
the area.  But wouldn't this  add  an additional  amount of water  from outside
of the  Manaket  area,  and  in turn increase  water  levels through on-site  re-
charge?

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EDWARD J. KING
   GOVERNOR
JOHN A BEWICK
   SECRETARY
                  tie
                            (OQnwnc-nwcaM/i.

                       xcattirfi  ([J/^icf  of

                                400

                                                           ftf- Sw/frrr
                               ollon,
                                                         02202
                 CERTIFICATE OF THE SECRETARY OF ENVIRONMENTAL AFFAIRS

                                        ON

                          DRAFT ENVIRONMENTAL IMPACT REPORT
          PROJECT  NAME:
                                    Wastewater Treatment Facilities for
                                    Nantucket Center & Siasconset.	
B-9
          EOEA NUMBER:
                                     03940.
          PROJECT PROPONENT:
                                     Nantucket  Board  of  Selectmen
          DATE NOTICED IN MONITOR:
                                     December  8.  1980.
               The Secretary of Environmental  Affairs  hc.irein  issues  a  statement
          that"the Draft Environmental  Impact  Report submitted  on  the above-
          referenced project dd"es  adequately and  properly  comply with  Massachusetts
          General Laws,  Chapter 30, Section  62-6211 inclusive,  and the regulations
          implementing MEPA.
                                          J011
     DATE/
c.c. Robert Mendoza - EPA
     Bill Klein - Nantucket Planning Commission.
     Brian Donahoe - WPC ,   Edward Reilly, CZM.
     FORM I)   Enclosed: CZM comments.

-------
 COASTAL ZONE


  MANAGEMENT
                             \Q
                                                                                   B-10
                           Executive  dJtnce  Of  0nv won men/at Stf/fa



                                     400  (bamwif/qe  y4 •


                         7>\
   FROM:  Edward J.  ReillK* Director




   DATE:  January 7,  1981




SUBJECT:  Nantucket  Wastewater Facility - MEPA //03940
       Coastal Zone Management  supports  the findings and conclusions of



the Nantucket Wastewater Collection  and  Treatment Facilities EIS/EIR.



The recommended option of constructing primary treatment facilities



with disposal by rapid sand  infiltration at Siasconset and Surfside



are consistent with all CZM  policies.
                                                                RECEIVED


                                                                     JAN   V r'dl

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OFFICE OF THE DIRECTOR
                                op G>M0t/
                                /
                                  i'ew of Wa
                                                                                     B-11
                                                              ff
                                                                        '«/*
                                          (7
                                                              December 19, 1980
                                                        RECEIVED
                                                            I •• '
                                                              REGION I
                                                       D    O™E OF T
                                                       REGIONAL AD,vilNiST;vATOR
Mr.  William R. Adams, Jr.
Regional Administrator
U. S. Environmental Protection Agency
Region I
J. F. Kennedy Building
Boston, Massachusetts,  02203

Dear Mr. Adams:
         This is to submit the following comments pertaining to the Draft EIS -
      Wastewater Cbllection and Treatment Facilities,  Nantucket,  Massachusetts.

         1.  Page 1-23, 1. 5. 3 - Floodplains or flood prone areas should be
      added to the list of land with constraints.  A further constraint may be pro-
      vided by DEQE Drinking Water Regulation 2lb, which provides that the
      owner of a public water supply shall control the use of the land within 400
      feet of a gravel packed well.

         2.  Page 1-25, 1st paragraph, last sentence.   This is misleading since
      there are  no restrictions presently imposed under the Wetlands Restriction
      Act. (M. G. L. C 140 S 40A.)

         We hope that this assists your agency in its efforts.

                                              Sincerely yours.
                                                       8
                                              Charles F. Kennedy
                                              Director & Chief Engineer
      CFK/WFB/hrb

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         IIIIIII
MASSACHUSETTS
        HISTORICAL
    ^COMMISSION
                                                                 B-12
                 COMMONWEALTH OF  MASSACHUSETTS
                 Office of the Secretary of State
                 294 Washington Street
                 Boston, Massachusetts
                 021Q8
                 617-727-8470
MICHAEL JOSEPH CONNOLLY
Secretary of State
                             June 10,  1981
Curt J.anow'ski
EPA
J.F.K.  Building
Boston, MA  02203

RE:  Nantucket, Water Pollution Control project, proposed
     trunk sewer replacement

Dear Mr. Janowski:

Thank you for supplying the Massachusetts Historical Commission
with information on the proposed trunk sewer replacement in con-
junction with the Nantucket water pollution control project.

MHC staff have reviewed the project and feel that this project
is unlikely to affect significant historic or archaeological re-
sources.  No further review in compliance with Section 106 of the
National Historic Preservation Act of 1966 is required.

If you have any further questions, please feel free to call
Valerie Talmage, State Archaeologist.
                             Sincerely,
                             Patricia L. Weslowski
                             Executive Director
                             Massachusetts Historical Commission
                             State Historic Preservation Officer
PLW/VT/pb

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                                                                                 B-13
                                            S &'   s    J &fi  /
                                          ty iTvsedfo a/tff <^/a/tA:4


                                             yStulctvna, ^ovewiment  venter-
- V-'                                                  v
 ••,'•

                             400 ^amlrUfye 0/Leet,  3§o^on 02202


                                                 January 1*», 1981

U. S.  Environmental Protection Agency
Region  1 - JFK BuiIding
Cambridge Street
Boston, MA 02203

Attention:   Environmental  Information Office

               Subject:  Review  of Draft Environmental Impact Statement
                         concerning Wastewater Collection and Treatment
                         Facilities, Nantucket, Massachusetts

Gentlemen:

     This office has  reviewed the attached  document and it does not  seem
that any of  the proposed facilities, as shown in Fig. R map in Chapter 2,
will effect  the Nantucket State  Forest either directly by land involvement
or indirectly by subsurface" changes in water quality  since there are no
developed facilities within  the  State Forest.  The  same map shows that the
nearest proposed alternate  site  is Site No.  3 which is east of Lovers Lane
and abuts the southeast corner of the State  Forest. .  However, the authors
of this report do  not  recommend  this area as a viable sit:e as indicated in
their  conclusions  on  pages  2-9-   If it turns out that Site No. 3 is  developed
then the facility  should be  screened from view along  Lovers Lane so  that this
approach to  the State  Forest will not have  its visual aesthetics destroyed.

     We appreciate the opportunity to review this proposed project.
                                               Gi
                                               Director of Forests and Parks
GAB:mk
attachment map

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                                                                            B-14
                                Town of Nantucket

                      NANTUCKET MEMORIAL AIRPO

                        Nantucket Island, Massachusetts  0255
Office of Airport Manager

  Phone (617) 228-1255

       January  63  1981
RECEIVED
 REGIONAL
vat,
                                                              REGION I
                                                            OFFICE OF THE
        Div-iNiSTRATHR
        t>— Statement.
Re:  Environmen
     Wastewater Treatment Facilities
     Nantucket County
     Nantucket, Massachusetts
       Mr. William P. Adams,  Jr.
       Regional Administrator
       U. S. Environmental  Protection Agency
       Region  1
       JFK Federal Building
       Boston* Ma. 02203

       Dear Mr. Adams:

       The Nantucket Airport  Commission Dishes to be recorded as opposed
       to the  area shown  on Figure  5  as alternate land disposal site No. 5.

       This site  is in  the  approach to Runway 243 our main instrument
       runway.  The Airport recently  acquired this property as to have
       control of its use.

       A waste water treatment  facility could be detrimental to aviation
       by attracting' wildlife,  seagulls,  migratory birds, etc.  If a
       spray treatment  was  used,  it would form vapor clouds, cutting into
       the visibility of  landing  aircraft.   Lighting of the facility would
       detract from our nighttime landing aids.

       Nantucket  Airport  has  govd approaches to its runways, and we try
       to keep them that  way.   This Airport is vital for its emergency
       use and the economy  of the Island.
       Sincerely ,
       ft
       "/Kenneth W. Holdgate
      /Airport Manager
       KWH:jmn

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                                                                         B-15

                      BOARD  OF SELECTMEN

                     County Commissioners      Board of Health.

                         NANTUCKET, MASSACHUSETTS

                                  617-228-0790        ^^-'

                                   March 20, 1981  ^ 9- 0
Division of Water Pollution Control
110 Tremont Street
Boston, MA  02108
Att: Al Slater                      RE: Selected Plan For Madaket Area

Dear Mr. Slater:

      The Town of Nantucket recognizes that there are waste disposal problems
with respect to a number of on-site septic systems in the Madaket area.  In the
EIS Needs Study three contaminated private  well supplies were identified out of
a sample of approximately 26 homes that were tested.  Additional well contamin-
ation problems may exist for a number of the approximately 250 homes that
were not tested.

      At the present time, the Town does not believe that a public water or
sewer supply system  is justified for the area.  The plan that the Town  wishes
to pursue for Madaket is the development of a non-structural management plan
for the area.  This would entail the identification of local corrective action to
eliminate well contamination conditions and  to correct problems with septic disposal
system problems where they exist.

      To properly evaluate the  cost-effectiveness and long range performance
capability of this plan,compared with the installation of a public water or sewer -
system;  will require  a comprehensive analysis of all individual well/septic
systems in Madaket.  Land use density controls  will also need to be evaluated in
light of the limited local water  supply resource of the area.  The Town would like
to undertake this additional evaluation work  under the Step I Facilities Planning
Program.

      Until a corrective action program is implemented in Madaket, the Town
health officer will continue to monitor the premises where private well supply
problems have been identified and advise occupants on appropriate action to pro-
tect public health.
                                   Sincerely,
                                   Kenneth Holdgate,
                                   Chairman
KH/sdb

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Appendix C
Technical Background -Table 8
Screening of Alternative Filter Bed Sites

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                                          .TABLE "8A7;

                                       NANTUCKET  DEIS
                                 INTERPRETATION OF TABLE 8
 I.   KEY TO NUMERICAL DESIGNATIONS
     A.   Ma^or Environmental Impact Components
         Environmental Effects
         1.  Soil
         2.   Vegetation
         3.   Groundwater
         4.   Air Quality
         5.   Animal and Insect
              Life
         6.   Climate
         7.   Surface Water
         8.   Geologic Formations

         Public Health Effects
         1.   Groundwater
         2.   Insects and.Rodents
         3.   Site Run-off*
         4.   Aerosols and Odors
         5.   Crops/Food Chain
         6.   Noise and Traffic
         7.   Surface Water
Social/Aesthetic Effects
1.  Land Use
2.  Community Growth
3.  Relocation of Residents
4.  Greenbelts/Open Space
5.  Recreational Activities

Economic Effects
1.  Loss of Tax Revenues
2.  Land Devaluation
3.  Energy Commitment
4.  Resource Commitment
5.  Groundwater
6.  Surface Water
7.  Revenues

Legal Effects
1.  Water Rights
2.  Implementation Authority
3.  Existing Regulation and
     Plans
     B.  Environmental Impact Identification Factors

         Environmental Impact Identification Factors indicate an increasing
         degree of adversity with values of from 1 to 3.   Beneficial impacts
         are indicated with a value of 1 and the most adverse impacts are
         indicated with a value of 3.

II.  ANALYSIS OF THE TABLE 8 ENVIRONMENTAL SCREENING

     The overriding factors considered in the analysis were groundwater impact,
     public health effects, land use, and the value of land.  By placing the major
     emphasis on these factors the list of most viable land disposal sites can be
     reduced to three sites; namely, the existing disposal beds sites 2 and 10 and
     site 1 on the west side of Miacomet Pond.  Sites 2 and 10 are the most suitable
     rapid infiltration sites.

     Site 1 is the most promising slow rate irrigation site on the island due mainly
     to its adequate land area, its proximity to the ocean and distance from Nantucket's
     major population center.  Major disadvantages of this site include:  substantial
     land acquisition costs,- a relatively high level of preapplication treatment,
     and expensive storage facilities.

     Based on the results of the screening, the most promising land, treatment site (s)
     for the island of Nantucket are the existing Surfside and Siasconset treatment sites.

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Appendix D
Bibliography

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Appendix E
List of Preparers

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BIBLIOGRAPHY

Commonwealth of Massachusetts, Department of Environmental
Quality Engineering (DEQE).  The State Environmental Code:
Minimum Requirements for the Subsurface Disposal of Sanitary
Sewage - Title 5.  May 20, 1977.

Commonwealth of Massachusetts, Department of Environmental
Quality Engineering (DEQE).  A Guide to the Coastal Wetland
Regulations, MA Wetlands Protection Act (GL 131, s. 40),
100 Cambridge Street, Boston, MA  02202.  December 31, 1978.

Commonwealth of Massachusetts, Department of Environmental
Management.  Planning Office.  Final Water Quality Manage-
ment Program for Nantucket (208).  December 1979.

Environmental Protection Agency.  Region I.  Existing Water
Quality Problems, Nantucket,  MA.  Interim 201/EIS Draft
Report.  Anderson-Nichols, Inc.  August 1979.

Environmental Protection Agency.  Region I.  Current Condi-
tions - Future Sewer Needs, Nantucket, MA.  Interim 201/EIS
Draft Report.  Anderson-Nichols, Inc.  August 1979.

Environmental Protection Agency.  Quality Criteria for Water.
EPA-440/9-76-023.  Undated.  Pages 201-203.

Environmental Protection Agency.  Population Projections and
Future Sewer Service Area Population.   (Draft)Nantucket, MA.
Interim 201/EIS Memorandum.Anderson-Nichols,  Inc.
February 1980.

Environmental Protection Agency.  Region I.  Draft EIS for
Wastewater Collection and Treatment Facilities  in Nantucket,
MA.  Anderson-Nichols, Inc.  November 21, 1980.

Goldberg, Zoino, Dunnicliff & Associates, Inc.   Nantucket
EIS Geohydrologic Report.  Newton Upper Falls,  MA.
May 9, 1980.

Nantucket Conservation Foundation.  Properties  of the
Nantucket Conservation Foundation.  Map.  Harbor Square,
Nantucket, MA.  August 1975.    (updated).

Nantucket Planning and Economic Development Commission (NPEDC)
Basic Data Report.  Broad Street, Nantucket, MA.  1978.
(updated with personal interviews).

Nantucket Planning and Economic Development Commission (NPEDC)
(Draft) Environmental Review;  Alternate Force  Main Routes,
Nantucket, MA. July 24, 1980.

Nantucket, Town and County of.  Official Zoning Map - 1979;
Assessor's Maps, May 9, 1975  (Photogrammetric map - set of
99 sheets).

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Pierce, Anne M.  Phase I Reconnaissance Survey and Study;
Proposed Wastewater Transmission Facilities, Nantucket, MA.
Anderson-Nichols & Co., Inc.  September 12, 1980.

Sheaffer and Roland, Inc.  Performance Assessment of Surfside
and Siasconset Rapid Infiltration Beds — Annex Report A.
December 1979.

Sheaffer and Roland, Inc.   (Final) Wastewater Facilities
Planning Alternatives for Nantucket, MA.  June 1980.

Sheaffer and Roland, Inc.  Item 1 - Cost of Ocean Outfall.
Letter to Bill Richardson, Anderson-Nichols,Inc.
March 3, 1981.

Sheaffer and Roland, Inc.  Cost Comparison of AWT Plant at
Surfside to Achieve Nitrogen Removal with Primary Treatment
and' Subsurface Disposal Requiring 90-Acre Case III Plume
Area.Technical Memorandum.April 1981.

U.S. Department of Agriculture.  Soil Survey of Nantucket
County, Massachusetts.  Soil Conservation Service and
Massachusetts Agricultural Experiment Station.
GPO:1979 0-273-220.  June 1979.

U.S. Department of Housing and Urban Development.  Flood
Hazard Boundary Maps - Sheets 1 through 26.  Federal
Insurance Administration.  September 13, 1974.  Updated
to 12/3/76.

U.S. Department of the Interior.  Water Resources of
Nantucket Island, Massachusetts.  Eugene H. Walker, Geologi-
cal Survey.Open File Report 79-558.

Weston Geophysical Engineers, Inc.  Geophysical Investiga-
tions of Nantucket Island, Massachusetts for the Massachu-
setts Water Resources Commission.Weston, MA.  November 8,  1966

Whitman & Howard, Inc.  Report on Proposed Sewerage System
and Sewage Treatment Facilities, Nantucket, MA.  89 Broad St.,
Boston, Mass.  July 1973.

Whitman & Howard, Inc.  Facilities Plan Environmental Assess-
ment and Cost Effectiveness Analysis for the Report on Pro-
posedTSewerage System, Nantucket, MassachusettsT45 William
Street, Wellesley, Mass.  October 1976.

