-------
'^/T'  :,,!'::,     i :   >!..:.''.   ,       :  niHiiH'Ji n liJiii 1,111    ..,.' tt

-------
       '
              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                REGION I

               J. F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203
To:  All Interested Agencies, Public Groups,  and  Citizens
Enclosed is a copy of the Final Environmental  Impact  Statement
(FEIS) on the Siting of: Wastewater Treatment Facilities  for Boston
Harbor.

In accordance with the requirements of the National Environmental
Policy Act of 1969, there will be a thirty (30)  day comment period
which will end on January 21, 1986.  Any  comments  or  inquiries
concerning the FEIS should be submitted to the  above  address.   The
Massachusetts Water Resources Authority (MWRA)  has prepared a
separate Final Environmental impact Report on  the  Siting of Wastewater
Treatment Facilities for Boston Harbor.   Any questions on the  MWRA
document should be addressed to Elisa Speranza,  Public Affairs
Coordinator, One Central Plaza, Boston, MA 02108  (742-7600).

EPA and the MWRA will sponsor a public information meeting on
January 8, 1986 at the Department of Transportation Building at
Kendall Square in Cambridge at 7:30 p.m.  EPA  and  the MWRA will
sponsor three public hearings on the FEIS and  FEIR on January  13,
14/ and 15, 1986.  The location and time  for each  public hearing  is
listed below:

January 13, 1986 - 7:30 p.m.
North Quincy High School Auditorium
316 Hancock Street
Quincy, MA.

January 14, 1986 - 7:00 p.m.
Faneuil Hall
Faneuil Hall Market Place
Boston, MA.

January 15, 1986 - 7:30 p.m.
Winthrop jr. High School Auditorium
45 Pauline Street
Winthrop, MA.

We encourage your participation.  EPA will receive comments on
the FEIS until January 21, 1986.  All comments  should be addressed
to Michael R. Deland, Regional Administrator,  EPA  Room 2100B.

Sincerely yours,
Michael R. Deland
Regional Administrator

-------
                  VOLUME I

   COMPREHENSIVE SUMMARY

   Final Environmental Impact Statement

                 SITING
                     of
           WASTEWATER
  TREATMENT  FACILITIES
                     for
         BOSTON  HARBOR

                  Prepared by
                 UNITED STATES
         ENVIRONMENTAL PROTECTION AGENCY
                   REGION I
               Technical Assistance by;
             THIBAULT/ BUBLY ASSOCIATES
             PROVIDENCE. RHODE ISLAND
     MICHAEL R. DELAND               Date
     Regions] Administrator, U.S. EPA, Region I
This Final Environmental Impact Statement has been prepared
by the U.S. Environmental Protection Agency (EPA) with
assistance from the General Services Administration as a
Cooperating Agency under the requirements of the National
Environmental Policy Act. The FEIS identifies and evaluates
the environmental impacts of various site options for waste-
water treatment facilities for treating Greater Boston's
wastewater in compliance with federal and state water
pollution control laws.

-------
                       FINAL ENVIRONMENTAL IMPACT STATEMENT
 PROPOSED  ACTION:
SITING OF WASTEWATER TREATMENT  FACILITIES  IN
BOSTON HARBOR
 LOCATION:
                             BOSTON,  MASSACHUSETTS
 DATE:
DECEMBER 1985
 SUMMARY OF  ACTION:
This FEIS considers the environmental accepta-
bility of alternative locations for  the  construc-
tion of new wastewater treatment facilities  for
Boston Harbor.  The FEIS recommends  the  construc-
tion of a secondary wastewater treatment facility
at Deer Island.
VOLUMES:
  I.  COMPREHENSIVE SUMMARY
 II.  TECHNICAL EVALUATIONS
III.  PUBLIC PARTICIPATION AND RESPONSE TO COMMENTS
 IV.  PUBLIC AND INTERAGENCY COMMENTS
 LEAD AGENCY:
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION I
JFK Federal Building, Boston, Massachusetts  02203
COOPERATING AGENCY:
GENERAL SERVICES ADMINISTRATION
TECHNICAL CONSULTANT:
THIBAULT/BUBLY ASSOCIATES
Providence, Rhode Island
FOR FURTHER INFORMATION:
Mr. Ronald Manfredonia
Water Management Division
U.S. EPA, Region I
JFK Federal Building
Boston, MA  02203
617-223-5610
FINAL DATE BY WHICH
COMMENTS MUST BE RECEIVED:

-------
                               TABLE OF CONTENTS

Volume 1

Introduction

  I.  The Existing Problem and the  "No Action" Alternative

      A.   Description

      B.   Environmental Impacts of the "No Action" Alternative

 II.  Secondary Treatment Alternatives

      A.   Description of Secondary Treatment

      B.   Generic Environmental Impacts of Secondary Treatment

III.  Results of Further Analysis of Impacts of Siting Alternatives

      A.   All Secondary Deer Island

           a.  Construction Traffic

           b.  Operation and Maintenance Traffic

           c.  Noise

           d.  Odor

           e.  Volatile Organic Compounds

           f.  Pathogenic Aerosols

           g.  Risk of Chlorine Spills

           h.  Archaeological and Historical Resources

           i.  The Benefits of Moving the Prison

      B.   Split Secondary Deer Island and Nut Island

      C.   All Secondary Long Island

           a.  Value of Long Island and Deer Island as a Park Resource

           b.  Impacts of Construction on the Appearance, Recreational Use and
               Archaeological Resources of the Islands

-------
           c.   Cost Estimates

           d.   Legal and Institutional Analysis

           e.   Over the Road Access to Long Island

           f.   Barge Terminal Feasibility

           g.   Relocation of Impacts

      D.   Split Secondary Deer Island and Long Island

 IV.  Decision Process

      A.   Decision Criteria

      B.   After close of Public Comment Period

      C.   Mandatory Mitigation Measures

      D.   Final Analysis

V.    Major Site Relevant Criteria

      A.   "Effects on Neighbors"

      B.   "Harbor Vision"

      C.   "Implementability"

VI.   The Decision

VII.  Completion of EIS Process

VIII. Appendices

      Appendix A  Headworks
      Appendix B  Primary Treatment Alternatives
      Appendix C  Principal Relevant Impacts for Each Decision
                  Criterion
      Appendix D  Additional Environmental Review Relating
                  Boston Harbor Clean-up.

      Impact Matrices

-------
                      Volume 1

                    BOSTON HARBOR
            FEIS - COMPREHENSIVE SUMMARY

INTRODUCTION

This document, Comprehensive Summary — Final
Environmental Impact Statement on the Siting of
Wastewater Treatment Facilities for Boston Harbor,
is one of four volumes prepared in response to
comments raised on the Supplemental Draft
Environmental Impact Statement/Environmental Impact
Report (SDEIS) published  jointly by the United
States Environmental Protection Agency (EPA) and the
Metropolitan District Commission (MDC) on December
31, 1984 to replace an earlier Draft EIS published
in 1978.  The treatment facilities will be
constructed by the applicant, the Massachusetts
Water Resources Authority  (MWRA), a successor agency
to the MDC.

The MWRA has the responsibility of selecting the
site for the wastewater treatment facilities.  The
EPA has the responsibility of conducting an
independent evaluation of  the site's environmental
acceptability, providing  federal financial
assistance if available,  and ensuring rapid
compliance with the federal Clean Water Act.

The General Services Administration (GSA) has
participated with EPA in  the preparation of this
Final Environmental Impact Statement (FEIS) as a
cooperating agency and has performed an independent
analysis of the environmental impacts of the
disposal of federally owned parcels on Deer Island.

This Comprehensive Summary includes a recapitulation
of the need for the project, the principal siting
alternatives, their impacts and the possible actions
that might be taken to mitigate those impacts.  It
outlines the key location-affecting issues that have
developed during the planning process; it summarizes
the United States Environmental Protection Agency's
evaluation of the alternatives; it identifies the
Agency's preferred alternative; and it lists
mandatory mitigation activities.

-------
 In  summary, this FEIS recommends All Secondary Deer
 Island as  the EPA's preferred alternative.  EPA has
 also  determined that All Secondary Long and Split
 Secondary  Deer/Long are environmentally acceptable.
 Split Secondary Deer/Nut is unacceptable.

 Volume II  of this  series, Technical Evaluations,
 includes the environmental impact analysis prepared
 by  GSA, and a number of technical reports and
 memoranda  prepared by EPA in response to comments on
 the SDEIS.  This SDEIS consisted of several
 volumes:   an Executive Summary; the SDEIS itself; a
 volume of  appendices on water quality impacts, land
 use and demographics, traffic, recreational
 resources  and visual quality, costs, financial
 impacts, noise, odor, geology, historical and
 archeological resources, and legal and institutional
 constraints; a volume entitled Evaluation of
 Satellite  Advanced Wastewater Treatment Facilities;
 a volume entitled  Boston Harbor Water Quality
 Baseline;  and a volume entitled Boston Harbor SDEIS
 Report of  Final Screening Results.

 Volume III of this FEIS, Public Participation and
 Response to Comments, describes the interagency and
 public participation review processes, summarizes
 comments received  on the SDEIS, and gives the
 Agency's responses to those comments.

 Volume IV  of this  FEIS, Public and Interagency
 Comments,  includes the comments received on the
 SDEIS.