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LIST OF PREPARERS
U.S. Environmental Protection Agency, Region I

Bob Mendoza, Environmental Impact Office,
             Overall Direction and Review

Chet Janowski, Project Manager, Continuing
               Review and Coordination

Paul Pinault, Construction Grants Review and
              201/EIS Coordination

Steven Koorse, Groundwater Supply Review
U.S. Geologic Survey

Michael Frimpter, Chief Groundwater Division,
                  Groundwater Modeling Review

Eugene Walker, Groundwater Specialist
Nantucket Planning and Economic Development Commission

Bill Klein, NPEDC Director, Continuing Review and
            201/EIS Coordination
Sheaffer and Roland, Inc.

Fred Roland, Facilities Planning and EIS/201
             Coordination
Goldberg-Zoino Associates/ Inc.

John Ayres, Coordination and Review

Mike Powers, Senior Groundwater Hydrologist,
             Groundwater Modeling

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Anderson-Nichols & Co.., Inc.

Burk Ketcham, Director, Planning Division

Bill Richardson, EIS Project Manager, Principal
                 Writer of DEIS/EIS, Overall 201/EIS
                 Coordination and Review

Jim Sempere, Resource Analysis, Public Participation
             and Communications

Ruth Baxter, Graphics, Report Production, Photography

Virginia Pink, Hydrologic Field Sampling and
               Groundwater Analysis

Anne Pierce, Historic and Archaeological Review
             and Coordination

Mark Thompson, Sanitary Engineering Review

Mike Sills, Sanitary Engineering Review

Joe Zeneski, Sanitary Engineering Review

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    ^eosr.,,

                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                           REGION I

                     J.F.KENNEDY FEDERAL BUILDING, BOSTON. MASSACHUSETTS 02203
To:  All Interested Governmental Agencies, Public Groups and Citizens
Pursuant to Section 102 ( 2) (c) of the National Environmental Policy
Act of 1969 (P.L. 91-190), and implementing regulations promulgated
by the Council on Environmental Quality  (CEQ) and EPA, the enclosed
copy of the Final Environmental Impact Statement (EIS) for the proposed
Wastewater Management Program for Nantucket, Massachusetts is provided
for your review and comment.  A period of 30 days following the
notification of availability in the Federal Register will be allowed
for this review, after which a Record of Decision will be issued and
distributed by EPA.

The Final EIS provides a summary of the findings and recommendations
resulting from the EIS process, with the revisions necessitated by
comments received on the Draft EIS.  All comments, and EPA's response
to these comments, are included in the report, as well as a synopsis
of the Public Hearing held on January 8, 1981.

Additional copies of the EIS are available at EPA's Region I office
in Boston or at the Town and County Building in Nantucket, Massachusetts.
Sincerely,
Lester A. Sutton, P.E.
Regional Administrator

Enclosure

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                          FINAL

              ENVIRONMENTAL IMPACT STATEMENT

             WASTEWATER TREATMENT FACILITIES
            NANTUCKET,  NANTUCKET COUNTY,  MASS.

                       August 1981
This FINAL Environmental Impact Statement (FEIS)
presents the recommended treatment and land disposal
alternative for Nantucket Center and Siasconset Village
on Nantucket Island, MA.  The facilities will be
upgraded to provide primary treatment with land
disposal at the existing sand filter beds at Surfside
and Siasconset.  Groundwater affected by the plume from
the filter beds will be designated as non-potable and ,
the area will be controlled by the Town's acquisition
of management zones.  A non-structural, water quality
management program is recommended for Madaket Village
to preclude contamination of the Madaket aquifer.  A
limited sewer rehabilitation program is recommended for
Nantucket Village.

Further information on this FEIS can be provided by:
          Mr. Robert Mendoza
          Environmental Impact Office
          EPA Region I (LEAD AGENCY)
          JFK Federal Building
          Boston, MA  02114	(617) 223-4635

          Technical Consultants:
          Anderson-Nichols & Co., Inc.
          Boston, MA  02114
Approved by:
                                   SEP 21 1981
Lester A. Suttoi
Regional Administrator
EPA Region I
Final Date by which
Comments on this
FINAL EIS may be
received

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EXECUTIVE SUMMARY

o   The Public Hearing for the Nantucket DEIS/201 Facilities
    Plan was held at 7 p.m., January 8, 1981, in the Nantucket
    Town and County Building.  A presentation was made on the
    treatment alternatives and recommended options contained in
    the 201 Plan.  Background was also given on the DEIS sewer
    needs analysis, identification of future sewer service
    areas, impact to groundwater at the filter beds and the
    requirement for an on-going monitoring program at the beds.

o   Comments on the Draft EIS were received from seven federal
    agencies, five state agencies and one local public body.
    The comments were generally favorable and very limited in
    scope.  Many respondents had no comment.  In those
    instances where revision or additions were warranted, they
    have been added to the text of this FEIS (see Chapter 5).
    Comments at the public hearing were similarly limited and
    all were responded to at the hearing.

o   The final recommendations are to upgrade the existing
    wastewater disposal facilities for Nantucket Center and
    Siasconset Village to, provide primary treatment prior to
    land disposal at the existing sand filter beds at Surfside
    and Siasconset.  The area around the filter beds.will be
    acquired by the Town and water supply wells will be
    restricted within that area.  A limited sewer
    rehabilitation program is recommended for Nantucket
    Center.  A long term, non-structural water resource and
    groundwater quality management program is recommended for
    Madaket Village.

o   EPA recommends that new sewer extensions be limited to an
    as-needed basis within the high-density zones which
    immediately abut the existing sewer systems in Nantucket
    Center and Siasconset.  Sewering should be provided over
    the next 20 years, as needed, in the high-density
    commerical corridor running south and east from Nantucket
    Center toward the airport.  The town wellfields are located
    in this area.  They should be protected from potential
    groundwater contamination which could result from
    high-density development.

o   The 1976 Facilities Plan had recommended the sewering of
    Madaket and the construction of a secondary wastewater
    treatment plant.  Similar recommendations were made for the
    outlying villages of Quidnet and Wauwinet.   EPA found no
    need to sewer either Quidnet or Wauwinet.  In Madaket,
    water quality tests show no pattern of general
    contamination.   Four wells in Madaket with high nitrates
    were found to be widely scattered,  the lots of varying
    sizes, the septic systems of varying ages and the wells at
    different depths.   Although the nitrates have a limited
                               11

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        3.3.2  Siasconset Recommended Actions               38
               3.3..2.1   Water Quality                      38
                           thru
               3.3.2.19  CZM Consistency                    42

        3.3.3  Madaket Recommended Actions                  42
               3.3.3.1.Water Quality42
                           thru
               3.3.3.19  CZM Consistency                    45

O  CHAPTER 4  MITIGATION MEASURES                           46

   4.1  WATER QUALITY                                       4 6
   4.2  COASTAL FLOOD HAZARDS                               46
   4.3  WILDLIFE/ENDANGERED SPECIES                         47
   4.4  WETLANDS                                            47
   4.5  AIR POLLUTION/ODORS                                 47
   4.6  PUBLIC HEALTH                                       47
   4.7  SOIL FILTRATION                                     48
   4.8  NOISE                                               48
   4.9  LAND USE/INDUCED GROWTH                             48
   4.10 RECREATIONAL USE                                    48
   4.11 TRAFFIC                                             48
   4.12 BUSINESS       '                                     48
   4.13 COSTS                                               49
   4.14 ENERGY                                              49
   4.15 ARCHAEOLOGICAL/HISTORIC                             49
   4.16 MINERAL RESOURCES                                   50
   4.17 SIGNIFICANT AGRICULTURAL LAND                       50
   4.18 WILD AND SCENIC RIVERS                              50
   4.19 CZM CONSISTENCY                                     50

O  CHAPTER 5  COMMENTS AND RESPONSES

   5.1  INTRODUCTION                                        51
   5.2  RESPONSE TO COMMENTS ON DRAFT EIS                   51
        5.2.1  Nantucket Center Comments                    51
        5.2.2  Siasconset Area Comments                     53
        5.2.3  Madaket Area Comments                        53
        5.2.4  Comments on Alternative Actions              54
        5.2.5  Comments on Treatment Levels                 55
        5.2.6  Buffer Zone Comment                          57
        5.2.7  Environmental Impacts Comments               57
        5.2.8  Mitigation Measures59
        5.2.9  Costs                                        59

O  APPENDICES

   APPENDIX A - SYNOPSIS OF PUBLIC HEARING
   APPENDIX B - AGENCY COMMENTS
   APPENDIX C - TECHNICAL BACKGROUND - TABLE 8
                SCREENING OF ALTERNATE FILTER BED SITES
   APPENDIX D - BIBLIOGRAPHY
   APPENDIX E - LIST OF PREPARERS
                              V

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o  LIST OF FIGURES                                 follows page

   FIGURE A - Nantucket Sewer System -
              Existing and Future Service Areas          7

   FIGURE B - Siasconset Sewer System -
              Existing and Future Service Areas          8

   FIGURE C - Nantucket Center Sewer Rehabilitation      8

   FIGURE D - Surfside Treatment Facility               17

   FIGURE E - Siasconset Treatment Facility             19
o  LIST OF TABLES
                                                       Page
   TABLE 1 - Summary of Recommended Actions -
             Capital Costs                              24

   TABLE 2 - Environmental Impact Profile -
             Nantucket Center Alternatives              28

   TABLE 3 - Environmental Impact Profile -
             Siasconset Alternatives                    29

   TABLE 4 - Environmental Impact Profile -
             Madaket Alternatives                       30
                             VI

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effect on public health/ measures are readily available to
counter these effects.;  The EPA, therefore, finds no
justification for sewering Madaket.

In addition to the sewering and wastewater treatment
issues, an overriding problem with sewage overflows into
Nantucket Harbor was addressed.  Because of the immediate
nature of the overflow problems, the associated engineering
solutions were "segmented" from the main body of the EIS
and their review was "fast-tracked" by state and federal
agencies.  Following an intense review of impacts, a final
plan was approved to eliminate the overflows.  This
consisted of constructing a new force main plus the
relining of the existing main and improvements to the pump
station.  Grants have already been awarded for the design
and construction of the new force main, as well as
improvements to the pump station.  Total costs for the
force main project will be $3,415,900.

Costs of the recommended actions in this FEIS are projected
at $7,000,000 (force main not included).  Costs per user
will be approximately $50 to $55 per year per residential
unit.

Impacts of the recommended actions on local resources are
generally insignificant and do not conflict with local
conditions or bylaws.  The most important long-term effect
will be a positive one:   the recommendations sustain local
growth and land use policies,  which are aimed at
concentrating future development within the downtown area
and along a corridor leading toward the airport.
Groundwater impacts at the existing land disposal sites
will not change significantly, although the area affected
by the future plume will be somewhat larger.

The most significant mitigation measure is the requirement
for a management zone around the filter beds.  This zone
will preclude the installation of wells within the area
contaminated by the wastewater plume.  Other mitigation
measures include construction during the off-season to
minimize disruption to the Island's tourist-based economy
and a water quality monitoring program in Madaket.   An
archaeological field survey is required during construction
of the force main to help locate and identify potential
artifacts.

No special permits will be necessary to construct the
recommended projects.  No federal or State permits are
required.  A local wetlands permit and hearing may be
required for certain elements of the sewer rehabilitation
project which are within 100 feet of a wetland area.
                           111

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TABLE OF CONTENTS

   Cover Sheet                                              i
   Executive Summary                                        ii
   Table of Contents                                        iv

O  CHAPTER 1  PURPOSE AND NEED

   1.1  INTRODUCTION                                        1
        1.1.1  Project History                              1
        1.1.2  Force Main Problem                           2
   1.2  NEEDS ANALYSIS                                      4
        1.2.1  Sewer Needs                                  4
               1.2.1.1  Groundwater Testing                 4
               1.2.1.2  Future Development and Sewer Needs  6
               1.2.1.3  Sewer Rehabilitation                8
        1.2.2  Sewage Treatment Needs                       9
        1.2.3  Disinfection12
        1.2.4  Buffer Zone                                 15

O  CHAPTER 2  RECOMMENDED ACTIONS

   2.1  NANTUCKET CENTER WASTEWATER FACILITIES             17
   2.2  SIASCONSET WASTEWATER FACILITIES                   19
   2.3  MADAKET AREA RECOMMENDATIONS                       21
   2.4  COSTS OF RECOMMENDED ACTIONS                       23

o  CHAPTER 3  ENVIRONMENTAL CONSEQUENCES

   3.1  INTRODUCTION - ENVIRONMENTAL SCREENING              25
   3.2  IMPACT EVALUATION PROCESS                          27
   3.3  ENVIRONMENTAL IMPACT EVALUATION                    32
        3.3.1  Nantucket Center Recommended Actions        3 2
               3.3.1.1   Water Quality                     32
               3.3.1.2   Coastal Flood Hazard              33
               3.3.1.3   Wildlife/Endangered Species       33
               3.3.1.4   Wetlands                          34
               3.3.1.5   Air Pollution/Odors               34
               3.3.1.6   Public Health                     34
               3.3.1.7   Soil Filtration                   35
               3.3.1.8   Noise                             35
               3.3.1.9   Land Use/Induced Growth •          35
               3.3.1.10  Recreational Use                  35
               3.3.1.11  Traffic                           36
               3.3.1.12  Business                          36
               3.3.1.13  Costs                             36
               3.3.1.14  Energy                            37
               3.3.1.15  Archaeological/Historic           37
               3.3.1.16  Mineral Resources                 37
               3.3.1.17  Significant Agricultural Land     37
               3.3.1.18  Wild and Scenic Rivers            37
               3.3.1.19  CZM Consistency                   37
                              iv

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Chapter 1
Purpose & Need

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CHAPTER  1 PURPOSE AND NEED

1.1  INTRODUCTION

     The Draft Environmental Impact Statement for Wastewater
     Collection and Treatment Facilities in Nantucket,
     Massachusetts, was published by EPA on November 21, 1980.
     The Draft EIS was prepared as part of a "piggy-back" EIS
     process  in conjunction with Nantucket's Supplemental 201
     Facilities Plan.  The Town's Final "Wastewater Facilities
     Planning Alternatives" report had been published on June
     20, 1980, by Sheaffer and Roland, Inc.

     The Draft EIS reported on the need for new sewers on
     Nantucket.  It also identified the groundwater impacts,
     evaluated the level of treatment for the sewage and '
     reviewed the general impact of the wastewater facilities
     upon the Island.  The 201 Facilities Plan investigated
     various  treatment options for the Nantucket and Siasconset
     sewer system, as well as alternatives for the Madaket
     Village area.

  1.1.1  Project History

         A 1973 sewerage facilities plan was prepared for
         Nantucket by Whitman and Howard, Inc.(l)  This was
         updated with revisions and an Environmental Assessment
         in 1976(2).  The report recommended sewering nearly
         two-thirds of the Island and building four secondary
         sewage treatment plants at a (1976) cost of over $24
         million.

         There was significant local controversy over the
         project.  Townspeople objected to the costs and the
         large area proposed to be sewered.   The Town
         subsequently decided to explore other treatment
         alternatives which would be less costly.

         In August, 1978, Nantucket retained Sheaffer and
         Roland, Inc. to prepare a "supplemental" 201
         Facilities Plan.  The supplemental plan explored
         various low-cost, low-technology sewage treatment
         alternatives.
v-HReport on Proposed Sewerage System and Sewage Treatment
FaciTTties, Nantucket, MA;  Whitman & Howard,  Inc., July 1973.

(2) Facilities Plan, Environmental Assessment and Cost
EffecTive Analysis for the Report on Proposed Sewerage System,
Nantucket, MA; Whitman & Howard, October 1976.

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         EPA's Region I Office indicated that it would assist
         the Town of Nantucket by preparing a "Problems and
         Needs" survey as part of a "piggy-back" EIS.  This
         "needs" survey was performed in conjunction with the
         supplemental 201 Facilities Plan and indicated how
         much of the Island actually needed to be sewered.

         The need for sewers was established by field testing
         the quality of water in the areas proposed for
         sewering in the original Facilities Plan.  Poor water
         quality would indicate a potential need for sewers.

         EPA conducted water quality tests during the spring
         and summer of 1979.  The previous summer, water
         quality tests had been done by the state as input to
         their overall "208" water quality management plan for
         the Island(3).  The combined results of all this
         testing gave a solid basis for the supplemental
         Facilities Plan, which was completed in June of 1980.

  1.1.2  Force Main Problem

         Very quickly after the new Facilities Plan was
         submitted, the critical problems with the force main
         in Nantucket Center were acknowledged and acted upon.
         During heavy rainstorms, the pipes would be surcharged
         with rainwater and the resulting flows would exceed
         the capacity of the pumps and the force mains in
         Nantucket Center.  Sewage would back up in the pump
         station and have to be vented off through an overflow
         pipe to the harbor.  There, the raw sewage caused
         closure of beaches and shellfish beds.  This
         threatened the Island's tourism and shellfish
         industries, both of which are mainstays of Nantucket's
         seasonal economy.