 This  FEIS  was prepared consequent to a location
 study for  the proposed facility, the Nut Island
 Wastewater Treatment Plant Facilities Planning
 Project Phase I, Site Options Study (published by
 the MDC).  In accordance with an agreement between
 EPA and the MDC dated April 18, 1978 on the phasing
 of facilities planning for the Metropolitan Sewer
 District,  this FEIS addresses the question of the
 location and construction of the proposed facility
 and appropriate mitigation actions.  Detailed
 facilities planning will be included in the next
 planning phase.

 In evaluating the  effects of the facility at the
various alternative locations considered in this
FEIS, the need for mitigating actions to avoid or
reduce adverse impacts were identified and
described.  These  mitigating actions, where

-------
considered essential by EPA, will be required of the
MWRA as a condition of any federal grant to the
applicant for construction of the proposed
facilities.

Finally the MWRA has prepared and published a
concurrent but separate Final Environmental Impact
Report (FEIR), as required by state law.  Copies of
the FEIR are available at the offices of the
Massachusetts Water Resources Authority, One Center
Plaza, Boston, Massachusetts 02108.

During the preparation of the FEIS and FEIR, EPA and
MWRA collaborated and shared technical information
so that their decisions would be based upon a common
data base.

-------
I.  THE EXISTING PROBLEM AND THE "NO ACTION*
ALTERNATIVE

Boston Harbor, one of New England's most valuable
economic and recreational resources, is being
seriously polluted in violation of federal law.  Its
waters are murky, streaked with floating wastes, and
contaminated with domestic and industrial
pollutants.  A major source of this pollution is the
discharge into the harbor of inadequately treated
wastewater from  43 cities and towns lying both along
the shores of the harbor and up to 30 miles inland,
including communities well outside of the natural
watershed of the harbor.

The flow of wastewater from the Deer and Nut Island
treatment plants exceeds in volume the average flow
of the Harbor's  three principal rivers, the Charles,
the Mystic, and  the Neponset.  Serious violations of
the Clean Water  Act are caused by the continued
discharge of this  inadequately treated waste
generated by residents, visitors and commuters
representing almost half of the state's population.
                                   MWRA SEWER DISTRICT

-------
As Judge A. David Mazzone of the United States
District Court, District of Massachusetts observed
in his September 5, 1985 decision which found these
discharges  to be illegal:

     "Boston Harbor  is a powerful ecological system
     which  is capable of reconstituting itself as
     long as the system is not overloaded ... The
     system  is being continuously overloaded and, as
     a result, each  day the Harbor becomes more
     polluted [as a  result of] ... chronic, flagrant
     violations of the federal law.  That law secures
     to the  people the right to a clean harbor.  No
     argument ... disputes the fact that massive
     quantities of pollutants are discharged every
     day into the Harbor."
A.  Description

Consideration of  "No Action" is mandated to EPA by
federal regulations adopted pursuant to the National
Environmental Policy Act of 1969, and, in some
cases, it  is the  most appropriate alternative.  In
this case,  "No Action" would consist of continuation
of the operation  of the existing undersized primary
treatment plants  at Deer and Nut Islands, in the
form to which they are being upgraded by an ongoing
improvement program known as "Immediate Upgrade" or
"Fast Track."  Although these improvements are
necessary  to prevent further deterioration of the
existing plants and their adjacent environments,
they will not bring the plants or their effluent
into conformance  with state or federal law.

At Deer Island, the improvement program consists of
repairs, replacement and upgrading of the main
treatment plant's power distribution system, pump
station, power supply, non-potable water system,
disinfection system, and primary sedimentation
system.  While construction of new scum and
skimmings disposal facilities has been recommended,
planning of these facilities is still being
conducted.  Construction of the rest of the proposed
work is scheduled for 1986-1989.  These improvements
are intended to enhance the safety of plant
operators and neighbors, reduce odors, reduce
operation and maintenance costs and improve the
level of treatment at the plant until long-term
plans can be implemented.

-------
At Nut Island, the program underway  includes
improvements to the power and air production system,
electrical system, treatment processes, odor control
system, preaeration and sedimentation tanks, and
outfalls.  The goal of this work is  to alleviate
bypasses and overflows, odor emissions, worker
safety concerns, and  the general unreliability of
the plant.

Figure 1-2 shows the  location of the existing
principal wastewater  disposal facilities  in Boston
Harbor.

The  treatment  process,  as  designed  a generation  ago,
provides  only  for  sedimentation, which  removes only
a small portion  of the  total  suspended  solids, and
for  disinfection  of the  clarified effluent.  The
plants  discharge  three-quarters of  this effluent to
President Roads,  off  Deer  Island, and one-quarter to
Nantasket Roads,  off  Nut  Island.  The wastes which
are  removed  by this  sedimentation process (known as
sludge) are  then  decomposed or  "digested," both  to
recover methane  for use within  the  plant  and to
reduce  the mass  of the  solids.  This sludge is also
        MWRA WASTEWATER DISPOSAL FACILITIES

-------
discharged on the ebb tide to President Roads, via
the effluent outfalls from Deer Island and via a
special sludge pipeline from Nut Island.

In addition, raw sewage discharges which are caused
by breakdowns at the main pumping station at Deer
Island are made by way of a 19th century sewage
pumping station and outfall system to Moon Island,
while other raw overflows occur at Deer and Nut
Islands.

Figure 1-3 shows the setting at Deer Island
including the existing treatment plant, the
immediately adjoining prison (Suffolk County House
of Correction), the Point Shirley neighborhood to
the north in Winthrop, the existing outfall system,
and the center lines and noise contours of Logan
Airport.  The treatment plant uses only about 26
acr es.

-------
   Most of  the land on the  island is underutilized
   except for the prison and  the treatment plant.   Fort
   Dawes at the southern end,  no longer in use,  is in
   the process of being disposed of by the federal
   government in the near future.  Access to  the island
   is controlled closely by the prison and no
   recreational use is permitted.  Figure 1-4  shows the
   present  pattern of land  ownership.
                                • her* Lin*
    SCALE IN FEET

SOURCE:  MCD Deer Island
      Fast-Track Facilities
      Plan, Havens & Emerson/
      Parsons Brinkerhoff/
      August, 1984.
OWNERSHIP OF LAND
                            ON DEER ISLAND-
PROPERTV LINES

EASEMENTS
MEAN LOW WATER
PARCELS B&C,MDC LEASED FROM NAVY
MDC
CITY OF BOSTON
QSA (U.S. NAVY)              I

-------
Figure 1-5 shows the setting at Nut Island including
the existing treatment plant, adjoining residential
areas, and the existing outfall system.  The
treatment plant owns 17 acres of available land with
minimal buffer space between the plant and the
adjoining residential area.   No recreational access
to the water is permitted.

-------
 B.  Environmental Impacts of the "No Action*
 Alternative

 Even upon completion of the "Fast Track-
 improvements previously discussed,  major problems
 would continue.  These represent the environmental
 impacts of the "No Action" alternative and include:
 a.   Continued  reliance  on undersized, overloaded
     treatment  plants  that discharge or bypass a
     daily  average  flow  of 450 million gallons of
     turbid wastewater,-  contaminated with bacteria
     and  putrescible materials far in excess of the
     limits established  by law.

 b.   Continued  daily discharge to Boston Harbor of 70
     dry  tons  (or 600,000 gallons) of digested
     sludge,  in violation of federal law.

 c.   Continued  discharge in the wastewater of plastic
     tampon inserters  and condoms.  These products
     are  found  throughout the harbor, have become as
     much a part of the  shoreside environment as
     seashells,  and are  often picked up as playthings
     by small children.

 d.   Continued  emissions of odors.  Full odor control
     is not part of the  "Fast Track" upgrading
     program.

 e.   Continued  exposure  of residents in the
     neighborhoods  around, and on the access routes
     to,  Deer and Nut  Islands to the risk of
     accidental  spills of liquid chlorine.

 f.   Continued barring of public access to the harbor
     at two potentially  recreationally valuable
     locations,  i.e. Deer Island and Nut Island.
     Both the existing wastewater treatment facility
     sites  offer good vantage points for viewing the
     panoramas of Boston Harbor, for watching the
     varied and  intensive boating traffic into and
     out of Boston  Harbor, and for shoreline fishing.

EPA  has concluded  that  the "no action" alternative,
even with  the upgrade,  was an unacceptable long-term
solution.
10

-------
II.  SECONDARY TREATMENT ALTERNATIVES

Abatement of this pollution will require a complex
set of actions, including, at its heart, the
construction of secondary wastewater treatment
facilities as required by federal law.  Evaluating
the environmental acceptability of a site for these
facilities is the subject of this Final
Environmental Impact Statement (FEIS).

There are four remaining alternatives for the siting
of secondary wastewater treatment facilities for
Boston Harbor that are described in this FEIS, and a
variation of one of those four.  These are the
following:

1.  All Secondary Deer Island — Consolidation of
    all major facilities on Deer Island.

2.  Split Secondary Deer Island and Nut Island —
    major facilities split between Deer and Nut
    Islands.

3.  All Secondary Long Island — Consolidation of
    all major facilities on Long Island.

4.  Split Secondary Deer Island and Long Island —
    major facilities split between Deer and Long
    Islands.

An important variation is similar in many respects
to All Secondary Deer Island, but includes the
mitigating action of removing the prison from Deer
Island.

Other alternatives, included in studies that have
led to this FEIS and that have been eliminated from
consideration, and the reasons for their
elimination, are described in the SDEIS.