         Both the state and EPA required that Nantucket
         eliminate this overflow from the pump station.  The
         Town had been issued an NPDES discharge permit with a
         schedule to clean up the problem. ,The permit expired
         in 1977.

         Immediate action was needed.   Emergency action to
         upgrade the pumps and patch the leaks had been
         approved by EPA and the state early in the project.
         This alleviated the overflows that were experienced
         during heavy summer rainstorms.
(•3)Final Water Quality Management Program for Nantucket,
Massachusetts Department of Environmental Management,  Planning
Office, December 1979.

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         But sewage overflows also occur when there are breaks
         in the force main.
                                             *

         The aging force main has had problems  with sewage
         leaking from joints and undermining the brittle cast
         iron pipe, causing it to sag and snap.  This has
         occurred as often as five times in one year.  Every
         time the force main breaks, the pump station has to be
         shut down and the overflow pipe opened to the harbor.
         The overflow stays open during the 12  to 24 hours it
         takes to fix the break in the main.

         It was quickly decided to expedite the force main
         element of the new Facilities Plan.  Shortly after the
         supplemental 201 Plan was submitted, EPA and the state
         "segmented" the force main from the overall EIS
         process and reviewed it on an accelerated schedule.

         The Nantucket Planning Commission prepared an
         "Environmental Review (of the) Alternate Force Main
         Routes"(4)  during late July of 1980.  It was
         recommended that a new force main be built along a
         route which avoided the heart of the downtown area.
         The existing main was to be slip-lined as a backup to
         the new force main.

         An archaeological-historical review of the force main
         routes was prepared by the EPA's contractor for the
         EIS, Anderson-Nichols.  The archaeological review was
         entitled "Phase 1 Reconnaissance Survey and Study:
         Proposed Wastewater Transmission Facilities,
         Nantucket,  MA"(5).  This report was prepared in close
         collaboration with the Nantucket Historical
         Association, the Peter Foulger Museum  and the
         Massachusetts Historical Commission.

         A Phase II  archaeological survey will  be required
         prior to the actual construction of the force main on
         certain sensitive portions of the route.  These
         include the area along Cato Land and adjacent to the
         high school (See page 24, Appendix B,  Nantucket DEIS).
l^MDraft)Environmental Review:  Alternate Force Main Routes,
Nantucket, MA; Nantucket Planning and Economic Development
Commission, July 24, 1980.

(5)phase I Reconnaissance Survey and Study;   Proposed
Wastewater Transmission Facilities, Nantucket, MA
Anne M. Pierce, Anderson-Nichols & Co.,  Inc.  September 12, 1980

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         The EPA and State  have  approved  the Town's force main
         project for a  combined  Step  2 and 3 design and
         construction grant of $3,415,900.

         The completion of  the new  force  main and relining the
         old main will  eliminate the  problems which caused
         overflows of sewage into the harbor.  This will
         alleviate the  most critical  wastewater-related problem
         facing the Town.
L.2   NEEDS ANALYSIS

  1.2.1   Sewer Needs
         The Draft EIS analyzed the need for new sewers on
         Nantucket Island.  This analysis had to be done in
         response to  the public controversy over the 1976 sewer
         plan, which  recommended sewers for 2/3 of the Island.

         The first step was a review of groundwater conditions
         and the second was a review of development trends.
         The groundwater conditions established the degree of
         contamination attributable to wastewater disposal
         practices.   Development trends indicated the
         likelihood of future, high-density growth which could
         lead to groundwater contamination.

         The state's  earlier 208 program had found that surface
         water quality conditions were generally good.   Two
         problem areas, however, were recommended for
         clean-up.  One was to make the boat pump-out system at
         the marina fully operational.  The second was to
         control leachates from the landfill in order to
         protect water quality in Long Pond.

             1.2.1.1  Groundwater Testing

             Groundwater conditions were established through a
             water quality testing program.  This groundwater
             testing program built upon the results of the
             state's 208 program,  which had found that
             groundwater and surface water conditions  were
             generally good (see DEIS pg.  1-10).

             To verify these results, the EIS retested
             groundwater conditions at the same sites  surveyed
             by the 208 study.   Additional areas were  added to
             the sampling program to check on conditions
             across the Island.  A total of forty-eight
             sampling points were tested by the EIS effort.

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              The tests were run in May and July of 1979.   The
              May samples were taken preceding the influx of
              summer tourists and the July samples were taken
              just after the peak summer season (July 4)
              holiday weekend.  This was done to determine the
              effect of summer population on groundwater
              quality.

              The results showed that overall groundwater
              conditions are good.  There was little overall
              change between the two sets of samples.  No
              general increase in contamination was detected
              during the summer season tests.

              Four of twenty-seven wells (14;8%) sampled  in the
              Madaket area, however, showed increased levels of
              nitrate in the groundwater.

              Decreases in nitrate levels also occuring in
              eight Madaket wells (29.6%) during the same
              May-July period.  This decrease in nitrates  is
              important since it illustrates the variability of
              groundwater conditions at Madaket.

              No single pattern could be identified among  the
              few, random occurrences of high nitrate levels at
              Madaket.  The nitrate problem was found on  small
              lots with older septic systems as well as on
              large lots with newer systems.  In a cluster of
              small, year-round houses, one well tested as
              safe, whereas the adjoining well was above  the
              safe nitrate limit.

              Elevated levels of nitrate/nitrites pose a
              potential risk only to very young infants (under
              three months of age) who are bottle-fed and  whose
              formula might be prepared using tapwater from
              contaminated wells(6).  Nitrates can cause  a
              "blue baby" condition to develop.  Older children
              and adults are not affected.

              The four families whose wells were found to  have
              the higher nitrate levels were notified by  the
              Nantucket Board of Health.  It was suggested that
              they ought to temporarily get water from a
              different water supply source, if they had
              bottle-fed infants younger than three months old.
v°fQuality Criteria for; Water, U.S.  Environmental Protection
Agency EPA-440/9-76-023, Pages 201-203.

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 Although nitrates  have been  identified as a
 limited problem in Madaket,  the Town has
 alternative,  non-structural  management options
 which it promptly  exercises.  The Board of Health
 helps to make arrangements for temporary
 alternate water supplies when needed.

 The availability of these alternate measures,
 coupled with  the low frequency of occurrence, low
 housing density of the village and seasonal use
 of  the area,  do not justify  the construction of a
 complete sewage system and treatment facility.
 This Final EI§ f;inds  no need to sewer Madaket
 Village.

 Groundwater tests  were also conducted in the
 villages of Quidnet,  Wauwinet and Surfside.
 Sample? were  also  taken along Hummock Pond Road
 and Hooper Farm Road.  No evidence of
 contamination was  found in any of the wells
 sampled.

 The lack of contamination, however, does not
 indicate that the  potential for groundwater
 pollution does not exist.  Contamination could
 still  result  from  over-fertilization of gardens
 or  lawns and  from  the improper placement of
 septic leaching  fields relative tp well screens.

 The overall results of the Nantucket groundwater
 testing  program did not reveal any conditions
 severe  enough  to warrant consideration of sewers
 as  a corrective measure.
                 \
 The sewering of Madaket and construction of a
 secondary wastewater treatment plant had been
 recommended in Nantucket's 1976 Facilities Plan.
 That plan  had made  similar recommendations for
 the outlying villages of Quidnet and Wauwinet.

 This EIS  finds no need to sewer Madaket,  Quidnet
 or  Wauwinet.

 1.2.1.2  Future Development and Sewer Needs

 As  noted above, the groundwater tests of  current
 conditions revealed no need to sewer the  outlying
 villages of the Island.   Conditions which might,
 however, create a need for sewers  at some future
 date also need to be analyzed.

Wastewater problems are generally  created by land
 use activities which dispose  too much on-site
 sewage in too little an area.  Basic determinants

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of the need for future sewers, therefore, are
growth rates and land use density.

Where will future development be located?  How
many people will live there?  What present trends
serve to indicate the location and densities of
that future growth?  Building permit trends, real
estate market demands, zoning bylaws and
subdivision plans offer the best clues.

The DEIS reviewed the growth trends on the Island
and determined that roughly 25 percent of all new
construction is tying into the two existing sewer
systems.  Based upon present zoning densities and
real estate market trends, there is a need to
plan for the extension of sewers into the
adjoining high-density use zones which surround
the downtown sewer system (see Figure A).

This extension of the sewer service area will
occur gradually and in response to pressures for
service generated by new high-density
development.  This development will follow
existing zoning.

Fanning south from downtown to the west toward
Cisco, between Somerset Road and Miacomet Avenue,
as well as to the east along Old South Road
beyond Nobadeer Road, are very high density 5,000
square foot Residential-Commercial zones.  These
areas of high density residential and commercial
zoning serve to direct growth southeast from
downtown along Old South Road toward the airport.

This is of concern to water resource planning
since the primary well field of the Wannacomet
Water Company, which supplies Nantucket Center,
is located right in the middle of this growth
corridor.  Already proposed for Old South Road
are several motel complexes and automobile
dealerships.  The Nantucket Planning Commission
projects that additional motel-hotel complexes
could easily bring the total to 8 to 12 new
facilities by the year 2000.

The extension of sewers into this area southeast
of Nantucket Center was reflected in the 201
Plan.  This is intended to help protect the
existing Wannacomet well field from potential
contamination which could result from these
high-density uses.

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 A  long-range planning policy of the Nantucket
 Planning  and Economic Development Commission
 (NPEDC) is  to cluster future growth in and around
 the  downtown area.  Given that policy, it is
 anticipated that most of the open parcels within
 or adjacent to the present downtown sewer system
 would be  serviced as they develop.  The same
 infill of open parcels was anticipated for the
 Siasconset  Village.

 Siasconset  Village is zoned Residential-Old
 Historic  (5000 square foot lots) and Residential
 1  (5000 square foot lots).  Southwest of Morey
 Lane and  at the town well field off of Milestone
 Road, the zone is R-2 (20,000 square foot lots).
 Real estate trends, however, show that the market
 is demanding half-acre lots, even in the
 one-eighth  acre zone.  People buying lots in
 Nantucket prefer the 20,000 sq. ft. parcels, even
 though they can build on 5000 sq. ft.

 Building permit records indicate that only 5 or 6
 new houses  are put up each year in Siasconset,
 far less a  building rate than at Nantucket
 Center.  The 201 Plan recommends that the
 existing sewer system be extended as necessary to
 service this construction within the one-eighth
 acre zone (see Figure B).

 1.2.1.3  Sewer Rehabilitation

 The 201 Facilities Plan made a series of
 recommendations regarding rehabilitation of the
 existing sewer system in Nantucket Center.  This
 Final EIS concurs with those recommendations.

 The North Beach Street sewer line should be
 replaced from Jetties Beach Road to Easton
 Street.  Internal inspection of this pipe
 revealed a  large number of dips and a few broken
 or cracked pipes.  The sewer also has an
 inadequate slope to maintain self cleaning
 velocities and is subject to considerable amounts
 of infiltration.   Approximately 2,400 feet of
 sewer will be replaced (see Figure C).

The South Beach Street sewer from Easton Street
 to Broad Street (800 feet)  has been recommended
 for rehabilitation.   This line is subject to
 excessive groundwater infiltration.  Relining of
 this sewer has been determined the most
cost-effective means of rehabilitation.

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* Whale Rock
                       Fig. A.  Existing & Future Nantucket Sewer Service Area

                                        Final EIS Report — Nantucket Wastewater Treatment Facilities
                             Steamboat
                             ^Wharf

                             >^y NANTUCKET

                             *r~^ *^ \

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                                                    "SankatyHead  *

                                                    *.  Golf Club. ,;
                                                     II    /Of  vr
                                                                        Filter Beds
   .kf •*•       N\  r\auiu i


Fig.  B. Existing & Future

Siasconset Sewc
                                                     Sewer Service Area
;ARY
                                                                      Existing

                                                                      Future
Final EIS Report — Nantucket Wastewater Treatment Facilities

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   mta^ SEWER GROUTED 1980




   Illllllll SEWER TO BE REPLACED
       Fig.  C.  Nantucket Center Sewer Rehabilitation
Final EIS Report — Nantucket Wastewater Treatment Facilities

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               Approximately  600  feet of sewer in Washington
               Street,  between Coffin Street and Main Street is
               recommended  to be  replaced.  This existing line
               has  inadequate capacity for existing peak flows
               and  is subject to  large amounts of infiltration.

               Approximately  750  feet of sewer in South Water
               Street,  between Main Street and Broad Street will
               be replaced.   The  existing sewer is inadequate to
               convey existing flows and has some minor
               structural defects.

   1.2.2   Sewage Treatment Needs

          In  addition to the  need for new sewers, a second issue
          which the DEIS reported on was the level of treatment
          for  the sewage.  Section 2.7 of. the DEIS presents an
          evaluation of primary treatment vs. secondary
          treatment.  The final recommendation is for primary
          treatment, followed by disposal on the existing filter
          beds  (pg. 2-25, Section 2.7.3,  DEIS).  The 201
          Facilities Plan also recommends primary treatment.

          In the evaluation of primary vs. secondary treatment,
          the basic comparison was between the increased costs
          of land (with primary treatment and land disposal)  vs.
          the higher costs of advanced treatment processes (with
          secondary facilities) .

          The DEIS reported on a method for calculating the
          breakeven point between various wastewater treatment
          levels (Section 2.7.3  and Appendix A, DEIS).   Using
          assumptions on land costs, infiltration rates at the
          filter beds, and pollutant levels, a series of present
          worth cost-curves were plotted  for various wastewater
          flows (Fig. 5, DEIS).   Using this approach, it was
          found that land costs  would have to be more than
          $100,000 per acre (present worth)  before secondary
          treatment became more  cost-effective than primary.

          The 201 Plan issued a  memorandum report on a
          cost-comparison of advanced (secondary)  vs. primary
          treatment (7).  This included an update on land costs
          and 0 & M costs for an advanced facility on 40 acres
          at Surfside designed to achieve nitrogen removal and
          disinfection.   Total present worth cost of the
(7)Cost Comparison of AWT Plant at Surfside to Achieve
Nitrogen Removal with Primary Treatment and Subsurface Disposal
Requiring 90 Acre Case 3 Plume Area Sheaffer and Roland,  Inc.,
April 1981

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         advanced treatment plant was estimated at $9.665
         million.  Present worth cost for primary treatment (on
         90 acres) was $4.584 million.  The $5 million dollar
         differential would mean that land costs (for the 50
         acres saved by going AWT) would have to be more than
         $100,000 per acre.

         In determining the final level of treatment, a series
         of evaluations were made.  These included a
         performance review of the existing filter beds and an
         evaluation of primary treatment vs. continued raw
         wastewater dis;posal.  This latter option represented
         the "no action" alternative of continuing present
         practice of no treatment, at all, prior to disposal.

         The effect of the filter beds on groundwater was
         tested during the EIS/201 groundwater sampling
         program.  These tests were run in conjunction with
         Sheaffer and Roland, the Town's 201 engineering
         consultant.

         The groundwater quality test data obtained for the
         Surfside and Siasconset filter beds reveal that the
         beds have provided a high level of BOD and solids
         removal.  However, due to the high loading rates, the
         beds operate at their limit as anaerobic treatment
         units.  This results in high ammonia and very low
         dissolved oxygen (D.O.)  levels in the underlying
         groundwater plume.  As a result, Sheaffer and Roland
         propose to eliminate the anaerobic conditions by
         raising the beds to maintain an elevation of 4 ft.
         above the groundwater level.

         The effluent plume that reaches the ocean through the
         groundwater is much higher in overall quality than
         that provided by a conventional secondary treatment
         facilitiy with respect to removal of biodegradable
         organics and bacteriologic organisms.  The effluent
         plume is comparable to that provided by a secondary
         treatment plant in terms of dissolved nutrients and
         other inorganic substances(8).

         Although the existing system provides adequate
         pollutant removal from an environmental impact
         viewpoint, other impacts must be considered.  These
         include:  wastewater contaminants which affect the
         operation of the beds;  potential public health
         problems; aesthetic problems such as odor and visual
         impacts; potential vector problems associated with
(^Performance Assessment of Surfside and Siasconset Rapid
Infiltration Beds (Annex Report A)  Sheaffer and Roland7 Inc.,
December 1979.
                               10

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 disease-carrying  insects or rodents; and operation and
 maintenance considerations.

 Grease  is  a contaminant contained in all wastewater.
 Nantucket, with its heavy tourism and hotel-restaurant
 activity,  has higher levels of grease in its
 wastewater than does the average, residential
 community.  Grease can cause serious problems by
 clogging the filter' beds.

 Full primary treatment will reduce the amount of
 grease  in  wastewater to acceptable limits prior to
 disposal.  This will minimize clogging of the filter
 beds and allow full rapid infiltration of wastewater
 into the soil.

 The necessity of  removing grease from the wastewater
 will increase as  the 201 Plan's recommended
 infiltration/inflow reduction measures are
 implemented.  The I/I reduction measures will reduce
 flows and  increase relative grease concentrations in
 the wastewater.  Unless primary treatment is used to
 remove  the grease, the clogging problem will rapidly
 worsen.

 A second problem with raw wastewater disposal is
 caused when the surface of the filter bed is rapidly
 sealed by unfiltered solids.  The wastewater backs up
 and is precluded from rapidly infiltrating into the
 soils.  This creates the potential for odor-producing
 anaerobic conditions to develop.  Occasional problems
 with odors have been'noticed at Surfside during summer
 peak-use periods.   Odor problems would be most
 noticeable during periods of high humidity when fog or
 mist is present.

 Because of the relative isolation of the Surfside and
 Siasconset filter  beds, localized odor problems have
 generally not led to public complaints.  However, as
 the land around both sites continues to develop, the
 likelihood of public objections will increase,
 especially if disposal of raw wastewater continues.
 The primary treatment facility proposed by the 201
 Facilities Plan will have a significant effect on the
 reduction of pathogenic microorganisms, aerosols and
 associated odors,  thereby reducing the potential of
 public health/nuisance problems.

An additional problem of applying raw effluent is the
 removal and disposal of the organic  mat that develops
after each loading cycle.   Presently, after a bed has
been used and has  dried,  the surface is scraped with a
tractor towing  a chain rake.  The accumulated solids
are broken up and  piled on  the embankment areas around
the beds.
                      11

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       This accumulated material can be the source of odor
       problems.  It also creates a potential public health
       problem.  It attracts flies, insects, birds and some
       mammals which feed on it or use it as a breeding
       habitat.  Drying of the organic mat on the filter
       beds, which is necessary before it can be scraped,
       also creates a potential odor and vector problem.
       Once completely dried,  the particles can be
       transported by the wind and become an airborne
       contaminant problem.

       Based on the problems discussed above, the DEIS found
       that continued disposal of raw sewage on the filter
       beds is not acceptable for meeting future treatment
       requirements on Nantucket.  The final recommendation,
       therefore, continues  to be that primary treatment be
       provided prior to disposal on the filter beds.
1.2.3  Disinfection
       Disinfection is the only treatment process
       specifically designed to remove pathogens from
       wastewater.   This is intended to eliminate  potential
       threats to public health.   It should be pointed out,
       however, that raw sewage has been applied to the
       filter beds at Surfside since 1929 with no
       disinfection.  Since that time, there have  been no
       reported problems of disease or contamination in the
       adjacent area.

       Historically, regulatory authorities have required
       that disinfection facilities be provided regardless of
       the receiving water (ground or surface water).  This
       practice, however, has come under increased scrutiny
       over recent years.

       Particular attention has been focused on the
       requirement for disinfectionvprior to land  disposal.
       This is due to:  (1)  the pathogen removal capacity  of
       soil;  and (2) the potential for certain disinfectants
       to form compounds which may be carcinogenic.

       There is a distinct lack of information available on
       disease caused by, or related to, wastewater treatment
       processes.  This may reflect either the absence of  a
       problem, lack of intensive surveillance, or the
       inadequacy of existing "tools" for detecting incidents
       of disease.   It should be  emphasized, however, that no
       incidents of disease have  been documented from a
       properly planned and properly operated land treatment
       system.

       If it can be shown beyond  a reasonable doubt that the
       soil matrix  within a wastewater management  area will
                             12

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         adequately remove pathogens from the wastewater
         effluent, then there is no need to provide
         disinfection as part of the above-ground treatment
         facilities.

         A large number of disease-causing microorganisms and
         parasites are present in domestic wastewater.   These
         include pathogenic bacteria, viruses, protozoa and
         parasitic worms.  Their concentrations in primary
         effluent range from 1 to 20,000 organisms per  gallon.

         Pathogens suryive fairly well in soil for periods of a
         few hours to as long as 5 years.  Their survival is
         highly dependent upon the following factors:  type of
         organism; type of soil; moisture and organic content
         of the soil;  pH; temperature; sunlight and rain; and
         the pollutant content of the wastewater.

         Subsurface pathogen removal is a function of the
         characteristics of the soil, such as particle  size,
         shape and surface properties.  Most pathogens  are
         removed after a brief passage through clay soils' and
         consolidated  sands by filtration and adsorption.
         Wastewater pathogens are effectively removed by
         percolation through a few feet of fine soil.  The
         organic mat that develops in the top 0.2 inches of
         soil has been observed to provide the greatest removal
         of pathogens, followed by a subsequent buildup at
         lower levels  to a depth of 7 to 10 feet.

         With regard to horizontal transport, it should be
         noted that pathogens do not travel significant
         distances in  all directions from a concentrated
         source, but are carried with and in the direction of
         groundwater flow.   Several studies have shown  that the
         great majority of  pathogens which remain after passing
         vertically into the groundwater are reduced to
         negligible levels  after appproximately 200  feet of
         horizontal groundwater  transport.

         In the case of Nantucket,  the disinfection
         capabilities  of the soil were confirmed by  analyzing
         samples drawn from test wells.   These wells are
         located inland of  the beds as well as between  the
         filter beds and the ocean, which is down gradient from
         the  beds.   Little  or no coliform bacteria were
         detected in any of the  well samples taken 135  feet
         down gradient from filter  beds(9).
l*)Ibid.Pages  12-15
                               13

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Based on the above discussion, and the following
considerations that were presented in the Facilities
Plan, it is recommended that disinfection facilities
not be provided as part of the preapplication
treatment train.

1.   Monitoring data for the down gradient wells show
     that the sand filter beds are achieving
     disinfection standards within the boundary of the
     managed groundwater area.

2.   Disinfection prior to filter bed application will
     have a detrimental impact on the biological
     treatment performance of the filter beds.

3.   Disinfection of primary effluent will require
     large doses of chlorine which increases the
     potential for creating chlorinated organic
     compounds which may be carcinogenic.

It should be emphasized that as long as wastewater is
applied to the rapid infiltration basins, pathogens
will be present in some degree in the wastewater plume
in the immediate vicinity of the filter beds.  The
concentration at any one point will be dependent
mainly on the initial concentration and distance from
the application point, and to a lesser degeee on the
conditions that exist in the soil matrix.

With the recommended "Case 3" management of
groundwater at the site, disinfection would not be
necessary to comply with the regulations that are part
of that designation.  Since there is no possibility
that the groundwater will be used for drinking  water,
the more strict disinfection requirements of Case 1 or
2 designation are not necessary.  Case 3 designation
will require that groundwater use within the extent of
the plume be strictly regulated due to the presence of
pathogens and other pollutants in the wastewater (see
Section 1.2.4, below).

Disinfection facilities (chlorination) were included
in the Facilities Plan's cost-effective analysis of
the treatment alternatives.  The elimination of
disinfection will not affect the outcome of that
analysis since the facilities were common to all
structural alternatives.

In terms of costs to the user, the elimination  of
disinfection will have little effect on the costs
presented.   Capital costs will be reduced by about 3%
and operation and maintenance costs will be reduced
minimally,  mainly by cost of chlorine.  The major
advantage in terms of operation and maintenance will
                      14

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          be the  elimination  of potential environmental problems
          associated  with  transportation and handling of
          chlorine.

          It is recommended,  however, that the treatment
          facilities  be designed so that chlorination facilities
          could be added at some future date, if and when
          needed.  This would necessitate a plant layout which
          does  not foreclose  the option of adding chlorination
          equipment in the event that future groundwater
          monitoring  indicates a need for them.
   1.2.4   Buffer  Zone
         The  effect of the wastewater plumes on local
         groundwater was analyzed in the DEIS geohydrologic
         report(lO).  Goldberg-Zoino performed loading tests at
         the  Surfside sewer beds and estimated the lateral
         extent of leachate plumes at both Surfside and
         Siasconset.

         The  results show that the expanded Surfside filter
         beds would create a leachate plume that, at its
         maximum lateral extent, would affect a 90 acre area
         450  feet inland and 700 feet to each side of the beds
         (Fig. 8 in Goldberg-Zoino report).  The Siasconset
         beds would affect a 20 acre area 250 feet inland and
         200  feet to each side (Fig. 9 in the Goldberg-Zoino
         report).

         In accordance with the Code of Federal Regulations
         dated February 11, 1976, the groundwater resulting
         from the land application of wastewater must be
         classified into one of the following:

              Case I:  The groundwater can potentially be used
         for  drinking water supply.

              Case II:  The groundwater is used for drinking
         water supply.

              Case III:  uses other than drinking water.

         The  Regional Administrator of EPA, in conjunction with
         state and local officials shall determine, on a
         site-by-site basis,  the areas in the vicinity of a
         land application site where the above criteria apply.

         In the case of the Surfside and Siasconset filter bed
         sites, the expected area of contamination, as shown on
TIP") Nan tucket BIS Goldberg- Ziono-Dunniclif f & Associates,  Inc
Newton Upper Falls, MA.  May 9, 1980
                               15

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Figures 8 and 10 pf the Goldberg, Zoino Report, could
not be designated as Case II because there are no
drinking water supplies present.  Also, as both filter
bed sites are presently in operation, a plume of
contamination currently exists which forecloses the
Case I option for both sites.

With the design of the new facilities, the
contaminated plume is expected to enlarge to the
extent mentioned above.  This enlargement will be
inland and to either side of the existing sites.  The
additional area of contamination represents an
insignificant loss to the total groundwater supplies
for the Island, and, because of its proximity to the
existing filter beds and ocean, was unlikely to ever
be developed for drinking water purposes.  The
benefits derived from the new treatment facilities
outweigh the insignificant loss of potential water
supply area.

The Board of Selectmen for Nantucket has requested the
Mass. Division of Water Pollution Control to designate
the contaminated groundwater plumes, identified on
Figures 8 and 10 of the Goldberg, Zoino report as Case
III.  The Town intends to purchase ;the area in fee
simple and has agreed to convenant the title of the
land within the control area to preclude the possible
construction of drinking water wells.
                      16

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Chapter 2
Recommended Actions

-------
CHAPTER 2 RECOMMENDED ACTIONS

2.1  NANTUCKET CENTER WASTEWATER FACILITIES

     The Nantucket Center planning area will require a
     wastewater treatment facility with a 20-year planning
     period design average flow of 1.8 mgd.  The principal
     facility elements include:  preliminary treatment facility
     comprising comminution, grit removal and flow metering;
     primary treatment settling tank;  and rapid infiltration
     recharge beds for Affluent disposal.  Provision for future
     disinfection facilities will be included.  The facility
     will be located at the same site as the existing rapid
     infiltration beds at Surfside.  The site will be expanded
     to include a 90 acre buffer zone around the filter beds
     and a sludge composting facility.  This will provide a
     Case III management zone consistent with Section 1.2.4,
     above (see Figure D).

     The basic design criteria are as follows:

         a.   Preliminary treatment

              Two parallel comminutor and aerated grit chamber
              units sized for 6.0 mgd peak hydraulic flow

         b.   Flow metering:

              Parshall flume with capacity to 6.0 mgd

         c.   Primary Sedimentation:

              Three parallel 0.6 mgd sedimentation basins;
              600 gpd/sq.ft. overflow rate at 1.8 mgd flow rate

         d.   Recharge Beds:'

              Gravity flow pipeline from primary treatment
              facility with peak flow capacity of 6.0 mgd

              10 beds with total area of 10.1 Ac.; design
              application rate of 4.0  gpd/sq.ft. @ 1.80 mgd
              design average flow

         e.   Composting facility:

              One acre paved pad with forced air blower system
              of perforated plastic pipe; 1700 cu. yd.  wood
              chips per year;  pad drained to primary treatment
              units.

     The existing site will be regraded and the beds will be
     raised to provide a minimum free-flowing depth of 4 feet
     to groundwater.  The construction of an access control
                               17

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 fence  around  the  treatment  facilities will be required as
 part of  the site  improvements.  A control building and
 laboratory facility will be required at the treatment
 site.  A 1,000  sq.ft. building will be adequate  for
 facility needs.

 The high cost of  electrical power on Nantucket makes the
 installation  of a wind  turbine at the Surfside site a
 cost-effective  and innovative action.  A 10 kw wind
 turbine  would cost approximately $25,000 installed and
 would  produce at  least  30,000 kwh/yr of electrical power.
 At $.10  per kwh for purchased energy, the present worth
 value  of the  power produced by the wind machine  is at
 least  $31,500 for the 20-year planning period and is,
 therefore, cost-effective.  A 10-kw wind machine could
 supply approximately 60 percent of the electrical power
 requirements  at Surfside (for Siasconset a 5 kw machine
 may be more cost-effective).  The type of wind machine
 that would be selected would be one that would operate in
 a synchronized manner with the power company supply such
 that there would be no  interruption in service.

 A number  of potential treatment site locations were
 investigated  between the airport and Long Pond.  However,
 none presented any advantages over that of the present
 Surfside  location.  In  fact, the Surfside site appears to
 be by  far the best location for a facility in terms of
 transmission  and separation from conflicting land uses.
 The present acceptance of this site by the public, and the
 fact that the groundwater under this site is already
 dedicated to  wastewater discharge, also supports the
 conclusion that this site is the most cost-effective and
 environmentally suitable location for the Nantucket Center
 treatment facility.

 Sludge composting at the Surfside facility is recommended
 as the preferred method of sludge stabilization.  The
 composted sludge will be used by the DPW and local
 citizens  for gardening a,nd landscape activities.  The
 composing facility will serve the Siasconset as well as
 the Surfside  service areas.  Dewatering and chemical
 stabilization of the sludge will be provided prior to
 composting.

The Nantucket Center treatment facility will be used for
 handling septage wastes from all areas of the island.
Facility requirements for septage handling include a
 receiving station, grit removal facility, aerated holding
 tanks with 16,000 gallons capacity and pumping and
conveyance facilities to discharge the septage into the
 head end of the primary settling facility.

Collection and transmission facility improvements are  also
 recommended for the  Nantucket Center area.   Downtown
                          18

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                           MAXIMUM EXTENT
                           OF LEACHATE PLUME
                                                                           PRIMARY; TREATI
                                                                           FACILITY
                                       ATLANTIC
OCEAN
     Recommended Case 3 Control Area
                                                            Fig. D. Surfside Treatment Facility
Final EIS Report — Nantucket Wastewater Treatment Facilities

-------
     sewers will be rehabilitated as described previously in
     Section 1.2.1.3.  Recommended improvements to the Sea
     Street pumping station, plus a new force main and relining
     the old force main, are being accomplished under a
     separate project which was removed from the EIS process
     because of the need for immediate improvements.

     Other collection facility improvements which are
     recommended as second phase actions, to be undertaken at
     the point in time when their need becomes apparent,
     include:

     o   Construction of a pump station and force main to
         divert flows from Milestone, Old South Fairgrounds and
         Hooper Farm Roads away from the Washington Street
         interceptor and the Sea Street pumping station.

     o   Construction of a new trunk sewer to serve the Old
         South Road corridor.

     Miscellaneous infiltration/inflow reduction measures are
     also recommended to be undertaken in accordance with
     Section 6.3 of the 201 Facilities Plan.   These include
     sewer grouting and relining, the removal of several  roof
     drainage connections,'and the removal of several catch
     basins.

2.2  Siasconset Wastewater Facilities

     The Siasconset planning area will require a wastewater
     treatment facility to be located at the currently utilized
     site, with a 20-year planning period design average  flow
     capacity of 260,000 gpd.  An additional 5 acres will be
     acquired to adequately buffer the 20 acre plume,
     consistent with Section 1.2.4,  above (see Figure  E).

     Raw wastewater will be comminuted,  receive grit removal
     treatment and flow metering prior to the primary
     clarification units.  Two primary clarifiers will be
     provided.   Each will have a design  flow capacity  of
     130,000 gpd.  During peak summer flow periods both
     clarifiers will be used in parallel fashion.  During the
     winter low flow period only one clarifier will be required.

     Clarified effluent will flow by gravity onto the  filter
     beds through a system of conveyance channels.   A  total of
     65,000 sq.ft. of bed application area will be required for
     the 20-year design summer flow  based on  an application
     rate of 4.0 gpd per sq.ft.  Provision for future
     disinfection facilities will be included in the design.
                               19

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The basis of design for the facility components are as follows:

    Preliminary Treatment:

      Comminution, grit removal and filow measurement sized
      for 1.2 mgd peak flow

    Primary Treatment

      -  Two clarifiers sized for 130,000 gpd each

      -  Overflow rate = 600 gpd/sq.ft. at 0.26 mgd flow
         rate

    Sand Filter Beds:

         Six beds with total area of 65,000 sq.ft.