(It is also possible that a primary treatment plant
requiring less than half as much land might be built
instead of the anticipated secondary treatment
plant, if EPA's finding that primary treatment is
inadequate, is successfully challenged.  The
alternative locations for primary treatment are
included in Appendix B of this volume.)

All the sites in the final set of alternatives were
selected after consideration of a large number of
factors as stipulated in the SDEIS (social,
                                                              11

-------
 technical, environmental, economic, political, legal
 and institutional), including the location of the
 existing major wastewater conveyances and of waters
 that are adequate in volume to receive the very
 large flows of treated effluent without violation of
 water quality standards.  Figure II-l shows the
 location of the major wastewater conveyances and the
 deeper waters off Boston.

 The identification of a suitable site for the
 treatment facilities is controversial because of the
 large land area that an adequate treatment plant
 requires, a scarcity of underdeveloped land near the
 harbor, intense competition for open land, and high
 population densities relatively close to all of the
 large underdeveloped land areas in the region.  As
 the plant will be sized to process a peak flow of
 about 1.2 billion gallons, or 5 million tons, per
 day, location very remote from the existing
 trunklines is not practical.
           MWRA WASTEWATER CONVEYANCE SYSTEM
12

-------
A.  Description of Secondary Treatment

Any secondary treatment facility that might be
constructed for Boston Harbor will have to be
designed to remove wastes from wastewater to the
standards set by law.  For a treatment plant of this
size, there are a limited number of processes that
could be used for this purpose.

The process assumed in this EIS on facilities
location is "activated sludge," the most widely used
process for large treatment plants and the one
assumed in the MDC's Nut Island Wastewater Treatment
Plant Facilities Planning Project, Phase I, Site
Options Study and in the MWRA's PEIR.  It relies
upon simple sedimentation to remove solids both near
the beginning, and near the end, of the process with
an aeration step, the "activated sludge" process,
between them.  The "activated sludge" process
biologically oxidizes part of the dissolved and
suspended organic compounds in the wastewater to
carbon dioxide and water and absorbs most of the
rest into the sludge biomass for subsequent removal
by sedimentation.
              SECONDARY ACTIVATED SLUDGE TREATMENT PROCESS
                                                              disinfection
                                                                 •
      tt-Z
                                                                       13

-------
Although some other process or design modification
might ultimately be selected, it is the construction
and operational effects of "Activated Sludge"
facilities that were used as the basis for
assessment of the  impacts of secondary treatment at
the various alternative sites in this FEIS.

In this case this  is a reasonable and conservative
assumption.  For all principal impacts in this case,
the severity of any impact is a function of the size
of the treatment facility, which in turn determines
not only its proximity to its neighbors but its
conflicts with other land uses.  Of all the
treatment technologies that could be reasonably
applied to a plant of this size, activated sludge is
the most land intensive and thus will be closest to
its neighbors and  have the greatest potential
conflict with other land uses.

The solids removed from the wastewater must be
disposed of in some manner, with or without several
possible intermediate processes.  These solids may
be as high as 415  dry tons per day (2000 tons per
day of sludge cake at 20% solids).  This amount, in
contrast to the quantity of effluent, is so much
smaller, that it is reasonable to consider its
removal from the wastewater treatment plant site by,
for example, small diameter pipeline or vessel for
disposal anywhere  within a broad region.

Digestion is one intermediate process commonly
employed to recover energy resources in the sludge
and to reduce its  polluting potential.  For the
reasons discussed  above concerning plant size, and
because digestion  is a land-intensive intermediate
process, the land  area requirements, cost and other
impacts in this FEIS are based on the assumption
that sludge would  be digested and dewatered on the
site.  Whether sludge digestion will in fact be part
of the final pollution control strategy will depend
on the choice of an ultimate sludge disposal method
or methods.

The MWRA has made  no decision as to how secondary
sludge will be disposed of except that on July 10,
1985 the MWRA voted that it preferred that sludge
disposal not occur at the wastewater treatment plant
island.  The ultimate sludge disposal alternatives
that appear possible in this case are landfilling,
composting/land application, and incineration.
14

-------
This document does not analyze the impacts of
ultimate sludge disposal because this siting
decision does not influence any future decision on
whether or where to landfill, to compost and apply
to land, or to incinerate.  Landfilling and compost
disposal can and must be done offsite, because
neither Deer Island nor Long Island is large enough
for a landfill or compost disposal area sufficient
to handle the quantities of sludge which are
expected to be generated by the plant.  Compost
processing also can and must be done offsite,
because the size of the plant and volume of material
to be composted eliminate both Deer Island and Long
island as locations for composting, except that
partial composting would be possible at either
site.  An incinerator large enough to handle the
MRWA wastes could be constructed offsite, or at
either Deer Island or Long Island, without violating
national ambient air quality standards or Federal
Aviation Administration regulations on Logan flight
paths.  Thus, selection of a treatment plant site
does not foreclose any of the available sludge
disposal alternatives.  Neither does it make the
selection of any alternative more likely because of
the similar constraints on all three options which
would be present at either island.

Conversely, even if the choice of landfilling,
composting/land application or incineration as the
sludge disposal method were made simultaneously with
the plant siting decision, any sludge decision would
neither foreclose nor encourage any treatment plant
site.  Landfilling and compost application is
impossible at both islands; composting is impossible
at both except as a partial solution, and
incineration is possible at either.  Any sludge
option is possible off-site.  Thus any sludge choice
made would not influence the site of the treatment
plant.  Because of high acreage requirements,
construction complexity, and enormously greater
flows, treatment plant siting takes precedence.

It is important to note that the construction of a
secondary treatment plant is mandated by the Clean
Water Act as a distinct phase of a process which
includes production of secondary sludge.  It is
appropriate to make a siting decision for the
treatment plant separately from a sludge disposal
decision because delaying this siting decision until
after study and selection of a sludge disposal
option would unreasonably delay the planning and
                                                             15

-------
construction of a secondary treatment facility,
resulting in additional environmental harm.

MWRA has begun a study which will lead to the
selection of a sludge disposal method and to an
EIR.  EPA intends to prepare an Environmental Impact
Statement.  The specific impacts of sludge
management  alternatives typically include
construction and operational traffic, odor, noise
and air or  water emissions; the cumulative impacts
of a 500 mgd treatment plant will be considered.

B.  Generic Environmental Impacts of a Secondary
Treatment Plant

The facilities necessary for the activated sludge
wastewater  treatment process generate some
environmental impact, both during construction of
the plant and during its operation.

During operation, all the alternatives would
discharge their treated effluents through a common
outfall diffuser to be constructed further out in
the harbor  at a site to be determined during the
facilities  plan.  Consequently, all would have
identical effects on water quality and marine biota.

The process requires the construction of large
concrete structures for aeration and sedimentation
tanks; some aerosols and volatile compounds are
emitted from the surfaces of the tanks and flow
channels.

The large size of a 500 million gallon per day
"activated  sludge* treatment facility would require
a large land area (about 115-140 acres), a
construction period of about eight years, the
employment  of 650 (average) to 1300 (one year peak)
workers and the movement of large volumes of
construction materials and construction wastes (over
one million tons) onto, around, or off the site.
The environmental effects of such extensive
construction would include the commitment of a large
area of waterfront land to wastewater treatment,
theoretically denying its use for future recreation;
and, without mitigating actions, the emission of
noise and dust from construction equipment and from
many hundreds of trips per day of trucks and
construction workers' autos.
16

-------
In addition, during operation the plant would
require a large staff and a steady supply of
materials and it would require periodic heavy
maintenance.  Without mitigating actions, the plant
has the potential to emit significant odors.

With a treatment facility the size of that proposed
for Boston Harbor, these effects could become
significant problems.

To reduce these impacts, a set of mitigating actions
was proposed in the SDEIS.  These mitigating actions
included barging of bulk materials to and from the
site(s) to reduce the amount of trucking, busing of
construction workers to reduce commuter traffic, and
control of noise and odor.  Continuing review of the
potential impacts of secondary treatment of the
specific sites under consideration has demonstrated
that more stringent mitigating actions will be
required by EPA of the applicant as a condition of
federal financial assistance to the project.

III.  RESULTS OF FURTHER ANALYSIS OF IMPACTS OF
SITING ALTERNATIVES.
The specific final secondary alternatives that were
described in the SDEIS, their impacts as further
defined since publication of the SDEIS, and the
mitigating actions that have been considered are
described in the sections of this FEIS immediately
below.  These mitigated impacts have been summarized
in a matrix appended to this volume and are
discussed in detail in Volume II of this FEIS.  The
process used in the selection of recommended
alternatives is described in the final chapter of
this volume.

For the reader's convenience EPA has reproduced for
each alternative its description as contained in the
SDEIS.
                                                             17

-------
       SDEIS SECONDARY  TREATMENT ALTERNATIVES
A.   All Secondary Deer Island

    "This alternative would:

    1.  Expand the existing primary wastewater
       treatment facility at Deer Island to a
       secondary treatment plant.

    2.  Reduce the existing primary treatment
       facilities at Nut Island  to a small
       headworks.

    3.  Construct a major new pipeline or tunnel
       from Nut  Island to Deer Island to allow the
       consolidation of the  two  facilities.

    4.  Construct a new local outfall to the  east of
       Deer Island Light.

    •AREA:  The existing wastewater treatment
    facility on Deer Island would be increased from
    26 acres to about 115-140* acres while that on
    Nut Island would be reduced from 12 acres to
    about 2 acres.

    "COST:  The overall construction cost of  this
    alternative would be about $1135* million and
    its annual cost of operation, maintenance and
    replacement would be about $50* million.
  "IMPACT:  This alternative would commit almost
  all the land on the island south of  the prison
  to wastewater treatment and level almost all the
  topographic features  of the island.

  •At Point Shirley, it will increase  traffic and
  traffic noise during  the 7 years of  construction
  by about 21 trucks and buses each day.  However,
  at the peak periods,  6 months to a year, it
  would increase by up  to 34 trucks and buses each
  day.

  "On the island itself, this alternative will
  cause:

  1.  Permanent preclusion of public access to a
      number of potential recreational resources
      including Signal  Hill (the Deer  Island
      drumlin), with its panoramic views of the
      whole range of the harbor islands, and the
      southern end of the island,  with its
      potential access  to the water for shoreline
      fishing.  Recreational use of this land,
      though suggested  in prior plans, is not a
      current priority  for the Commonwealth/ so
      that this would only be a moderate impact.

  2.   Destruction of Signal Hill,  the visual
      landmark that defines the northeastern limit
      of  the harbor,  and that is an important
      component of the  views of the harbor from
      significant vantage points.   It  is judged to
      be  a severe impact.

  'This  alternative will have no significant
  adverse impact on Nut Island.  It will preserve
  Long Island for major recreational use, a
  priority for the Harbor Islands  state Park."
Ftof>o$e
   *Updated, See Vol  II.
  18

-------
Salient comments on the SDEIS raised questions on
the sensitivity of the adjoining areas to traffic
and noise that would be generated by this
alternative; the feasibility of their mitigation
including over-water transportation of all workers,
materials, and equipment; the emissions of odors,
volatile organic compounds, and pathogenic aerosols;
the risks of accidental spills of chlorine in and
near residential areas; the potential of
archaeological, historical and recreational
resources on Deer Island; and the benefits of moving
the Deer Island Prison.

Each of these issues was subsequently reviewed and
re-evaluated.  The key findings of these reviews are
described in the sections below; the discussion of
the recreational potential of Deer Island is
included in the section on All Secondary Long.

a.  Construction Traffic

Existing road conditions in Winthrop and East
Boston, with or without the construction of a large
wastewater treatment plant on Deer Island, give rise
to the following specific concerns:

1.  Emergency access to Deer Island and the
    neighborhood adjacent to the treatment plant
    site, Point Shirley, is possible by only one
    narrow, winding roadway through Winthrop.
    Furthermore, the roadways closest to Deer
    Island, at Point Shirley, are very narrow and do
    pose a potential for accidents as a result of
    the mixture of through traffic and residential
    use.  In particular,- the portion of Shirley
    Street from Washington Avenue to Cottage Hill,
    with public transit buses, two way traffic,
    parking on both sides, an offset alignment and a
    fairly sharp curve, does not provide completely
    safe and convenient public traffic service.

2.  The Town of Winthrop is accessible from the
    surrounding metropolitan area by only two
    roadways, each with only two travel lanes.  The
    intersections on Saratoga Street near Bennington
    Street in East Boston, with their public transit
    station bus ways and parking lots, constrained
    roadway width, and adjoining business uses, are
    congested, creating a long, stop-and-go queue,
    up to one mile, on Saratoga Street in the
    mornings.

    The Saratoga Street Bridge over Belle Isle Inlet
    is in deteriorating condition, and may need
    replacement in the near future.
                                                                       19

-------
                                                          one. UACJ
                                                          d?Hg6frtVM
                                                               9#r
In addition, in order for Winthrop and East
Boston residents to travel anywhere except to
the north, they must traverse both the Sumner
Tunnel and downtown Boston on ramps and roadways
that are severely congested, almost all day
long, by traffic from Logan Airport, the
northeastern metropolitan area, and beyond.
20

-------
Without mitigation, this multi-year construction
project would generate major new traffic (up to 500
trucks a day) and would make a difficult situation
worse.  The SDEIS proposed to limit the traffic
increase to about 8 heavy trucks (round trips) and
to an average of 13 buses (26 peak) per day by
requiring barging of all bulk materials and the
busing of all construction workers.  This increase
in traffic will not be significant, especially since
most of it will run counter to the predominant flow
of commuting traffic, using lanes that are not
otherwise heavily traveled at that time of day.

Comments on the SDEIS raised the question of whether
such mitigation was in fact possible, and whether
still more could be done.  Review of the mitigating
actions proposed in the SDEIS indicates that they
are feasible.  Historically a great deal of major
public works construction has occurred on Deer
Island prior to its connection to the mainland.  The
waters off Deer Island are sufficiently deep for
barges and the underlying soils, while not ideal,
are suitable for pier foundations.  For the
commodities proposed in the SDEIS for barging, no
special facilities would be needed for off-island
loading and unloading.  Gravel and steel could be
loaded into the barges from any general purpose pier
and surplus earth excavation to be removed from the
island would likely be dumped off shore anyway since
there is no longer a ready market for common fill.

In arriving at its conclusion that the number of
heavy truck trips could be limited to eight per day,
the SDEIS assumed that the lack of roll-on/roll-off
(RO/RO) loading facilities precluded the barge
movement of material and equipment other than bulk
materials.  However, further study demonstrated that
it is feasible to reduce construction traffic even
further by providing RO/RO facilities at Deer Island
and at a point on the mainland (such as along the
Mystic, Chelsea, or Fore or Back Rivers, or Lynn
Harbor).  RO/RO facilities, for low volumes of cargo
(8 to 20 trucks per day) would require a simple ramp
supported by a gantry or a float and some mooring
dolphins at each end of the barge line, a single
barge and less than one acre of land.  EPA regards a
RO/RO facility as a desirable construction practice
which will virtually eliminate heavy construction
trucking and reduce operation traffic.  Accordingly,
                                                              21

-------
EPA includes RO/RO as a mandatory mitigation
measure.  It is estimated that construction related
trucking would be reduced to an average of eight
lighter trucks per day.

The SDEIS, in estimating 13 buses (26 one year  peak)
per day, assumed that all workers would be bused  to
the site.  This number could be reduced by providing
a ferry service for workers coming from the south
and west.  Further analysis has confirmed that  this
is not only practical, but that intra-harbor worker
ferry service could be a highly satisfactory mass
transit alternative for workers living to the south
and west of the harbor.  An investigation of the
factors influencing the feasibility of ferrying
(e.g. cost, harbor regulations, terminal sites)
showed that it would be feasible to provide this
service and to reduce predicted bus traffic.  A
prohibition on individual construction worker
vehicles and a requirement of a combination of
busing and ferrying will be mandatory mitigation
measures.

In summary, review of construction traffic impacts
indicated that the impacts of the proposed project,
as they will be required to be mitigated, will  be
acceptable.

b.  Operation and Maintenance Traffic

The operation of the wastewater treatment
facilities, with a permanent operating staff
estimated at 227 in the SDEIS, could be expected  to
generate the average traffic equivalent of a 50
house residential neighborhood or a small industrial
facility.   The traffic generated, about 250 round
trips per day, would be spread over three shifts,
lessening peak load.
       is   so  150      1,500    15,000
      -H	1	1	1	1
      150   250 1,500      15,000    150,000 7Rlp6
22

-------
 This  level  of traffic is well within the roadway's
 capacity  and will not be distinguishable from the
 present level of treatment plant  and prison
 operations  traffic.

 c.  Noise

 Salient questions on noise centered  on construction
 traffic and on the effects of multiple pieces of
 equipment in simultaneous use at  the construction
 site  on nearby receptors.

 Traffic noise from the few trucks and buses that
 would use the streets of Winthrop, with waterborne
 transportation of construction  materials, would be
 of brief  duration, only a few minutes per day, and
 hence is  an acceptable impact of  the proposed
 project.

 Recalculation of construction noise, on the other
 hand, indicates that the SDEIS  underestimated both
 the number of pieces of heavy construction equipment
 likely to be on the site on  average  and the noise
 likely to be generated by individual pieces of
 equipment.   The net effect of these  changed
 assumptions would be to generate  the noise levels at
 the prison and Point Shirley, during daytime
 construction operation, to those  shown on the
 accompanying table.
                            TABLE III-l

                      EXPECTED CONSTRUCTION NOISE
                       DEER ISLAND AND VICINITY

                            Ambient Noise
                              Measured    Total Noise  Boston N.C. Reg.
                           L „ dBA (1 hr.)  dBA (L  )      L   dBA
  Location           Zoning    10	  	iP.—  	i°	
Tafts Street
(Pt. Shirley)       Residential       60         59-63         75

Prison            Residential/       Q2        69_?5         „
Prison            Institutional
Without aircraft noise.
Estimated.
                                                                23

-------
 These levels at the nearest portions of Point
 Shirley are well below (15 decibels) City of Boston
 noise regulations applicable to construction
 projects and are equivalent to current ambient L^g
 noise levels at Point Shirley without aircraft
 overflights.  During aircraft overflights,
 construction noise would be completely masked at
 Point Shirley-  However, at the prison, even though
 the noise regulations are not exceeded, EPA believes
 mandatory mitigation will further reduce the
 levels:  EPA will require that the drumlin be
 excavated from its south side so that the remnant
 acts as a shield; furthermore, a sound barrier must
 be erected to reduce noise levels at ground level at
 the prison.