      -  Hydraulic loading rate =4.0 gpd/sq.ft. at
         0.26 mgd

         Organic loading rate = 274 Ib./ac/day

In terms of sludge handling, it ,is recommended that the
sludge be chemically stablized and stored for eventual
transportation and further processing at the Surfside
Facility.

Site improvements will include a control fence around the
treatment facilities,  a paved access road, a small (20' x
20') control building, and a 5 kw wind turbine electrical
generator.
                        •(        .      .      ..      .
The present recharge bed treatment site is the most
suitable location for  treating the wastes from the
Siasconset area for the following reasons:

1.  The site is in close proximity to the service area.

2.  The present filter beds and conveyance pipeline can be
    utilized.

3.  The site is a good location relative to the diffusion
    of the underflow into  the ocean.

4.  There is good isolation from most surrounding land
    uses and land is available to secure adequate buffers
    from future development.
                          20

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::::::::::::::::  Recommended Case 3 Control Area
                                                                         «

                              ' Fig. E.  SiasconsetTreatment Facility
 Final EIS Report
_ Nantucket Wastewater Treatment Facilities

-------
     The main  trunk sewer to the filter beds is a 12" line with
     a  peak  flow capacity of 1.3 mgd.  This line will be
     adequate  for the flow projected through the 20-year
     planning  period.

     The 201 Facilities Plan's proposed second-phase
     improvements to the Siasconset collection system would
     include the eventual installation of approximately 8,200
     L.F.  of 8" sewers to service that portion of Siasconset
     zoned for 5,000 square foot lots.  A portion of this area,
     Cod Fish Park, would require a small lift station and 300
     feet  of 6" force main to tie into the main trunk sewer.
     Funding for these improvements is not included in the
     recommended Phase I project.

2.3  Madaket Area Recommendations

     Although nitrates in groundwater was identified as a
     limited problem in Section 1.2.1.1 "Groundwater Testing,"
     the Town has alternative control mechanisms available.
     These include the Board of Health's notifying affected
     families and, in the event the family includes an infant,
     helping to secure a temporary alternate source of water.
     Once  the infant reaches 3 months of age, the potential
     threat  passes and the family can return to its original
     supply.

     This  is, at best, a temporary fix and does not resolve the
     original problem.  However, sewers are not warranted due
     to the  low land use density and seasonal use of the area.

     The Town of Nantucket should develop a comprehensive
     approach to managing wastewater disposal and water supply
     protection for the entire Island.  The Town should begin
     this  effort in Madaket Village.

     Wastewater disposal through on-site leaching systems is
     regulated under Title 5 of the state Environmental
     Code(11).  Title 5 is based upon standard rates of
     percolation, wastewater volumes and minimum distances
     between water resources and on-site facilities.  The
     minimum distance between a leaching facility and a well is
     100 feet.
        State Environmental Code;   Minimum Requirements for
the Subsurface Disposal of Sanitary Sewage -  Title 5,
Commonwealth of Mass., Dept. of Environmental Quality
Engineering, May 20, 1977.
                               21

-------
Title  5, however, states that specific, identifiable local
conditions may require more stringent regulation to
protect the public health and environment.

The Nantucket Board of Health has adopted more stringent
regulations for new construction in Madaket.  These
"Madaket Reg's" require at least 150 feet between a well
and a  leaching field.  This is a constructive step in the
right  direction.

In at  least two of the Madaket wells that were found to
have nitrates, however, it was noted that the distance
between the well and the septic system was 150 feet, or
more.

Clearly, the criterion of horizontal separation alone is
not enough to protect wells in such rapidly-permeable
soil.  Other factors should be considered in developing
local  regulations for on-site wastewater disposal.

These  variables include:

    1.   design of leaching fields;
    2.   seasonal occupancy and water usage rates;
    3.   actual wastewater output per household/season;
    4.   density of leaching fields and volume of
         wastewater per acre;
    5.   soil permeability and transmissivity;
    6.   pumping rates and density of wells;
    7.   aquifer gradients and recharge volumes;
    8.   agricultural fertilizer or livestock keeping
         practices;
    9.   water conservation to reduce domestic usage.

The Madaket situation does indicate a need for better
management practices.  These would include improved
regulations for locating wells relative to septic fields,
especially in soil with high permeability.  Such  improved
practices are necessary to protect the Island's potable
groundwater resources from degradation due to on-site
wastewater disposal.

Such a management program could require the installation
of waterless toilet  systems in new construction;
initiating a water conservation program;  recommending
proper horticultural  and agricultural fertilization
procedures;  and increasing the Board of Health's
requirement for separation between a private well and
on-site septic disposal systems.
                          22

-------
     The longer-term implications for  Nantucket  Island  are
     clear:  the need to properly manage  and  protect  its
     groundwater is critical.   Groundwater  is the  sole  source
     of potable water on the Island.   The Town should begin
     acting now to manage- that resource.

2.4  Costs of Recommended Actions

     Table 1 presents a summary of the estimated construction
     costs for the various components  of  the  recommended
     facilities plan.  Costs are shown for  both  the Nantucket
     and Siasconset construction activities.   Costs for the
     recommended non-structural management  program for  Madaket
     are unavailable.

     The total capital cost for the recommended  actions is
     $7,000,000.  This cost is based upon the Engineering News
     Record (ENR)  base cost for construction  as  of July, 1981,
     and reflects the most recent estimates from Sheaffer and
     Roland, the 201 Facilities Plan engineer.

     Table 1 also indicates the estimated U.S. EPA and
     Commonwealth of Massachusetts grant  assistance
     participation in the proposed improvements.   Federal and
     State participation are projected to be  $6,464,000 or 92
     percent of the total cost of the  recommended  project
     costs.  The remaining local cost  of  $536,000  would be
     funded by the Town.  The first year  payment on a typical
     20-year bond at 7 percent interest would be $64,320 on
     this local share.

     The 201 Facilities Plan (pg VIII-7)  has  a thorough
     discussion of user fees as the preferred method  for
     recovering these capital  costs and the annual operation
     and maintenance (0 & M)  costs. Based  upon  the number of
     summer season residential users,  combined with commercial,
     hotel, motel and public equivalents, a total  residential
     user equivalent of 3,270  was used to determine individual.
     fees.  Depending upon the final allocation  of costs, the
     typical residential user  can expect  a  fee of  $50 to $55
     per household per year.
                               23

-------
                             Table 1

                  Summary of Recommended Actions
                          Capital Costs
         ITEM
Surfside Primary
Treatment Facilities
and Recharge Beds

Siasconset Primary
Treatment Facilities
and Recharge Beds

Sewer Rehabilitation
- So. Water trunk sewer
- N. Beach sewer
- Lining sewers
- Remove catch basins
- Sewer grouting

Construction Total

Surfside Case III Land
Siasconset Case III Land

Engineering, Contingencies
and Administration

           TOTAL
CONSTRUCTION
    COST
   650,000,
   500,000.
   425,000.
    80,000.
    20,000.
    25,000.
 1,350,000.
   100,000.
 FEDERAL &
  STATE
  GRANTS
$2,450,000.   2,303,000,
  611,000,
  450,000
  382,500
   72,000
     -0-
   22,500
$4,150,000.   3,841,000,
1,269,000
   94,000
 1,400,000.   1,260,000
LOCAL
SHARE
$7,000,000.  $6,464,000
               147,000
 39,000
 50,000
 42,500
  8,000
 20,000
  2,500

309,000,

 81,000,
  6,000,

140,000,
              $536,000
Source:  Sheaffer and Roland, Inc., July 1981 (ENR = 3475)
                               24

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Chapter 3
Environmental Consequences

-------
              CHAPTER 3 ENVIRONMENTAL CONSEQUENCES
3.1  INTRODUCTION -  ENVIRONMENTAL  SCREENING

     The Draft EIS evaluated ten alternate locatons for the
     treatment site, five treatment  alternatives  for Nantucket
     Center,  four treatment alternatives  for Siasconset and six
     service  options for  Madaket Village  (see Chapter 2, DEIS).

     In accordance witp CEQ guidelines, not every conceivable
     impact for each alternative was covered.  Rather, the
     categories were focused,  through an  inter-agency scoping
     process,  on those impacts which were judged to be most
     important.  This resulted in  an impact evaluation of the
     following fifteen environmental categories:

         Water Quality    .              Noise
         Coast Flood Hazard Zones       Land Use/Induced Growth
         Wildlife/Endangered Species    Recreational Use
         Wetlands                      Traffic
         Air Pollution                  Business
         Public Health                  Costs
         Soil  Erosion                  Energy
         Archeological/Historical  Sites

   Comments on the  DEIS  suggested that four additional
   categories be added:

         CZM Consistency               Significant Agricultural
                                       Land
         Wild  and Scenic  Rivers        Mineral Resources

   A  summary  of  the environmental screening process is
   presented  on  Tables 2,3  and 4.  Table 2 has the Nantucket
   Center  Alternatives.  Table 3 has the Siasconset
   Alternatives  and Table  4 has the Madaket Alternatives.  A
   complete discussion of  each of these impacts is contained
   in Chapter  4  of  the DEIS.

   The screening of alternate locations for the treatment
   facilities  and filter bed sites is not included on these
   tables.  Because alternate sites was not an issue during
   the review  of the DEIS,  the reader is referred to pages 2-1
   through 2-10  of  the DEIS for a complete discussion of that
   evaluation.   It  concluded that, from both an environmental
   and transmission costs  standpoint, the present sites should
   continue in use  as filter beds.
                               25

-------
     The 201  engineer  also  evaluated secondary treatment with a
     discharge  to  the  ocean.(12)  Based upon a preliminary
     cost estimate of  £.7,587,000 for treatment and a 5,500 L.F.
     ocean outfall pipe, plus  environmental effects to bathing
     beaches, the  ocean outfall was dropped from further
     consideration.

     The five treatment alternatives for Nantucket Center
     depicted on table 2 were  reviewed in detail on pages 4-3
     through  4-14  of the DEIS.  Table 2 lists the Nantucket
     alternatives  in five vertical columns, with the type and
     intensity  of  impact indicated by graphic symbols within
     each category.  The categories are read horizontally across
     each column to give a  relative sense of how each
     alternative compares with another.

     The summary charts give an overall picture of the
     environmental impacts  and environmental significance of all
     the alternatives.  The more black dots that appear to the
     right in each column,  the more significant are the adverse
     impacts.  The more triangles in a column, the less
     environmentally significant, and more favorable,  an
     alternative.

     Using these summary tables, the alternatives that were
     dropped from  consideration and the resulting recommended
     actions can be easily  seen at a glance.

     For  the Nantucket options, other than no action,  the
     least-cost construction option is primary treatment.  The
     two  secondary treatment options are next most expensive
     with  low-rate irrigation the most costly.  No action and
     low-rate irrigation have more significant,  adverse
     impacts.  Based upon costs and impacts,  therefore, primary
     treatment is  the perferred option, for Nantucket and the
     others dropped from consideration.

    For the Siasconset options on Table 3,  the  option  with the
     lowest initial capital cost is secondary:   aerated lagoon,
    which  is only slightly less costly than  primary treatment.
    However, when the 201 Plan added the costs  of operating and
    maintaining a secondary treatment plant,  it found  that
    primary treatment costs were less by a factor of  36% (Table
    29, pg. VII-11, 201 Plan).  Over the long run,  therefore,
    primary is  actually less expensive than  secondary
     treatment.   Although primary treatment has  minor  adverse
     impacts to  groundwater quality and soil  filtration,  the
riZ)"Item 1 - Cost of Ocean Outfall",  Sheaffer  and  Roland,
Inc. letter to Bill Richardson,  Anderson-Nichols, Inc. March 3,
1981.
                               26

-------
     significance can be minimized by applying a buffer  zone
     around the site as a mitigation measure.   While no  action
     has no impact in most categories, potential operational
     problems and an increased effect on public health (see
     Section 1.2.2)  make it an undesirable option.   Due  to
     costs, impacts and mitigation measures,  primary treatment
     is the preferred option for Siasconset.

     For the Madaket area alternatives on Table 4,  public water
     is the least expepsive construction option, whereas each
     of the treatment pptions is nearly twice as expensive.
     From the standpoint of impacts, the four structural
     alternatives (3 treatment options;  plus  water)  each have a
     number of significant, adverse environmental impacts.  The
     no action and non-structural management  options have the
     least impact.  The non-structural management option has
     the most beneficial impacts of all the Madaket
     alternatives.  Based upon the environmental impacts, costs
     and the findings of the sewer needs analysis (which found
     no need to sewer Madaket), the preferred option is  the the
     non-structural management program.

3.2  IMPACT EVALUATION PROCESS

     The recommended actions have a number of environmental
     effects on the Island.  Some of those impacts  may be
     beneficial, others will be adverse.  The significance of
     those impacts has been evaluated in context with the
     Island of Nantucket and its local resources.

     The recommended actions have been evaluated using the
     nineteen environmental categories listed  above.   Each
     action is evaluated within each parameter to establish the
     intensity and type of impact.  Impacts are categorized as
     direct or indirect, and short or long-term.  There  may be
     no impact, insignificant impact, minor or major  impact.

     The key consideration is the "significance"  of  an impact,
     whether it be of a short or long term (over  six months)
     nature. Significance requires considerations of  both
     context and intensity.  These are used to gauge  the
     severity of impact.  For this EIS,  four categories  of
     impact have been used.  These are none,  insignificant,
     minor and significant.  These are more fully described
     below:

         a.    No Impact

              This is self-explanatory;  there  are no  impacts on
              the environment due to the actions  proposed.
                               27

-------
                 Table 2
                 Nantucket EIS
                 Environmental  Impact Profile
Nantucket Center Alternatives
NJ
oo
                 Category of Impact
1 Water Quality
2 Coastal Flood Hazard
3 Wildlife / Endangered Species
4 Wetlands
5 Air Pollution / Odors
6 Public Health
7 Soil Filtration
8 Noise
9 Land Use / Induced Growth
10 Recreational Use
11 Traffic
12 Business
13 Costs
14 Energy
15 Archeological / Historic Sites
16 Mineral Resources
17 Significant Agricultural Land
18 Wild & Scenic Rivers
19 CZM Consistency
COST (Total Capital Costs: $ million
updated from 201 Plan x 1.29 as per
S & R)

O

O







O


O
O
O
O
O





•

•
•
•
•

•
•





•

A

•

•































$4.626





















0

O







0


0
O
O
O
O
•




e
•
•
•
•
•












•







•
•







A
















$5.356

^



















O

O







O


O
O
0
O
O
•




•
•
•
•
•
•










A

•







•
•
























$5.289





















O













O

0
O


•
•


A



•
A




•


A'




•

•
•
•









1


,-
•







•
•
•




$7.611




















O

O



O

O
O
O
0
O
O
O
O
O
O








•










•

A

•
•
•
































                 Type  S Intensity of Impacts:   ^adverse   Abeneficial   O no impact

-------
Table  3
Siasconset Alternatives
Nantucket EIS
Environmental Impact Profile
Category of Impact
1 Water Quality
2 Coastal Flood Hazard
3 Wildlife / Endangered Species
4 Wetlands
5 Air Pollution / Odors
6 Public Health
7 Soil Filtration
8 Noise
9 Land Use / induced Growth
10 Recreational Use
11 Traffic
12 Business
13 Costs
14 Energy
15 Archeological / Historic Sites
16 Mineral Resources
17 Significant Agricultural Land
18 Wild & Scenic Rivers
19 CZM Consistency
COST (Total Capital Costs: $ millions
updated from 201 Plan x 1.5 as per S&R)

0
0
o





o
o
o


o
o
o
o
0





•

•
•



•
•





•



•

•































$0.974





















o
o
o





0
o
o


o
o
o
o
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•




•
•
•
•




•









•







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$1.658





















o
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$0.915




















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Type &  intensity of impacts:  • adverse   A beneficial  O no impact

-------
Table 4
 Nantucket EIS
 Environmental  Impact Profile
Madaket  Alternatives
Category of Impacts
1 Water Quality
2 Coastal Flood Hazard
3 Wildlife / Endangered Species
4 Wetlands
5 Air Pollution / Odors
6 Public Health
7 Soil Filtration
8 Noise
9 Land Use / Induced Growth
10 Recreational Use
11 Traffic
12 Business
13 Costs
14 Energy
15 Archeological / Historic Sites
16 Mineral .Resources
17 Significant Agricultural Land
18 Wild & Scenic Rivers
19 CZM Consistency
COST (Total Capital Costs: $ millions
updated from 201 Plan x 1.4 as per S&R)









O





0
O
O



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•





•
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O

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9

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$5.740





























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$6.216





























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$5.698




















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$3.724




















O
O
0


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Type &  Intensity of^Impacts:   ^adverse   Abeneficial  O no impact

-------
b.   Insignificant Impact

     The action will have a negligible  impact on  the
     environment.

c.   Minor Impact

     The impact will be of importance but  not severe
     enough to be  considered under  the  definition of
     significant,  below.

d.   Significant Impact

     An impact of  major severity and critical
     importance would be rated  as significant.  There
     are no hard or fast rules  to rate  significance.
     The criteria  listed below  were considered  in
     determining the significance of impacts:

          Public health or safety is threatened.