 Considering the duration of the proposed
 construction project, however, consideration should
 be given to further reasonable mitigation.  To some
 degree, additional mitigation appears possible in
 the scheduling of construction activities, and in
 limiting the number of noise emitters operating
 simultaneously near the prison.  Further mitigation
 may be possible by the construction of an earthen
 mound, across the neck between Deer Island and Point
 Shirley, using excavated earth that would otherwise
 have to be removed from the site.  The specific
 extent of the mound, and its resulting
 effectiveness, will depend in large part on the
 availability of land.  Figure III-3 shows one
 possible layout for a mound system.

             .
             3   100 ft hiah
                                             Deer  "
                                          Res / -;
POSSIBLE NOISE MITIGATION BUFFER

   POINT SHIRLEY / DEER ISLAND
 24
  •  •
Fort Dawes

 "

-------
In summary, review of noise likely to be generated
by construction of the facility indicated that no
violation of the applicable noise control
regulations will occur either at Point Shirley or
the prison.

d.  Odo r

Questions on odors centered on the level, frequency,
and severity of odor emissions to areas surrounding
the facility.  In summary, further analysis has
demonstrated that due to the characteristics of the
incoming wastewater, the uncontrolled odor impact of
the plant could be significant, but it is not a site
determining factor; existing and available
technologies can be used to reduce odors to an
acceptable level at all receptor sites, and odors
might be reduced even further as the result of
aggressive design.  However, it is not possible to
rule out some rare occurrences of odor due to
process upset or equipment malfunction.

The odor impact of a treatment plant is not a
controlling one in the site selection process
because a treatment plant at either Deer Island or
Long Island would have approximately the same odor
impact on a wide selection of receptor sites around
the Harbor.

l.If no odor controls are applied, odors would be
perceptible about the same percent of the time at
many receptor sites, as shown by the following table
(hours per year, percentages rounded):

                     Table  III-2
             Odors  Without  Odor Control:
              Percent of  Year  Perceived

                 Plant at Deer I.   Plant at Long I.

    Prison              9.8              6.0
    Point Shirley       6.3              4.0
    Cottage Park        5.4              3.3
    Squantum            3.5              4.5
    Hull                7.9             14.9
    Beachmont           3.4              3.2
    Hough's Neck        5.1              6.0
    Thompson Island     3.8              4.7
    Winthrop Beach      4.1              4.3
    South Boston        4.6              4.6
    Peddock's Island    5.4              9.0

Source:  Vol. II,  Section II-2, Tables 3 and 4
                                                             25

-------
Note that the neighborhood with the greatest
frequency of perceived uncontrolled odors would be
Hull from a Long Island plant, but Hull would also
be the most frequently impacted community from a
Deer Island plant.  In general, communities on the
west and south of the harbor would be more
frequently impacted by a Long Island plant.  Certain
neighborhoods in Winthrop such as Winthrop Beach are
also potentially as frequently affected by a Long
Island plant as by a Deer Island plant.
Furthermore,  a month by month analysis indicates
that, due to prevailing winds, during certain months
such as January, June, October and December impacts
on all receptors in Winthrop are either the same
from either plant or worse from a Long Island
facility.

2.  Without controls, the frequency at these
receptor sites of odors likely to generate strong
complaints is even lower, but still approximately
the same whether the plant is sited on Deer Island
or Long Island, except at the prison (hours per
year, percentages rounded):

                     Table III-3
         Percent of Year Uncontrolled Odors
           Would Generate Strong Complaint

                 Plant at Deer I.   Plant at Long I.

    Prison              8.1              1.2
    Point Shirley       1.5              0.7
    Cottage Park        0.5              0.3
    Squantum            0                1.2
    Hull                1.3              2.2
    Beachmont           1.3              0.5
    Hough's Neck        0.6              2.3
    Thompson Island     0.3              1.6
    Winthrop Beach      1.0              1.0
    South Boston        0.4              0
    Peddock's Island    0.5              1.7

Source:  Vol. II, Section II-2, Table 5.

3.0  Even without controls, odors strong enough to
severely interfere with normal activities could be
expected almost never at any receptor sites except
the prison.  However, location of the plant at Long
Island does result in a slightly greater impact on
Winthrop (percent of hours per year):
26

-------
                    Table  III-4
         Percent of Year Uncontrolled Odors
  Would  Severely Interfere with Normal Activities

                 Plant at Deer I.    Plant at Long I.

    Prison              4.3%
    Point Shirley        —            0.2%
    Winthrop Beach       —            0.2%
    Cottage Park
    Beachmont           0.3%
    Squantum
    Hough's Neck
    Peddock's Island
    Hull
    Thompson Island      —           1%

Source:  Vol. II, Section II-2,  Table 5.

Note that the Prison is clearly the most  heavily
impacted receptor.   The figures indicate  that when
uncontrolled odors would be perceived at  the prison,
they would be strongly perceived.   Uncontrolled
levels at the prison could on occasion approach
those at which headaches and  nausea result.

Though properly designed and  operated sewage works
employing good housekeeping practices should not
pose an odor problem,  the incoming metropolitan
Boston wastewater carries with it  the potential for
serious odor problems  independent  of such factors
and demands that a thorough investigation of
specific mitigation actions be made.

Effective mitigation of odor  from  a Boston Harbor
treatment facility will be contingent upon the
implementation of the  following mandatory mitigation
measures:

1.  A further, complete monitoring of the odor
    characteristics of the influent to the current
    treatment works.

2.  A commitment to the maximum feasible  degree of
    mitigation.

3.  A thorough investigation  of state-of-the-art
    odor control technologies to be applied not only
    at the treatment plant but at  points  in the
    conveyance system.   This  study will be
    undertaken as part of the facilities  planning
    process.
                                                             27

-------
By making every effort  to apply reasonably available
technology designed  to  achieve a high degree of
efficiency, EPA believes that a reasonable and
effective mitigation  of odors can be achieved, so
that  except at the prison odors would be perceived
very  rarely at all receptors and never at the level
which would generate  strong complaint.  Due to the
proximity of  the  Deer Island House of Correction,
however, it is possible that odor could reach levels
at the prison at  which  complaints could arise, but,
should the above  reasonably available technologies
be applied, it is expected that these occurrences
would be rare and levels would never reach those
which cause severe interference with normal
activities.

Furthermore applying  the above mandatory mitigation
measures, EPA expects that detailed odor control
strategies can be developed during detailed
facilities planning  and design which will eliminate
"strong complaint" odors at the prison and further
reduce perceptible odors at other receptors.

It should be  noted that even a well-operated
facility emits a  low  level of musty odor to which
some  people object if they can smell it at all but
this  is unlikely  off-site.  Also, it is impossible
to guarantee  that a  process upset or equipment
malfunction will  not  reduce the efficiency of the
odor  control  system  so  that odor will increase to
perceptible levels; because it is expected that odor
control technologies  will be applied at multiple
locations in  the  delivery and treatment system,
temporary failure of  a  piece of equipment or a
process will  not  result in severe odor at a
receptor.  The likelihood that such a temporary
event,  if it  occurred,  could be perceived in a
neighborhood  is roughly expressed by the Table III-3
of percentages.

In summary, EPA concludes that acceptable levels of
odor  control  can  be achieved through reasonably
available technology  and that the mandatory
mitigation measures can result in a treatment plant
which is rarely perceived as offensive.

e.  Volatile  Organic  Compounds

The metropolitan  sewer  system is used by many people
for the disposal  of such volatile organic compounds
(VOC)  as cleaning fluids and solvents.  These
28

-------
compounds can be expected to volatilize continuously
throughout the sewer system, including the treatment
plant, and be dispersed into the atmosphere where
ever they volatilize.

These compounds have two quite different adverse
environmental effects, i.e. they may be directly
damaging to health in their original forms, and they
may be indirectly hazardous by contributing to the
formation of atmospheric smog.  The effects of each
of these potential impacts were separately evaluated.

To examine the impacts associated with compounds
that may be directly damaging to health, their
concentrations in the vicinity of the treatment
plant were calculated.  It was estimated that, (1)
at the present time, with primary treatment, 1/3 of
these compounds that reach the plant go off into the
air and  (2) with secondary treatment with no
controls, about 85% could do so.

EPA calculated the concentrations of the various
compounds in the air even without emission controls;
EPA found no levels that can be construed to be a
significant health threat, either at the prison or
in any neighborhood, according to criteria developed
by EPA's Carcinogen Assessment Group and the U.S.
Public Health Service's Centers for Disease Control.

As discussed above, the atmospheric smog problem is
quite different in character from the toxic VOC
problem.  Smog is formed in the air by complex
interactions of oxides of nitrogen (emitted by
engines  and boilers), volatile organic compounds,
oxygen,  and sunlight.  The combination, which takes
hours to form, results in new compounds that are
irritating to the eye and damaging to lung tissue
and vegetation.

These new compounds are not a site specific problem,
but occur over large areas where the total emissions
of oxides of nitrogen and volatile organics can form
mixtures in the atmosphere that are stable long
enough to interact.  The most effective method of
control  is reduction over large areas of the
emission of oxides of nitrogen and volatile organic
compounds.

The proposed secondary treatment facility, wherever
it is located, is expected to generate more volatile
organic compound emissions than the existing primary

-------
facilities.  Wherever the plant is located, an
identical level of control of these emissions will
be required under the Clean Air Act.  Specific
controls could include:

1.  control of emissions at the treatment plant by a
    volatile organic compound capture system.

2.  control of the discharge of volatile organic
    compounds to the sewer system by user
    pretreatment or recycling.

3.  more stringent control of volatile organic
    compound emissions from other sources throughout
    the metropolitan area to compensate for the
    emissions from the wastewater treatment plant.

In summary, review of volatile emissions indicates
that they will pose no hazards to public health and
are not significant in siting the facility.

f.  Pathogenic Aerosols

Commentors noted that the "activated sludge" process
for secondary treatment generates aerosols, less
than one percent of which can contain viable
microorganisms that can, theoretically, have adverse
effects on public health.

EPA reviewed relevant literature to determine what
is known about the impact of pathogenic aerosols on
populations working or living near wastewater
treatment plants.  No epidemiological evidence was
found of public health hazards from such plants on
nearby residential neighborhoods.

For further discussion on this and other technical
issues, see Volume II.

g.  Risk of Chlorine Spills

Public comment on the SDEIS raised questions as to
whether the continued storage and use of liquid
chlorine (i.e., liquified gaseous chlorine) at Deer
Island poses a threat to public health and safety,
and whether the storage and use of liquid chlorine
would be safer if the treatment plant were built at
Long Island instead of Deer Island.
30

-------
Chlorine gas is toxic, and it, can move rapidly with
the wind in a gaseous state.  It is usually shipped
and stored as a pressurized liquid, but if spilled
it readily vaporizes at normal atmospheric pressures
and temperatures.  An accidental liquid chlorine
spill during transport, storage, handling, or use at
a sewage treatment plant should be considered a
potential threat to the health and safety of
treatment plant staff and local residents.  Such
accidents, while rare, have occurred as a result of
the widespread use of liquid chlorine by industry
and by other municipal sewage treatment facilities.

Further study of the implications of the use of
liquid chlorine for the MWRA secondary treatment
plant showed that liquid chlorine use does not
affect the site selection process.  Even though a
plant at Long Island would be farther from
residential areas than a plant at Deer Island
(causing greater dilution of any chlorine gas cloud
which might reach populated areas), the winds would
be approximately three times as likely to blow such
a cloud from Long Island toward a residential area
such as Hull.  Thus, the proximity of inhabitants
near Deer Island to its proposed plant site, weighed
against the increased risk of a release being blown
toward residential areas in the case of a Long
Island site, reduces chlorine use as a
site-determinating factor.

However, certain special features of the Deer Island
site call for unusual precautions for the long-term
use of chlorine.  The treatment plant would be
immediately adjacent to the Deer Island House of
Correction, unless the prison were removed.  The
prison inmates and staff would be at increased risk
in the event of a chlorine spill from this larger
facility because of their proximity to the plant and
lack of mobility.  Compounding the problem, Deer
Island and neighboring Point Shirley could be
difficult to evacuate because they are served by
only one narrow roadway.  The roadway itself leads
directly away from the plant (i.e., downwind if the
wind is wrong) without intersecting alternative
routes for two miles.  In light of these special
characteristics of the Deer Island site, EPA has
determined that, as a mandatory mitigation measure,
if Deer Island is to be the site of the new
treatment plant, liquid chlorine shall not be used
at a new Deer Island treatment plant unless the MWRA
can demonstrate to EPA during facilities planning
                                                             31

-------
that there is a clear and convincing need for the
use of liquid chlorine and that it can be
transported, handled, stored, and used in an
environmentally acceptable manner.

The transportation of liquid chlorine through
Winthrop by truck presents a separate but related
issue.  The Massachusetts Executive Office of
Environmental Affairs has stated that the frequent
transport of liquid chlorine for a Deer Island
treatment plant through residential streets as
narrow as those in Point Shirley is undesirable and
should be eliminated from planning for the long-term
facility under study in this FEIS.  EPA agrees and
believes reasonable alternatives exist.
Accordingly, as part of its effort to minimize
impacts on neighbors, as a mandatory mitigation
measure EPA will require that the trucking of liquid
chlorine through Winthrop cease upon completion of
the pier and associated on-shore transportation
facilities called for in this FEIS.

h.  Archaeological and Historical Resources

An archaeological reconnaissance survey of Deer
Island prepared by a consultant for MHRA has
identified the abandoned sewage pump station complex
(including a farmhouse) and the House of Corrections
complex as potentially eligible for listing on the
National Register of Historic Places and for the
special consideration afforded by that listing.
Moreover, an archaeological survey has verified the
existence of unmarked graves on the prison grounds.
MWRA is continuing investigation of the House of
Corrections complex and the graveyard.  No
prehistoric archaeological sites have been located
on Deer Island.

With respect to the prison and pump station
complexes, all steps necessary to comply with
Section 106 of the National Historic Preservation
Act will be completed as soon as possible.  This
will include determination of whether the project
will have an effect or an adverse effect on these
structures and preparation of a "preliminary case
report" and "memorandum of agreement" between the
EPA, the Massachusetts Historic Preservation
Officer,  and the Advisory Council on Historic
Preservation, taking into account the effects of the
project on eligible historic properties.   During
facilities planning,  preservation and reuse of
eligible  structures will be rigorously evaluated.
32

-------
With respect to the graveyard, legislative action
might be necessary to relocate the graves.  Instead,
depending upon the extent of the graves, the
cemetery might not be affected.  The additional
study under way will provide the information
necessary to make this decision.

It should be noted that neither the presence of
graves nor of historic structures (which may be
present at each island) precludes construction of a
treatment plant.


i.  The Benefits of Moving the Prison

There is a variation of the All Secondary Deer
Island which assumes that the prison would be
removed, as a mitigating action, and that its site
would be made available for the wastewater treatment
plant.  This variation would use most of the island
but land would be available for buffering,
contouring, and recreational use.

The removal of the prison would reduce the impacts
of the treatment plant in several ways, including
the following:

1.  It would remove the receptor population (the
    prison workers and inmates) most affected by the
    plant's impacts, including noise and odor.

2.  It would eliminate prison-related traffic, thus
    offsetting construction-related and operations
    traffic for the treatment plant.

3.  It would improve the appearance of Deer Island
    by removing the prison buildings.

4.  It would permit opportunities for sculpting the
    landscape to a more natural appearance and for
    screening the facility from both the harbor and
    Point Shirley and Cottage Hill in Winthrop.

5.  It would increase the opportunity for buffering
    noise at Point Shirley by earthen barriers on
    prison property.

6.  It would permit the retention of at least a
    portion of the island's shoreline for recreation,

7.  It would remove prison-related anxieties from
    Winthrop.
                                                              33

-------
8.  It would make more land available to the
    wastewater treatment facility, possibly making
    construction and maintenance easier.

This variation does not reduce the need for any of
the mitigating actions proposed for the All
Secondary Deer Island alternative with the prison to
remain, except for those intended to reduce impacts
at the prison itself, e.g., a noise barrier.

However, the process required to release the Deer
Island prison site for treatment plant use may be so
lengthy as to delay or frustrate the construction of
this variation of the All Secondary Deer Island
alternative.

EPA has long advocated removal of the prison if Deer
Island is to be the treatment plant site, but EPA
will not require removal of the prison as a grant
condition because implementation of secondary
treatment as required by the Clean Water Act cannot
be made dependent upon removal of the prison if the
site is otherwise acceptable.  This FEIS concludes
that in EPA's judgment the All Secondary Deer Island
alternative can be implemented without unacceptable
environmental impacts even if the prison remains.
     34

-------
  SDEIS SECONDARY TREATMENT ALTERNATIVES
B.  Split Secondary Deer Island and Nut Island

The SDEIS summary said of this alternative:

    "This alternative would:

    1.   Expand the Deer Island treatment facility to
        provide secondary treatment for all flows.

    2.   Expand the Nut Island treatment facility to
        provide primary treatment.

    3.   Construct a new pipeline or tunnel from Nut
        Island to Deer Island to allow pumping of
        Nut Island primary effluent to Deer Island
        for seconda ry treatment.

    4.   Construct a new local outfall  to the east of
        Deer Island Light.

    "AREA:  The existing facility on Deer Island
    would be increased from 26 acres to about
    115-140* acres while those on Nut  Island, now
    about 12 acres in extent, would be increased to
    about 18 acres.

    "COST:  The overall construction cost of this
    alternative would be about $1285*  million and
    its  annual cost of operation, ma intenance and
    replacement would be about 350* million.

    "IMPACT:  On Deer Island  its significant impacts
    would be virtually identical to those of the
    preceding alternative, namely slight to moderate
    traffic impacts at Point  Shirley and moderate
    loss of recreational potential and severe loss
    of  visual quality at Deer Island.
        Proposed gxtrje Pier
                                                  "On Nut Island,  however, since the  site is
                                                  closely limited  by  both adjoining houses and the
                                                  sea,  th is alternative would generate severe
                                                  environmental effects.  The expansion of the
                                                  plant  would expose  the  immediately  adjacent
                                                  neighborhood on  Quincy Great Hill,  during the
                                                  construction period, to five years  of noise and
                                                  mess,  and, thereafter,  to the sight and
                                                  infrequent smells of an even larger sewage
                                                  treatment plant  than now exists.  To maintain a
                                                  buffer zone, it  will be necessary either:

                                                  a.   to fill up to 3 acres of Hingham Bay, or

                                                  b.   to relocate  the small number of families
                                                      immediately  adjoining the site.