          Unique characteristics, such  as  locally
          important wetlands or historic resources may
          be adversely affected.

          The effects on the quality of the  human
          environment, including economic  concerns are
          likely to be highly controversial.

          The actions proposed  by the alternative may
          open up  potentials for future growth  not
          consistent with local goals and  plans.

          The action, in concert with other
          insignificant or minor actions,  could result
          in a cumulative impact of a significant
          nature.

          The action may have a significant  adverse
          effect on a site listed or eligible for the
          National Register of  Historic Places.   The
          action may cause the  destruction of
          significant scientific, cultural or
         .. historical resources.
                                                   \

          The action may have a significant  adverse
          effect on the habitat of a species
          identified by the Endangered  Species  Act of
          1973.

          The action threatens  a  violation of Federal,
          State, or local law or  requirements imposed
          for the  protection of the .environment.
                      31

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     In addition to Significance,  an impact may be either
     Direct or Indirect.  These two general categories  can  be
     defined as follows:

         e.   Direct effects which are caused by the  action and
              occur at the same time and place.

         f•   Indirect effects, which are caused by the action
              and are later in time or farther removed  in
              distance.   Indirect  effects may include growth or
              induced changes in the pattern of  land  use,
              population density and their related effects  on
              other natural systems.
3.3  ENVIRONMENTAL IMPACT EVALUATION

     The recommended actions to  service Nantucket Center and
     Siasconset are primary treatment of wastewater  followed by
     rapid infiltration land disposal at separate facilities
     located at the present Surfside  and Siasconset  disposal
     sites.   A long-term water supply-wastewater disposal
     management program is recommended for Madaket Village.

     These recommended actions are  evaluated  in the  following
     section.  Each action is evaluated within each  of the
     nineteen environmental categories, noted above, and
     impacts are categorized as  direct or indirect,  short or
     long term and in the level  of  significance.  A  narrative
     text provides background on each evaluation.

  3.3.1  Nantucket Center Recommended Actions

         Primary wastewater pretreatment facilities  with rapid
         infiltration at the Surfside filter beds, a 90 acre
         management area, a septage handling  facility, sludge
         composting,  wind generator,  downtown sewer
         rehabilitation and long-term sewer service  along Old
         South Road towar(? the Airport are the recommended
         actions for  Nantucket Center.  The impacts  and
         environmental consequences are as follows.

              3.3.1.1  Water Quality;  Direct, Long-Term,
                       Minor, Adverse

              Groundwater quality in  the vicinity of the
              filterbeds would continue to be adversely
              affected by high nitrate levels in the wastewater
              plume.   Since this represents no change over that
              of the  previous 50-odd  years, the impact is of
              minor importance.  A  Case III designation of the
                               32

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3.3.1  Nantucket Center Recommended  Actions  (cent.)

            plume area as non-potable  and  the Town's
            acquisition of the  90  acre area  to preclude the
            installation of private  wells  would also have an
            impact.   Since there are no houses in  the area,
            however,  and since  ownership patterns  are so
            fragmented, this Case  III  designation  will have
            only a minor impact because of the remote
            likelihood of ever  using the groundwater for
            potable  supplies.   The Mass. Division  of Water
            Pollution Control  (DWPC) will  require  groundwater
            monitoring wells to check  on future pollutant
            loadings  within the plume.

            Surface water quality  in Nantucket Harbor should
            be improved as a result  of the improvements to
            the Sea Street Pump Station and  force  main.
            These improvements  will  eliminate the  causes of
            sewage overflows to the  Harbor.  This  will
            alleviate the most  serious water quality problem
            facing the Island.

            3.3.1.2   Coastal Flood Hazard;  No Effect

            None of the facilities at  the  Surfside treatment
            beds would be located  within a Federal flood
            hazard area.   Neither  the  completed project or
            any future growth on the Island are expected to
            worsen flood damage and  losses due to  storms.
            EPA policy is not to provide funding for, any
            project that would  promote  growth in an
            environmentally  sensitive  area such as a flood
            hazard zone.

            3.3.1.3   Wildlife/Endangered Species!   Indirect,
                     Long-Term, Minor,  Beneficial

            Construction  of  the facilties  and the new sewer
            beds would not directly  effect the tern nesting
            areas at  Surfside.  The  terns presently nest in
            the area  between the filter beds and the beach.
            The location  of  the new  filter beds is in a line
            behind those  presently constructed and parallel
            to  the beach.  The  proposed ownership-management
            area which would be associated with the Surfside
            treatment  facilities would  enable the management
            of  wildlife within  that  zone.   This creates an
            indirect,  long-term, minor, beneficial impact for
            wildlife management within  the ownership area.
            No  endangered  species are affected by the
            proposed project.
                             33

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3.3.1  Nantucket Center Recommended Actions  (cont.)

            3.3.1.4  Wetlands;   No Effect

            The only wetland in  the vicinity  of  the  Surfside
            filter beds is the beach and dune system along
            the Atlantic Ocean.   Since  the proposed  filter
            beds will be built well behind the primary dunes,
            no wetland impacts are anticipated.  EPA policy
            is not to fund any projects that  would promote
            growth ip an environmentally sensitive area, such
            as wetland.

            3.3.1.5  Air Pollution-Odors;  Direct, Long-Term,
                     Minor,  Adverse

            Adverse effects  are  probable, due to odor and
            aerosols generated by the proposed facilities.
            Major sources of odor are likely  to be the open
            primary clarifiers,  the septage receiving
            facility and the sludge processing facility.
            Meteorological data  indicate that the prevailing
            wind direction is from the  southwest during the
            warm weather months  and from the  northwest during
            the cold weather months.  The predominant
            direction is from the southwest at an average
            velocity of 13 mph.   At Surfside,  the area with
            the highest potential for odor or  aerosol impact
            is the area east-northeast  of the  beds at the
            southerly end of Surfside Road.  Proper  operation
            of the primary treatment facility  and the
            proposed management  buffer  zone should keep,the
            odor impacts minor.   Operation of  the facility
            should have no effect on the Massachusetts SIP
            air pollution control plan.  Exhaust from
            construction vehicles would create temporary
            impacts during the reconstruction  of the sewers
            in the downtown  area.   These impacts would be
            highly localized and relatively minor.

            3.3.1.6   Public  Health;  Direct, Long-Term,
                     Insignificant,  Adverse

            Minor  adverse impacts  which currently exist would
            be further  reduced by the implementation of the
            proposed action.  The provision of the management
            area and associated  fencing of the filter beds
            would  minimize public  contact.  The buffer zone,
            if extended to the boundary of the wastewater
            plume,  would also prevent private wells  inside
            the plume that could jeopardize public health.
                             34

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3.3.1  Nantucket Center  Recommended Actions  (cont.)

            3.3.1.7   Soil Filtration;  Direct, Long-Term,
                     Minor,  Adverse

            The filtration of  wastewater would be  improved
            over the  present no-action situation.  However,
            nitrates  would still  reach the groundwater at a
            rate of 392  Ibs./day  by the year 2000.  Suspended
            solids on the beds would be reduced, improving
            oxidation and improving drying time, but the
            presence  of  nearly a  ton per day of solids would
            still require scraping to keep the beds from
            clogging, causing  long-term, minor, adverse
            effects.

            3.3.1.8   Noise;  Direct, Long-Term,
                     Insignificant, Adverse

            Noise effects from the operation of equipment,
            sludge processing, septage dumping and composting
            would be  on-going, but insignificant impacts.
            Short-term noise impacts would result during
            construction of  the facility and the
            rehabilitation of  the sewers.

            3.3.1.9   Land Use/Induced Growth;  Direct,
                     Long-Term, Insignificant, Adverse

            The proposed actions will serve to concentrate
            growth in the downtown areas as lots are infilled
            and tie into the existing sewer system.
            Long-term impacts will be to consolidate growth
            in  a corridor running out toward the airport.
            Both of these impacts are consistent with the
            Town's zoning and  its growth management policy.

            The proposed 90 acre Case III management area at
            the filter beds would have an adverse affect on
            the future development of those parcels.  Because
            the parcels  are so small and title is difficult
            to  clear,  this impact is relatively minor.

            3.3.1.10  Recreational Use;   Direct, Long-Term,
                     Insignificant, Adverse

            The project  will hinder     recreational access
            to  the beach.  At present, beachgoers may gain
            access through the filter bed site on their way
            to  the beach.  This access will             be
            blocked by a  fence around the treatment
            facilities.  Access along the beach is not be
            affected.   This impact is rated as insignificant,
            since the filter beds are not used to any great
            extent for beach access.
                             35

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3.3.1  Nantucket Center Recommended Actions  (cont.)

            3.3.1.11  Traffic;   Direct, Long-Term,
                      Insignificant, Adverse

            Increased movement  of  septage pumper trucks will
            increase the flow of traffic to the filter beds.
            The beds, however,  are remote and  the access road
            runs through a sparsely populated  area.  The
            impacts would, therefore, be insignificant.
            Plans ar£ to pave only that portion of the access
            road within the treatment plant site to allow
            maneuverability to  septage haulers on a
            year-round basis.

            Temporary traffic impacts could result during the
            rehabilitation of the  downtown sewers.  Streets
            that will be affected  include:  North Beach,
            South Water, South  Beach and Washington.
            Temporary detours and  construction during the
            off-peak season from September through June will
            minimize the impact on local traffic.

            3.3.1.12  Business;  No Effect

            The proposed action is located entirely at the
            filter bed site at  Surfside Beach.  It will not
            affect businesses.   (It should be  pointed out,
            however, that the associated force main project
            could have a direct effect on businesses if the
            force main route were  to be constructed through
            the downtown business  district.  For a discussion
            of  the forcemain  and impact on business, please
            see the "Environmental Review:  Alternate Force
            Main Routes",  NPEDC, July 24, 1980).

            The rehabilitation  of  the sewers in downtown
            Nantucket could have an adverse effect on
            businesses if work  is  done during  the summer
            tourist season.  This  will be avoided, however,
            by  completing all construction during September
            through June.   The  only street where businesses
            could be affected,  South Water, has largely a
            summer-oriented clientel.

            3.3.1.13   Costs;  Direct, Long-Term,
                      Insignificant,  Adverse

            Primary treatment at the Surfside  filter beds is
            the  least  costly of  the options proposed for
            Nantucket  Center.  The capital cost would amount
            to  $4,626,000,  including land acquisition,
            engineering  and contingencies.   This is
            determined to  have an  adverse impact,  but it is
            less  signficant than the other treatment options


                             36

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3.3.1  Nantucket Center Recommended Actions  (cont.)

            proposed.   The cost to  service an  average
            customer would be about $50  per  year, which  is
            the least  expensive unit service cost of any
            alternative.

            3.3.1.14   Energy;  Direct, Long-Term,
                      Insignificant,  Adverse

            There is some energy cost associated with the
            operation  of the  control  building, disinfection
            facilities and sludge composting facilities.  The
            combined power requirements  for  the recommended
            action are expected to  be 50,000 kilowatt hours
            per year,  at an annual  cost  of £5,000.  This is
            the least  energy-consuming alternative.  Energy
            costs will be further reduced by the installation
            of a wind  powered.turbine generator on site.

            3.3.1.15   Archaeological/Historical;  No Effect

            An archaeological review  of  the  proposed project,
            including  the rehabilitation of  the downtown
            sewers, was conducted through the Mass.
            Historical Commission.  MHC  staff concluded  that
            the proposed actions were unlikely to affect
            significant historic or archaeological
            resources.   No further  review in compliance  with
            Section 106 of the  National  Historic Preservation
            Act is required.

            3.3.1.16   Mineral Resources;  No Effect

            No significant mineral  resources are affected by
            the recommended actions.

            3.3.1.17   Significant Agricultural Land;  No
                      Effect

            No significant agricultural  lands will be
            affected by the recommended  actions.

            3.3.1.18   Wild and  Scenic Rivers;  No Effect

            There are  no listed wild  or  scenic rivers in
            Nantucket.

            3.3.1.19  CZM Consistency;  No Effect

            The proposed actions  for Nantucket Center are
            consistent  with all Massachusetts Coastal Zone
            Management  policies.
                             37

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3.3.2  Siasconset Recommended Actions

       Primary wastewater  pretreatment  facilities with rapid
       infiltration at the Siasconset filter beds, a 20 acre
       management area,  six sand  filter beds, a small wind
       generator  and sludge stabilization and storage
       facility are the  recommended actions for Siasconset.

            3.3.2.1  Water Quality;  Direct, Long-Term,
                     Minor,  Adverse

            The groundwater  in  the vicinity of the filter
            beds  has been  degraded as the result of more than
            50 years of  wastewater disposal at the site.
            Nitrates in  the  wastewater column would continue
            to degrade the groundwater  (65 Ibs./day by 2000),
            preventing its use  as a source of drinking water
            supply.   A Case  III designation of the 20 acre
            plume area has been requested by the Town to
            prevent installation of wells.  There is public
            water service  available in the street immediately
            above the filter beds.  Overall effects on ground
            water quality  would be adverse, although not
            significant  in context with the entire Island.
            No surface water resources are affected by the
            recommended  actions.

            3.3.2.2   Coastal Flood Hazard;  No Effect

            None  of the  facilities recommended for
            construction at  the filter bed sites would be
            located within a federal flood hazard area.  EPA
            policy is not  to fund projects which would
            promote  growth in environmentally sensitive
            areas,  such as a  coastal flood hazard zone.

            3.3.2.3   Wildlife/Endangered Species;   No Effect

            Construction of  the facilities at the Siasconset
            filter beds would not affect the habitat of any
            major  wildlife species.  There are no known
            nesting  areas  in  the immediate vicinity of the
            filter beds on the beach.   The proposed Case III
            management area  associated with the Siasconset
            treatment  facilities would enable management of
            wildlife within  that zone if a wildlife habitat
            became established there.   No endangered species
            would be  affected by the recommended action.
                            38

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3.3.2  Siasconset Recommended Actions  (cont.)

            3.3.2.4   Wetlands;   No  Effect

            The only wetland in the vicinity  of  the proposed
            Siasconset treatment facilities is the beach and
            dune system along the Atlantic Ocean.  EPA policy
            is not to fund projects which would  promote
            growth in environmentally  sensitive  areas, such
            as wetlands or beaches. Although the existing
            filter beds are located on,a high beach and,
            therefore,  technically  in  a wetland  area, they do
            not adversely effect the function of the beach as
            a wetland.   Since the existing and the proposed
            filter beds would be built well behind the
            primary  dunes, no wetlands impacts are
            anticipated.   Cod Fish  Park is also  on the high
            beach and technically may  come under state
            coastal  wetland regulations.  Since  the proposal
            is to serve only existing  houses, no new effects
            are anticipated.   Capacity at the proposed filter
            beds includes only existing development at Cod
            Fish Park.

            3.3.2.5   Air  Pollution/Odors;  Direct, Long-Term,
                     Minor,  Adverse

            Odor generated by the proposed facilities is
            probable,  although  probably less  than what
            presently exists.   Potential sources of odor are
            the two  open  primary clarifiers and  the sand
            filter beds.   At  Siasconset the potential for
            odor impact is somewhat less than at Surfside,
            even though there are several houses within 1,000
            feet of  the beds.   This is because the prevailing
            winds would normally carry odors  and aerosols out
            to sea.   Proper  operation of the plant would
            keep the air  pollution  impacts to a  minor level.
            Temporary air quality impacts could  exist on a
            highly localized  basis  as  a result of
            construction  activities.

            3.3.2.6   Public Health;  Direct, Long-Term,
                     Insignificant, Adverse

            Minor adverse impacts which currently exist
            include  the potential for  human contact and
            vector transport  by insects, birds and rodents.
            These conditions  would  still exist,  but would be
            improved by this  alternative, due to the
            inclusion of  fencing around the site and a land
            buffer zone.   Private wells would be precluded
            within the  area,  so no  nitrate contamination
            would result  from the filter beds.  Although
            these mitigating  measures  can be used to reduce
            the impact  on public  health, an insignificant
            adverse  effect would  remain.
                             39

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3.3.2  Siasconset Recommended Actions  (cpnt.)