                                                  "This  alternative will have no impacts on Long
                                                  Island and will  preserve it for  future
                                                  recreational use.'
                                                              'Updated, See  Vol II,
                                                                             35

-------
Comments on this alternative, made in response to
the SDEIS, were similar to those made on the All
Secondary Deer Island alternative, but with stronger
expressions of concern about the closer proximity of
the Nut Island facility to a residential area.

Subsequent reviews indicate that at Nut Island, the
impacts would be even more severe than those
described in the SDEIS.  It is likely that L^Q
(10% peak) construction noise would be about 10
decibels worse than previously estimated, resulting
in 82 dBA in the adjoining residential neighborhood
for various lengthy periods during five years.  This
severe noise level would be probably impossible to
mitigate because of the topography, the small size
of the site and the closely adjoining residences.
Some mitigation could occur by careful scheduling of
construction activities.
36

-------
            SDHS SECONDARY TREATMENT ALTERNATIVES
C,  All  Secondary Long Island

The SDEIS  summary said of this  alternative:

    •This  alternative would:

    1.   Construct a wholly new, consolidated
        secondary treatment facility on Long Island.

    2.   Reduce the existing primary treatment
        facilities at Deer Island and Nut Island  to
        smaller headworks.

    3.   Construct major new pipelines or tunnels
        from both Nut and Deer  Islands to Long
        Island to allow the consolidation of the
        facilities.

    4.   Construct a new local outfall to the east of
        Deer Island Light.

    •AREA:  The new Long Island treatment facility
    would  require about 115-140* acres of land,
    while  the Deer Island and Nut Island facilities
    would  be reduced from 26 and 12 acres
    respectively to 5 and 2 acres.

    •COST:  The overall construction cost of this
    alternative would be about  $1180* million and
    its  annual cost of operation, maintenance and
    replacement would be about  $50* million.

    •IMPACT:  The sheer size of this alternative
    would  require the removal and relocation of the
    City of Boston's Chronic Disease Hospital from
    the  island.  It would have  a severe impact on
    the  proposed recreational development plans of
    the  City and Department of  Environmental
    Management for the island.  It would occupy all
    of the central upland, precluding the island's
    development as a large, diversified recreation
    area.

    •The facility would also be immediately adjacent
    to,  and upwind of, the parade ground and Long
    Island Head, areas proposed to be intensive use
    recreation areas.
"In addition,  it would change the appearance of
the island from both on-island and off-island
vantage points and would have a severe impact on
archeological  and, possibly,  other cultural
resources on  the island.

•In addition,  it should be noted that this
alternative would require land transfer from the
City of Boston, approval of land transfer and
construction by the Department of Environmental
Management, and approval of land transfer by the
legislature.   It would also require review by
the United States Advisory Council on Historic
Preservation and the Massachusetts Historical
Commission.  These procedures could
significantly  delay, or even  impair, the
implementation of this alternative.

"This alternative will have no significant
adverse impact on Nut Island.  It is expected to
release almost all of Deer Island for other
purposes including, possibly, recreation."
                               '/fm.
                                                                         •Updated.   See Vol. II.

                                                                                         37

-------
Comments on the SDEIS raised questions about the
possibility that the SDEIS exaggerated:

1.  The intrinsic value of Long Island as a park
    resource, as compared with Deer Island.

2.  The adverse impacts of a treatment plant on Long
    Island on the appearance, recreational use
    potential, and archaeological resources of the
    island.

3.  The legal difficulties of acquiring the site for
    a treatment plant, including the difficulties of
    removing the civil war cemetery.

4.  The difficulties of over-the-road access to Long
    Island.

Commenters also questioned the feasibility of
establishing a barge terminal on Long Island,
whether shifting the facility from Deer Island to
Long Island would not eliminate any adverse
environmental neighborhood impact but simply shift
it from one neighborhood to others, and whether the
higher costs of building on Long Island would fall
disproportionately on local taxpayers.

Review of these issues indicates:

a.  Value of Long Island and Deer Island as a Park
    Resource

    Direct comparison of the on-site natural
    resources of the two islands indicates that Long
    Island does offer a greater variety of close-up
    quality natural landscapes, including.a small
    waterfowl pond, marshes, beaches,  bluffs, etc.

    Similar comparison of the seascapes that
    surround the two islands indicates that Deer
    Island offers a greater variety of broad views
    of the sea, the rocky shoreline of Massachusetts
    Bay,  the harbor and the islands, and the Blue
    Hills.

    Systematic evaluation of Long Island and Deer
    Island for the range of recreational activities
    that  appear appropriate (viewing the scenery,
    walking,  fishing,  picnicking, etc.)  indicates
    that  the two islands appear to be  approximately
    equal  in  potential  long-term value as
    recreational resources, as places  around which
    to  walk  in a variety of landscapes and from
    which  to  view a variety of waterfront scenery.

 38

-------
However a Deer Island park faces severe short
and  intermediate term difficulties due to
problems of prison security access, delays
inherent in treatment plant demolition and the
necessity of extensive  island rehabilitation.

Finally, evaluation of  both islands as elements
of the harbor landscape, as viewed from off the
islands, indicates that the two islands are
quite similar, though Long Island occupies a
more central location.  They are nearly equal in
area and in their range of topographic
variability; they both  present large areas of
vegetation; and they both are the sites of large
and  highly visible institutional building
complexes.
b.  Impacts of Construction on the Appearance,
    Recreational Use and Archaeological Resources of
    the Islands
The amount of land required for this alternative
will be more than the 96 acres estimated in the
SDEIS.  With secondary treatment and sludge
digestion all on Long Island, the plant would
                                                                     39

-------
     extend  from the edge of the uplands  just to the
     south of  the Nike missle base site to a line
     just below the "Head"  to the northeast, an area
     of  between 115-140  acres.

     Though  preliminary  design  studies for the siting
     of  treatment facilities on Long  Island indicate
     that a  plant could  be  built on Long  Island
     somewhat  following  the terrain and keeping
     somewhat  back  from  the edges of  the  bluffs, it
     is  likely that a plant of  this scale would cause
     harm to the appearance of  the island as seen
     from the  adjoining  waters  and shorelines.

     However,  the facility  could be built with no
     disturbance  to  the  wetlands, barrier beaches  and
     documented archaeological  resources  on the
     southwestern portion of the  island,  and with  no
     direct  disturbance  to  Long Island Head and its
     old fortifications. These undisturbed areas,
     including most of the  scenic and ecologically
     valuable areas  of the  island, could  be preserved.

     Any similar plant built on Deer  Island would
     require levelling the  drumlin and occupying all
     of  the  island  south of the prison, unless the
     prison  were  to be removed. With removal of the
     prison, however, an attractive,  alternative
     landscape having recreational potential could be
     created in the  land remaining around the
     treatment facility. There are no wetlands,
     barrier beaches or  documented archaeological
     resources on Deer Island.

 c.   Cost Estimates

     Review  of the  cost  estimates of  the  various
     secondary treatment alternatives indicate:

     1.  That  all the alternatives are likely to be
        significantly more costly than previously
        estimated.

     2.  That  there are  no  significant differences in
        the costs of the various alternatives, i.e.
        the differences between alternatives are
        less  than the inherent errors of engineering
        cost  estimation.

With little or no difference in cost between
alternatives, there would  be no disproportionate  tax
impact  if the Long Island  site were  to be chosen.
40

-------
                                     TABLE III-2

                      COMPARATIVE CONSTRUCTION COSTS OF OPTIONS (1985)
                                      (Millions)

                          All Deer      All Long   Split Deer-Nut Split Deer-Long

        Primary          1,065 - 1,090   1,180 - 1,285  1,210 - 1,230  1,345 - 1,365

        Secondary        1,11s1- 1,1352  1,1803- 1,2854  1,275 - 1,295  1,355 - 1,375


                Estimated Annual Operation, Maintenance and Replacement Costs

        Primary Facilities Only           $16,500,000 - $33,500,000

        Secondary Facilities Only         $28,000,000 - $50,000,000


        •'•Prison removed.
         Prison to remain.
         Hospital removed.
         Hospital to remain.


        Source:  FEIS Vol. II, Section II-8.
                FEIR on Siting of Wastewater Treatment Facilities for Boston Harbor,
                Vol. I, C.D.M., Dec. 1985.
d.  Legal  and Institutional Analysis


       Since preparation of the SDEIS,  the Massachusetts
       legislature created the MWRA  to  operate and  improve
       sewage collection, disposal and  treatment systems
       which were formerly under the control of the MDC.
       The  act creating  the MWRA provides new powers  to and
       limitations on  the MWRA which were not applicable to
       the  MDC, including new provisions  exempting  the  MWRA
       from certain state laws, and  subjecting it to  new
       legislative controls.  Accordingly EPA conducted a
       legal analysis  of the power of the MWRA to acquire
       necessary land  and construct  wastewater treatment
       facilities on both Long Island and Deer Island.   Its
       legal analysis  is part of Volume  II of this  FEIS.

       The  legal analysis concluded  that, for several
       reasons, legislative and gubernatorial approval
       would certainly be required to authorize
       construction of a secondary treatment facility on
       Long Island, but  that the need for such an approval
       is less clear in  the case of  Deer  Island.  The
       recent discovery  of graves on Deer Island increases
       the  likelihood of the need for legislative
       approval.  In any event, legal counsel for the MWRA
                                                                         41

-------
   has determined that the Authority should seek
   legislative and gubernatorial approval of a Deer
   Island site as a precautionary matter.  Thus, it is
   probable that whichever site were selected, the
   approval of the legislature and governor would be
   sought.  Although the need for legislative approval
   is not a site-distinguishing factor, the probability
   of obtaining support for the selected site is
   important.  In the judgment of EPA,  for reasons
   explained below and in the Decision  Process section,
   the legislature is more likely to approve of Deer
   Island than Long Island.  This conclusion follows
   from the policies regarding plant siting on the part
   of the governmental entities which own or control
   the use of property on both islands  and the
   implications of these policies for legislative and
   gubernatorial approval.