       3.3.2.7  Soil Filtration;   Direct, Long-Term, Minor,
                Adverse

            Clogging of the  surface on the filter beds would
            be reduced over  that  experienced with no
            treatment.  Solids would be applied at a rate of
            up to 174 Ibs./day by the year 2000 and would
            still clog the sand beds.  The beds would have to
            be scraped on a  regular basis in order to remove
            the organic mat  that  develops, and the use of the
            beds would still have to be rotated as each bed
            became loaded to capacity.  This would be less a
            problem than with no  treatment.

            3.3.2.8  Noise;   Direct, Long-Term,
                     Insignificant, Adverse

            Short-term noise impacts would be probable, due
            to construction  of the facilities.  Long-term
            impacts would result  from maintenance equipment
            but these effects  are expected to be very
            insignificant.

            3.3.2.9  Land Use/Induced Growth;  Indirect,
                     Long-Term, Insignificant, Adverse

            The proposed actions will serve to concentrate
            growth in the high-density zoned areas of
            Siasconset Village.  This is consistent with the
            Town's growth management policies.  The
            additional 5 acres which the Town would need to
            add to control the 20 acre area affected by the
            plume  will have  an adverse affect on development
            of those  parcels.  This adverse impact would be
            of insignificant  importance in context with the
            entire Island.  A new house constructed to the
            south  of  the disposal site will not be affected
            any more  than it presently is as a result of its
            proximity to the filter beds.  The Town should*
            discourage such  construction on the high beach
            area,  consistent with coastal regulations.

            3.3.2.10   Recreational Use;  No Effect

            The proposed treatment option will not have any
            effect on the recreational use of the beach.   At
            present,  there is very little use of the
            back-shore behind the beach in the immediate
            vicinity  of ,the filter beds.   Most swimming takes
            place  further up the beach at Cod Fish Park.
            Access  along the beach will not be affected.
                            40

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3.3.2  Siasconset Recommended Actions  (cont.)

            3.3.2.11  Traffic;   No  Effect

            A small, paved access road  would be  constructed
            onto the site for access to the control
            building.  The access road  would be  used only
            occasionally by DPW personnel.  The  frequency of
            these visits would not  increase appreciably over
            those at present.

            3.3.2.12  Business;  No Effect

            The proppsed action is  located entirely at the
            filter bed site at Siasconset.  It will not
            effect existing businesses  in the Siasconset area,

            3.3.2.13  Costs;   Direct, Long-term,
                      Insignificant, Adverse

            Costs of the recommended action are  estimated at
            $974,000 with annual user charges of about $50
            per house.  These costs are judged to be adverse,
            although relatively insignificant in terms of the
            costs of alternatives.

            3.3.2.14  Energy;   Direct,  Long-term,
                      Insignificant, Adverse

            Energy requirements  for the recommended action
            amount to 10,000  kilowatt hours per year at a
            cost of $1,000  per  year.  These requirements are
            the least energy  consuming  of any treatment
            alternative  and have an insignificant adverse
            effect.   These  costs will be mitigated by the
            installation of a wind-powered generator on site.

            3.3.2.15  Archaeological/Historical;  No Effect

            No  historical or poteritial  archaeological sites
            have been identified in the vicinity of the
            Siasconset filter beds.  A Phase I survey
            indicated there would be no archaeological or
            historical impacts associated with any treatment
            process  at the  Siasconset site.  Mass. Historical
            Commission staff concluded  that there will be no
            impact to significant historic or archaeological
            resources.   No  further  review in compliance with
            Section  106  of  the National Historic Preservation
            Act is required.

            3.3.2.16   Mineral Resources;  No Effect

            No  mineral resources are affected by the
            recommended  actions.
                             41

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3.3.2  Siasconset Recommended Actions (cont.)

            3.3.2.17  Significant Agricultural Land;   No
                      Effect

            No significant agricultural lands  are affected by
            the recommended actions.

            3.3.2.18  Wild and Scenic Rivers;   No Effect

            There are no wild or scenic rivers, underground
            or otherwise, on Nantucket Island.

            3.3.2.19  CZM Consistency;   No Effect

            The recommended actions are consistent with all
            Massachusetts Coastal Zone Management policies.

3.3.3  Madaket Village Recommended Actions

       The recommended action for Madaket is that the  town
       initiate a non-structural, comprehensive wastewater
       disposal and water supply protection management
       program.  This should include  improved  regulations  for
       locating wells relative to septic fields, initiating a
       water conservation program, encouraging the use of
       waterless toilet systems in new construction, and
       encouraging improved agricultural fertilization and
       livestock keeping practices.

            3.3.3.1  Water Quality;   Direct, Long-term,  Minor,
                     Beneficial

            Continued on-site disposal of wastewater at
            Madaket under the present Madaket  regulations
            creates the potential for occasional
            contamination of wells.   The relatively low
            frequency of contamination would be of minor
            significance.

            Based on a sample survey,  the 201  facilities plan
            projects that 20 to 40 houses in Madaket might
            experience problems with  private water supply.
            These problems would include nitrate levels  above
            the 10  milligrams per liter  level  (mg/1) of
            contamination.  Implementation of  £he
            non-structural program would consist of a  number
            of elements designed to eliminate  contamination
            of new or existing private wells.   This would
            have an important beneficial effect on water
            quality in private wells.
                             42

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3.3.3  Madaket Village Recommended Actions  (cont.)

            3.3.3.2  Coastal Flood Hazard;  No Effect

            The implementation of a non-structural  management
            program in Madaket would not  have an  impact on
            future growth.   Therefore,  there would  be  no
            likelihood of induced construction in the  coastal
            flood hazard zone as  a result of this option.

            3.3.3.3  Wildlife/Endangered  Species;   No  Effect

            Implementation  of the non-structural  management
            option would not affect any wildlife  habitat.
            Since no induced growth would result, there would
            be no indirect  impact on wildlife or  endangered
            species.

            3.3.3.4  Wetlands;  No Effect

            Implementation  of the non-structural  management
            program would not impact wetlands, and, since no
            induced growth  would  be generated, there is no
            likelihood of any indirect  adverse impacts on
            wetlands.

            3.3.3.5  Air Pollution/Odors;  Direct,  Short-Term,
                     Insignificant, Adverse

            There would be  exhaust from equipment during
            implementation  of various elements of the
            non-structural  program.   However, these air
            pollution  effects would be  highly localized and
            very  insignificant.

            3.3.3.6 Public Health;   Direct, Long-Term, Minor,
                    Beneficial

            Construction of the various non-structural
            program elements would have a beneficial
            long-term  effect on public  health.  This would be
            due to the reduction  in exposure to potential
            nitrate contamination in the private water
            supplies.   Because  relatively few houses
            experience problems,  the overall beneficial
            result will be  minor.

            3.3.3.7 Soil Filtration;  No Effect

            Since no primary or secondary treatment facility
            would be constructed  with filter beds, there
            would be no requirement  for soil filtration as an
            element in the  treatment process.  The continued
            use of on-site  septic  systems will not have any
            appreciable effect on  soils in the area.
                             43

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3.3.3  Madaket Village Recommended Actions  (cont.)

            3.3.3.8  Noise;   Direct,  Short-Term,
                     Insignificant, Adverse

            There would be short-term insignificant  noise
            generated by the construction of  various
            non-structural elements.   This would  not be
            excessive and would be highly localized  in nature,

            3.3.3.9  Land Use/Induced Growth;   Indirect,
                    •Long-Term, Insignificant,  Adverse

            The implementation of  a non-structural management
            program could require  increased lot sizes in
            Madaket to prevent excessive depletion of the
            limited water supply and  to reduce  the further
            build-up of nitrates from septic  tank leachates.
            This element of  the program could have an
            adverse, short-term impact on growth, although
            the long-term effect would be to  sustain balanced
            growth within the carrying capacity of the
            aquifer.  This is consistent with the Town's
            growth management policy  and is considered to be
            an insignificant private  impact in  terms of the
            costs of the alternative  to the general  public.

            3.3.3.10  Recreational Use;  No Effect

            The recommended  action would not have any impact
            on recreational  activities in Madaket.

            3.3.3.11  Traffic;   No Effect

            The implementation of  a non-structural program in
            Madaket would not have any effect on  traffic.
            Since there would be no new growth  induced by the
            management program there  would be no potential
            for resulting traffic  increases.

            3.3.3.12  Business;  Indirect, Long-Term, Minor,
                      Beneficial

            The implementation  of  a non-structural program in
            Madaket could have  a long-term minor beneficial
            impact resulting  from  future growth in Madaket
            under  the  improved  regulations.

            3.3.3.13   Costs;  Direct,  Long-term, Minor,
                      Adverse

            Although the  Final  EIS  has not been provided any
            costs  for  the non-structural program, there would
            be  costs  associated with  the various elements.
                             44

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3.3.3  Madaket Village Recommended Actions  (cont.)

            The elements might include community leaching
            fields or a limited water  supply  system or
            relocation of septic systems  or  improved land  use
            regulations.  Each of these elements would  have  a
            public cost that is judged to be  adverse,
            although not of major significance  in context
            with the other recommendations.

            3.3.3.14  Energy;   No Effect

            The implementation of a non-structural  management
            program would have little  or  no energy
            requirements.

            3.3.3.15  Archaeological/Historical;  No Effect

            A non-structural management program would be
            oriented to improving on-site septic systems.
            Since the earlier  construction of these systems
            would have disturbed earth at that  site, there
            would be little or no potential for historic or
            archaeological impacts.

            3.3.3.16  Mineral  Resources;  No  Effect

            No mineral resources are affected by the
            recommended actions.

            3.3.3.17  Significant Agricultural  Land;  No
                      Effect

            No significant agricultural lands will  be
            affected by the non-structural management program.

            3.3.3.18  Wild .and Scenic  Rivers;   No Effect
                          \
            There are no wild  or scenic rivers  in Madaket.

            3.3.3.19  CMZ Consistency;  No Effect

            The proposed actions for Madaket  Village are
            consistent with Massachusetts CZM policies.
                             45

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Chapter 4
Mitigation Measures

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CHAPTER 4 MITIGATION MEASURES

4.1  WATER QUALITY

     The implementation, of a Case III buffer zone around the
     Surfside and Siasconset filter beds is the most
     significant mitigation measure for water quality.  The
     Town of Nantucket has requested the Division of Water
     Pollution Control (DWPC) to designate the 90 acre plume at
     Surfside and the 20 acre plume at Siasconset as Case III
     buffer zones.  The Town will then acquire these zones and
     preclude private wells from being established in the area
     affected by the plumes.

     This Case III measure will be supplemented by a DWPC
     requirement to monitor the quality of groundwater in the
     plume on a regular basis.  If pollutant loadings increase
     substantially over projected levels, the monitoring will
     detect it and the need for disinfection could be
     evaluated.  The recommended action suggests that, while
     disinfection facilities are not warranted under present
     circumstances, the facilities will be designed to allow
     their provision, if and when needed.

     Good construction practices will be followed during the
     construction of the new facilities and the rehabilitation
     of sewers.  These practices will ensure that runoff and
     siltation is minimized and that dewatering operations be
     controlled with sediment traps or retention basins.  When
     such activities takes place within 100 feet of a wetland,
     a permit will be sought from the Nantucket Conservation
     Commission.   Runoff from the composting pad at Surfs'ide
     will be collected and run back to the head end of the
     treatment plant.

     The Mandaket non-structural program will result in a
     gradual improvement of groundwater quality in the Madaket
     aquifer.   This will have an important, beneficial effect
     on water quality in private wells.

4.2  COASTAL FLOOD HAZARDS

     EPA policy is not to provide funding for any project that
     would promote growth in an environmentally sensitive area,
     such as a coastal storm hazard flood zone.  The controls
     on the provision of sewers will be consistent with the
     prevention of coastal flood hazard,  the Massachusetts
     Wetland Protection Act,  MA Executive Order 181 and the
     Nantucket Conservation Commission requirements.
                               46

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4.3  WILDLIFE/ENDANGERED SPECIES

     The improvements at the Surfside filter beds will be
     implemented in a manner that enhances the adjacent tern
     nesting area.  The Nantucket Planning and Economic
     Development Commission's (NPEDC) proposed management area,
     in conjunction with the 90 acre buffer zone, would enable
     the management of wildlife within the entire area.  The
     Town should coordinate such a management program with
     representatives of local wildlife groups.

4.4  WETLANDS

     EPA policy is not to provide funds for any project that
     would promote growth in a wetland area.  The controls on
     the provision of sewers shall be consistent with the
     requirements of the Mass. Wetlands Protection Act,
     Massachusetts Executive Order 181 and the requirements of
     the Nantucket Conservation Commission.  The provision of
     sewers to Cod Fish Park, which might technically be
     considered a wetland area, shall be conditioned with these
     requirements.  Capacity at the Siasconset filter beds has
     been provided only for existing structures located at Cod
     Fish Park.  No new structures will be serviced.  Future
     grants should preclude service to structures located in
     wetlands which may be built subsequent to the grant action,

4.5  AIR POLLUTION/ODORS

     The most important item in keeping possible odor and air
     quality impacts to a minimum is to operate and maintain
     the treatment facilities, the land application system, and
     the composting facilities in accordance with modern
     sanitary engineering standards.  Any variation from
     recommended operating procedures can have an adverse
     impact on neighbors adjacent to the treatment facilities.

4.6  PUBLIC HEALTH

     The designation of a Case III buffer zone around the
     Surfside and Siasconset filter beds, as recommended by the
     Draft EIS and requested by the Town, will minimize risks
     to public health by preventing public wells from being
     installed in the areas contaminated by the wastewater
     plume.  Fencing the area around the treatment facilities
     will prevent public contact with the filter beds and
     wastewater equipment.   The Madaket non-structural program
     will have a beneficial long-term effect due to the gradual
     improvement in groundwater quality in the Madaket
     aquifer.   This will improve water quality in private wells
     and reduce the risk of nitrates contaminating public water
     supplies.
                               47

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4.7  SOIL FILTRATION

     Proper maintenance of the filter beds will include regular
     scraping of the dried, organic mat.  Loading rates will be
     kept to 4 gallons per day per square foot to ensure
     adequate filtration of wastewater pollutants.

4.8  NOISE

     Proper operation and maintenance procedures will reduce
     noise levels emanating from the treatment facilities.
     These will be coupled with considerate construction
     practices which minimize noise generated by heavy
     equipment during the construction or rehabilitation of the
     sewer facilities.

4.9  LAND USE/INDUCED GROWTH

     The Town of Nantucket should consider growth and land use
     density controls as a part of the non-structural water
     quality management controls for Madaket Village.  Sewer
     hookups will be prohibited in environmentally sensitive
     areas such as coastal flood plains, wetlands, prime
     agricultural lands or beachfront areas.

     Aesthetic impacts at the filter beds, such at those
     created by high visibility of the facility, will be
     minimized by design elements such as fences,  vegetative
     screens, and earth berms.  A vegetated, earth berm will
     help to screen the site and any associated buildings or
     lab facilities.

4.10 RECREATIONAL USE

     (No mitigating measures required.)

4.11 TRAFFIC

     The rehabilitation of downtown Nantucket sewers will take
     place on North Beach, South Beach,  South Water and
     Washington Streets.   Construction will be scheduled during
     the off-peak,  non-tourist season from September through
     June.  Local detours will be well-posted and  minimize the
     routing of heavy traffic flows along narrow,  residential
     side streets whenever possible.

4.12 BUSINESS

     The rehabilitation of sewers in  downtown Nantucket will be
     scheduled for  the off-peak,  non-tourist season, as noted
     above.   This will minimize disruption of downtown
     businesses during their  peak volume period.
                               48

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4.13 COSTS

     (No mitigating measures required.)

4.14 ENERGY

     Due to the excessive costs of shipping diesel generator
     fuel to the Island, the use of wind turbine generators  is
     recommended to help offset power generation costs.  This
     will entail the installation of a 10-kw wind turbine
     generator at Surfjside and a 5-kw machine at Siasconset.
     As mentioned in Section 2.1, such wind machines  are
     cost-effective and, in ^antucket's exposed and wind-swept
     location, are an ideal means of energy production.

4.15 ARCHAEOLOGICAL/HISTORIC

     The recommended projects will not have any significant
     effect on historic or archaeological resources on
     Nantucket.  Several mitigating measures,  however, are
     proposed to lessen what minor impacts could occur as a
     result of sewer rehabilitation.  Paving materials such as
     cobblestones, beach stones,  granite curbing or brick
     paving shall be replaced,  wherever  possible,  with the
     original stones in the same, original pattern.   Use of new
     material of the same type  as the original,  in the same
     patterns and textures, would be an  alternative under
     certain circumstances.

     Although the construction  of sewer  laterals is not
     included in the recommended funding package,  the Town
     should be aware of the potential for archaeological sites
     in certain areas which may have laterals  installed during
     the 20 year planning period covered by the  Facilities
     Plan.   These areas include:

         the undeveloped land west of the high school and
         elementary school;  west side of Atlantic  Ave.

         the undeveloped land east of the high school and south
         of Sparks Ave.

         the undeveloped land north of Vesper  Lane, west of the
         hospital.

         the undeveloped land north of the junction of Orange
         Street and Milestone Road,  south of  the area known as
         The Creeks.

     If laterals are constructed  in  these areas, the  following
     suggested mitigation measures  could be  taken.
                               49

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     Before the time of construction or trenching, the
     Nantucket Historical Association should be notified.  A
     person with appropriate background in the archaeology of
     Nantucket should be available to the construction crew to
     monitor excavation), in cooperation with the Nantucket
     Historical Association (NHA).

     If evidence is found indicating the presence of a site,
     construction should be temporarily halted until a
     determination is made of the significance of the material
     found.

     In the absence of an official monitor, back hoe operators
     and crew members can be made aware of their relative
     proximity to archaeologically sensitive areas.  If, during
     construction, some materials thought to be archaeological
     or historical were disturbed, the NHA should be notified
     by those people conducting the excavations.

4 .16 MINERAL RESOURCES

     (No mitigation measures required.)

4.17 SIGNIFICANT AGRICULTURAL LAND

     (No mitigation measures required.)

4.18 WILD AND SCENIC RIVERS

     (No mitigation measures required.)

4.19 CZM CONSISTENCY

     (See Sections 4.2, 4.4 and 4.9)
                               50

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Chapter 5
Comments & Responses

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CHAPTER 5  COMMENTS AND RESPONSES

5.1  INTRODUCTION

     The Draft Environmental Impact Statement for  Nantucket's
     wastewater treatment facilities was  published on November
     28, 1980.  During the period allowed for public comments,
     November 28, 1980 through January 19,  1981, EPA received
     14 written responses.  These are reproduced  in Appendix B.

     Of those written Responses,  nine had no  conflict or  no
     comment, two were opposed to alternatives that had been
     rejected in the Draft EIS but had no conflict with the
     recommended actions, and three had comments on various
     aspects of the DEIS.

     At the Public Hearing held on January  8,  1981, background
     statements on the Draft EIS  were made  by Mr.  Robert
     Mendoza, Hearing Officer, by Mr. Fred  Roland, 201
     Facilities Planning Engineer, and by Mr.  Bill Richardson,
     EIS Project Manager.  Comments and questions  on the  Draft
     EIS were raised by 5 members of the  audience. Eight
     townspeople and eight memebers of the  201/EIS team were in
     attendance.  (See Appendix A).

     It should be noted that many of the  comments  overlapped on
     similar issues.  The questions raised  at the  Public
     Hearing were answered by EPA reprsentatives at the hearing,

     In the sections that follow, EPA has prepared a response
     to the oral comments at the  Public Hearing and the written
     comments received during the review  period.   The comments
     are identified with a letter and number  keyed to their
     sources in either Appendix A or B.  Comment A-9, for
     example, is from the ninth response, or  question, listed
     in Appendix A, "Synopsis of  Public Hearing."

5.2  RESPONSE TO COMMENTS ON DRAFT EIS

  5.2.1  NANTUCKET CENTER COMMENTS

              5.2.1.1  Comment;   (A-9)

              Will tidal action affect the  cleanliness of the
              filter beds and help to keep  them clean?

              Response;

              Tidal action does not affect  the filter beds at
              Surfside or Siasconset, since the groundwater
              beneath the beds is fresh water  which is flowing
              toward the sea.   The beds are kept clean by
              periodically scraping them.
                               51

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 5.2.1.2  Comment;   (A-10)

 What if the emergency  outfall  is  sealed off and
 there is an emergency  power  failure during a
 rainstorm?

 Response;

 The likelihood  of  a  complete power outage is
 remote, but the project  is designed with dual
 force mains,  stand-by  power, improvements to
 catch basins  and reduction in  leakage, plus three
 pumps for excess flows.  If  the entire system
 fails during  an exceptionally  heavy rainstorm,
 the sewer manholes will  pop  their covers.  The
 NPDES permit  requires  that the overflow be sealed
 off.

 5.2.1.3  Comment:  (A-ll)

 Why does all  the sewer flow  get directed downtown
 instead of  diverting directly  to the beds?

 Response;

 The proposed  sewers along Old  South Road out
 toward  the  airport will  be diverted at a lift
 station  to  flow  to the filter  beds.

 5.2.1.4.  Comment;   (A-12)

 Why raise the Surfside filter  beds if they are
 working all right, now?

 Response;

 The beds should  be raised to ensure at least 4
 feet  of free drainage before hitting
 groundwater.  This will  improve the filtration of
 wastewater and conform to state regulations.

 5.2.1.5   Comment;   (B-8.17)

 How much woodchip bulking material is needed for
 composting?  Is  it available?  How much does it
 cost?  What are  the impacts?

 Repsonse;

Approximately 1700  cubic yards  of woodchips  would
 be used per year and it would be available free
 through the Nantucket DPW.  The compost pad  will
 be screened from view by an earth berm and
 drainage will be collected  for  return to the
 treatment plant.
                 52

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            5.2.1.6  Comment  (B-8.22)

            The access road within the  site will  be  paved,
            not Sewer Bed Road.

            Responses

            The Final EIS text has been modified  to  clarify
            this point.
5.2.2  SIASCONSET ARljlA COMMENTS:
            5.2.2.1  Comment;   (A-5)

            Will the Cod Fish  Park  area be  sewered?

            Response;

            Phase two of the 201  Plan proposes  to  sewer  this
            beachfront cottage area.   The provision  of sewers
            to the area should be consistent  with  coastal
            wetland regulations,  CZM  policies,  EPA policies
            and coastal flood  hazard  potential.

            5.2.2.2  Comment;   (B-8.27)

            Increasing the size of  the sewer  system  in
            Siasconset will have  an effect  on growth there.

            Response;

            The pressure for growth in Siasconset  is not
            great;  new houses  are built much  less  frequently
            there than elsewhere  on the Island.  Most new
            homes are on lots  of  one  half acre  or  more,  even
            in areas zoned for 5,000  sq.  ft.  lots.   Sewer
            laterals have been extended infrequently to
            service new growth due  to the lack  of  demand for
            connections.  The  increased size  of  the
            Siasconset filter  beds  will enable  new growth  to
            be serviced on an  as-needed basis,  but will  not,
            in and of itself,  generate new  growth  there.   If
            anything, the costs to  tie into the  sewer will
            have a somewhat negative  effect in  Siasconset.
5.2.3  MADAKET AREA COMMENTS
            5.2.3.1  Comment;   (A-l)  (A-2)

            What is the  amount  of  nitrates  found  in Madaket
            water and is there  any danger to anyone?  Was any
            salt found?
                             53

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            Response;

            There was no general problem with nitrates found
            in Madaket's water.  Four houses had levels above
            the safe limit of 10 mg./l.  Nitrates affect only
            very young infants who are less than three months
            old.  Older children and adults are not affected
            (see Section 2.3).  No traces of specific
            conductance, an indicator of salt, were found in
            the Madaket wells.

            5.2.3.2  Comment;  (B-8.10)

            Which alternative has the Town selected and will
            EPA require the Town to do anything in Madaket?

            Reponse;

            The Town has selected the non-structural
            management action, consistent with EPA
            recommendations.  This Final EIS recommends the
            Town undertake such a program and lists the
            elements to be included in Section 2.3.

            5.2.3.3.  Comment;  (B-8.28)

            Adding public water service to Madaket (pg. 4-29,
            DEIS)  could increase groundwater levels through
            on-site recharge.

            Response;

            This statement is theoretically true.   However,
            in Madaket's sandy and rapidly-permeable soils,
            water  percolates so quickly and the aquifer is so
            large, relative to on-site wastewater  volumes,
            that it would take a massive influx of outside
            water  to raise the groundwater level.

5.2.4  COMMENTS ON ALTERNATIVE ACTIONS

            5.2.4.1  Comment;   (B-5)  (B-14)

            The FAA and Nantucket Airport Commission oppose
            Site #5 as  an alternate site  for the filter beds.

            Reponse;

            The Draft EIS,  later  in the discussion of
            alternate sites for the filter beds, rejects  Site
            #5 and all  other alternates in favor of continued
            use of the  existing filter beds  (see Draft  EIS
            Section 2.2.3,  page 2-9).
                             54

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            5.2.4.2  Comment;  (B-8.5)

            The EIS must evaluate the alernative of secondary
            treatment with discharge to the ocean,  at least
            on a preliminary cost basis.

            Reponse;

            Ocean outfall of secondary  effluent has been
            considered and rejected on  the basis of high
            costs (spe Secion 3.10).

            5.2.4.3  Comment;  (B-8.8)

            Table 8 in the DEIS should  have an index which
            explains the headings.

            Response;

            An interpretation of Table  8 has been prepared
            and is on file at EPA (see  also Appendix C).

5.2.5  COMMENTS ON TREATMENT LEVELS

            5.2.5.1  Comment;  (A-7)  (A-8)

            How many tons of sludge per year will be
            generated at the Surfside filter beds?   Can  it  be
            used on Nantucket?

            Response;

            About 100 tons of dried material,  a type of  dried
            sludge,  will produced each  year.  The Town DPW
            could easily use that much  a year,  plus local
            farmers  or gardeners.

            5.2.5.2   Comment;  (A-8)  (B-8.9,  8.16,)

            What are the advantages of  primary treatment
            prior to applying wastewater to the filter beds?

            Response;

            The text in Section  1.2.2 of this  Final EIS has
            been expanded to provide a  complete discussion of
            the advantages of primary pretreatment  prior to
            land disposal.
                             55

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 5.2.5.3  Comment;   (B-8.4)

 Primary treatment removes 30% to 40% of suspended
 solids and little or no dissolved solids.

 Response;

 This statement is correct.  Page 1-19 of the
 Draft EIS should be reworded accordingly.

 5.2.5.4  Comment;   (B-8.14)

 Is the total flow on Table 12 of the Draft EIS in
 mgd or gpd?

 Response;

 Mgd.

 5.2.5.5.  Comment;  (B-8.24) (A-3)

 The EIS should assess whether or not disinfection
 is needed as part of the treatment process.

 Response;

A new section has been added in the Final EIS
 dealing specifically with the disinfection issue
 (See Section 1.2.3).
                                               t

 5.2.5.6  Comment;   (B-8.15)

 Section 2.7.3 of the Draft EIS is difficult to
 understand.  Aren't EIS's supposed to be easy to
 read?

Response;

Yes they are supposed to be easy to read.  But a
cost-effective analysis, required by EPA
 regulations,  is not an easy subject that is
 readily grasped by the lay reader.  The analysis
 is technical and complicated.   A technical
appendix was developed as back-up in order to
keep 2.7.3 as simple as possible.  Reducing the
section further would result in an incomplete
cost-effective analysis on the level of
 treatment, which was a basic issue in the DEIS.
                 56

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5.2.6  BUFFER ZONE COMMENT
            5.2.6.1  Comment;   (B-18)  (B-19)

            The EIS (Should recommend what the  minimum buffer
            zone should be for Surfside and Siasconset.  What
            is the lateral extent of the plume as  Siasconset?1

            Response;

            A new section has  been added to this Final EIS
            which consolidates all discussion  of the  buffer
            zones, effluent plumes and  Case III designation
            procedures (see Section 1.2.4). The lateral
            extent of the 20 acre plume at Siasconset is 250
            feet inland and 200 feet to each, side  of  the
            filter beds.
5.2.7  ENVIRONMENTAL IMPACTS
            5.2.7.1  Comment;   (B-6)  (B-8.20)

            The EIS should also  discuss  impacts on mineral
            resources,  significant  agricultural lands,
            endangered  species,  wild  and scenic rivers and
            CZM consistency.   Impacts on surface water
            quality should be  discussed  under  the water
            quality section.

            Response;

            New impact  categories were added to this Final
            EIS, as suggested.   It  sould be pointed out,
            however,  that this EIS  went  through an early and
            thorough scoping process  with all  federal, state
            and local agencies,  plus  public input.  The
            original 15 impact categories in the DEIS
            reflected the results of  that process.  These
            additional  categories,  many  of which are purely
            administrative in  value,  were not  included
            originally  due to  their irrelevance to the
            Nantucket EIS process.  They have  been added to
            satisfy administrative  purposes.   Surface water
            impacts are a justifiable concern  and have been
            adde"d to  the discussion of water quality impacts,
            as  appropriate.
                             57

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5.2.7.2  Comment;   (B-8.3)

The EIS should discuss the impacts of the sewer
rehabilitation work in Nantucket, as well as the
sewer service extensions in Nantucket Center and
Siasconset.

Response;

The Final EIS includes a more specific discussion
of the rehabilitation and sewer extension impacts
in Sectipn 3.3.  These generally fall under the
categories of Land Use/Induced Growth, Traffic,
Business and Archaeological/Historic.

5.2.7.3  Comment;   (B-8.25)

The Draft EIS impact evaluation section
frequently referred back from a proposed action
alternative to a no action alternative,
indicating that each had the same impacts.  This
is not always true since the proposed alternate
freuently involved construction and the no action
does not.

Response;

This statement is correct.  However, in those
instances where references are made back from one
alternative's impacts to another's, the type of
environmental impact in a specific category was
often similar, if not the same.  Additional
language added to the description of impacts,
rather than a simple reference, would have been
more complete.  This editorial technique,
however, did not affect the substance of the
evaluation process or alter the outcome of the
findings.

5.2.7.4  Comment;  (B-8.26)

EPA's policies on not funding projects which
promote growth in critical environmental areas
should be mentioned.

Response;

The text in Chapters 3 and 4  of this Final EIS
has been altered to include this reference in the
sections on coastal flood hazard zones, wetlands
and CZM consistency.
                 58

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            5.2.7.5  Comment;   (B-6)

            The EIS (Should discuss  the archaeological
            significancer  impacts and mitigation  measures  for
            all alternatives.   The  EIS should  undertake
            further studies in undisturbed  areas  and  in  areas
            near knoyn archaeological sites and the results
            addressed in the Final  EIS.   The comments  of the
            State Historic Preservation  Officers  (SHPO)
            should be included in the Final EIS.

            Response?

            A thorough archaeological and historic review  was
            made of all known  sites on Nantucket  Island.
            This was conducted jointly with Mass. Historical
            Commission (MHC) and the Nantucket Historical
            Association (NHA).  The results of that review
            are summarized in  Appendix B of the Draft  EIS.
            MHC policy prevents full discussion of all
            sites.  The SHPO has reviewed the  Draft EIS  and
            the new, proposed  sewer projects and  the response
            letter is in Appendix B of this Final EIS.
            Mitigating measures are proposed in Section  4.15
            of this Final  EIS  for the recommended actions.

5.2.8  MITIGATION MEASURES

            5.2.8.1  Comment;   (B-8.18)

            A more complete mitgation section  should have
            been developed.

            Response;

            A new, expanded section on Mitigation Measures
            has been added to  this  Final EIS (see Chapter  4).

5.2.9  COSTS

            5.2.9.1  Comment;   (A-4)

            How are sewer  user fees arrrived at?

            Response;

            One way to establish a  user  fee is to establish
            an equivalent  residential unit.  As an example,
            an average home contributes  "x"  gallons of
            sewerage a month and a  restaurant  or hotel
            contributes 5"x" or 10"x"  gallons  per month.   A
            fee can be established  equivalent  to that  amount
                             59

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and the user would pay in proportion to that
schedule,  A typical house might pay $10 a month
and a restaraunt $60 a month depending on the
amount of sewage it contributed.  A number of
options are also available.

5.2.9.2  Comment;  (A-6)

Could a cost credit be assigned to the beneficial
uses of sludge and wastewater?

Response^

The 201 Planning Engineer reviewed the benefits
of using recycled sludge as compost fertilizer
and of using wastewater for spray irrigation of
crops.  Beneficial values can be assigned to each
use, but it was found to be difficult to quantify
in terms of a dollar value or a cost credit.  in
practice, the dried sludge will be given away by
the DPW to whomever wishes to use it as a
fertilizer.

5.2.9.3  Comment;  (B-8.23)

Do the cost figures given on page 4-6 and 4-17 of
the Draft EIS include debt service plus O&M?

Response;

No.  These costs only reflected the capital cost
per house to service an area.  Actual user
charges are given for the recommended actions in
Section 2.4.
                 60

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Appendices

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