   Long Island, with the exception of the lighthouse,
   is owned by the City of Boston under the care,
   custody, and control of the Boston Department of
   Public Health and Hospitals.   It lies within the
   corporate limits of the City of Boston, which has
   expressed its desire to continue the hospital use
   and supports use of Long Island for  recreation.
   Abandonment of hospital use could additionally
   require the approval of the Massachusetts Department
   of Public Health which must evaluate whether needed
   facilities are available elsewhere.   Furthermore,
   the siting of the treatment plant on Long Island is
   strongly opposed by the Massachusetts Department of
   Environmental Management (DEM).  DEM has the
   umbrella authority under the Harbor  Islands Act to
   veto public land transfers, construction and other
   activities which it deems inconsistent with the
   purposes of that act.   The DEM Commissioner,
   commenting on the SDEIS/EIR,  cited the "great
   significance and consequence  to the  Commonwealth" of
   Long Island as a park and noted that in OEM's view
   three million five hundred thousand  people annually
   would be deprived of what he  describes as a sorely
   needed recreational experience if Long Island were
   to become a major treatment plant site.  He
   described that loss as "severe" and  stated that no
   other island offered equivalent opportunities.  In
   addition, the City of Quincy,  through which the
   major access route passes, is  opposed to the use of
   Long Island for  siting of the  treatment plant.
42

-------
By contrast, the MWRA already owns or controls most
of the Deer Island site which is its tentative
preferred alternative by its vote of July 10, 1985.
The City of Boston has expressed a willingness to
transfer to the MWRA the Deer Island land it owns
(including the land currently occupied by the House
of Correction as well as other lands which would be
needed even if the prison remains.)  The General
Services Administration (GSA), in this document, has
tentatively identified the wastewater treatment
facilities as its preferred alternative use for the
federally owned parcels there, which are in the
process of disposal.  The DEM did not include Deer
Island in its 1984 draft recreation plan for the
harbor islands.

The array of opposition from its owner and other
governmental authorities to Long Island as a
treatment plant site, contrasted with the support of
the entities which control Deer Island, suggests
that approval of the Deer Island site would be more
likely than approval of the Long Island site.  For a
further legal analysis, the reader is referred to
the memorandum of law which is contained in Volume
II.
 Over  the  Road  Access  to  Long  Island

 Review  of roadways  to Long  Island confirms that
 they  are  inadequate for  the unmitigated impact
 of  many hundreds  of daily construction
 vehicles.   However, with barging and busing and
 with  the  portion  of Quincy  Shore Drive between
 Hancock and East  Sguantum Street opened to
 trucks  and buses, they would  be significantly
 better  for the  greatly reduced traffic than
 those to  Deer  Island.  In general, access would
 be  possible entirely  on  main  through roads that
 are heavily traveled  or  that  do not pass through
 residential areas.  However,  if Quincy Shore
 Drive cannot be opened to trucks and buses,
 drivers would  be  required to  use East Squantum
 Street  between  the Shore Drive and Hancock
 Street, a roadway as  narrow and winding as any
 on  the  route through  Winthrop to Deer Island.
 With  mitigation,  traffic to Long Island is
 acceptable.
                                                             43

-------
f.   Barge Terminal Feasibility

    In response to comments,  review  of  topographic
    conditions both on shore  and  off shore  at  Long
    Island show a pier is  feasible.   The pier
    facilities would be more  appropriate along the
    northwestern shore of  the Parade Ground rather
    than further to the southwest as shown  in  the
    SDEIS.   A parade ground location, somewhere
    between the two rotting,  existing piers, would
    avoid the bluffs that  could be a problem with
    the more southwestern  location;  it  would offer
    access to deeper water without dredging, and it
    would facilitate the use  of the  parade  ground as
    a "laydown" area during construction.
 44

-------
Relocation of Impacts

On the issue of whether "relocating" the
wastewater treatment facility from Deer Island
to Long Island would actually reduce human
exposure to adverse environmental effects or
simply relocate them from one neighborhood to
another:

1.  From the limited perspective of traffic
    congestion, if Quincy Shore Drive were
    available to trucks and buses, Long Island
    would be a better site.  It would be
    accessible over roads that are wider,
    straighter, and more separated from
    residential areas.  If the Drive is not
    opened, access is equal at both islands.
    However, with barging and RO/RO and ferrying
    and busing of construction workers, traffic
    is expected to have an insignificant impact
    at both sites.

2.  From the limited perspective of construction
    noise, Long Island would be a better site
    since there would not be any nearby
    residential receptors.  Construction noise
    levels at Deer Island prison are expected to
    be loud but within standards.  Construction
    noise levels at Point Shirley are well under
    Boston noise levels as the neighborhood is a
    half mile away from construction activity.
3.  From the perspective of odors, since EPA
    will require that the wastewater treatment
    facilities incorporate effective control
    systems, the facility is normally expected
    not to emit perceived odors and hence the
    two sites are equal, except at the prison
    where though the odor would occasionally be
    perceived from a Deer Island plant the
    impacts are expected to be acceptable.

To the extent that some level of perceived odors
do rarely occur even with mitigation as the
result of process upset, moving the plant to
Long Island does not significantly benefit
Winthrop overall and does increase impacts on
other harbor neighborhoods, such as Hull.
However, moving the plant to Long Island would
                                                         45

-------
   reduce the close exposure of the prison workers
   and inmates; Hull would be more frequently but
   less intensely impacted than the prison, but in
   either event, odor incidents are expected to be
   very rare and at worst, temporarily moderate.

   If the prison were to be removed, plants on
   either island would result in approximately the
   same overall neighborhood exposure to what very
   infrequent slight odor events may occur.

   As to other relevant impacts, it was concluded
   that any variation in impact was insignificant.
46

-------
            SDHS SECONDARY TREATMENT ALTERNATIVES
D.  Split  Secondary Deer Island  and Long Island

The SDEIS  summary said of this alternative:

    •This  alternative would:

    1.   Expand  the existing Deer Island treatment
        facility for primary treatment only.

    2.   Construct a new treatment  facility to
        provide secondary treatment for all flows  on
        Long  Island.

    3.   Reduce  the existing primary treatment
        facility at Nut Island to  a small headworks.

    4.   Construct new pipelines  or tunnels from both
        Deer  and Nut Islands to  Long Island to allow
        the consolidation of the facilities.
    5.
        Construct a new local  outfall to the east  of
        Deer  Island Light.
    •AREA:   The  new Long Island  facility would
    require about 82-96 acres of land; the Deer
    Island  facility would be increased from 26 acres
    to about 52  acres, and the Nut  Island facility
    would be reduced from 12 acres  to about 2 acres.

    •COST:   The  overall construction cost of this
    alternative  would be about $1365* million and
    its annual cost of operation, maintenance, and
    replacement  would be about $50* million.
    •IMPACT:   At Long Island,  the  effects of this
    alternative are virtually identical to those of
    the preceding  alternative.   It would occupy the
    central uplands, require relocation of the
    Chronic Disease Hospital,  preclude development
    of the proposed hiking and nature study area to
    the south, severely impact on  proposed intensive
    use areas at Long Island Head, and suffer from
    severe institutional constraints to
    implementation.
                       Long bland Mead'
   Proposed &arr]e fter
•Elsewhere,  based on the extensive and detailed
evaluations  of all the impacts, as described in
detail in  the SDEIS/EIR, none of  the
environmental impacts of this alternative, with
the required set of mitigating actions, are
expected  to  be severe or significant.  At Point
Shirley,  the nearest neighborhood in Winthrop,
nearly one half mile away from the plant, it is
expected  that traffic and traffic noise will
increase  somewhat during construction, but that
the increase will have slight impacts.
Construction traffic is not expected to exceed
15 trucks  and buses each day.

"with respect to Deer Island, this alternative
is not expected to have any severe environmental
effects since the plant will not  alter the
appearance of the island, the island is ample in
size, and  most of the land to be  used is
otherwise  unused or committed.  The expansion
will leave substantial portions of Deer Island
for other  purposes including, possibly,
recreation.

•This alternative will have no significant
adverse impact on Nut Island."
                                                                              •Updated.   See Volume II.
                                                                                         47

-------
Salient comments on this alternative were limited to
the question of why the adverse environmental
impacts of a sewage treatment plant, its odors,
emissions and changes in land use and appearance
should be spread to more than one site.

Specific impacts of the split option on each island
would be perceived to be very similar to building
the entire plant on that one island alone.  For
impacts such as traffic, construction noise, and the
potential for odor, the effects on neighbors in
Winthrop and the prison would be about the same as
those of the All Secondary Deer Island alternative,
while the conflicts with the Commonwealth of
Massachusetts, and the City of Boston's proposals
for hospital and recreational use of Long Island
would remain.

The sole benefit of splitting the treatment plant
between the two islands is the reduction of the size
of the plant on each island.  The division of the
treatment plant to two sites, by reducing the land
area required on each site, would increase the
fraction of land available for other uses of both
islands,  including recreation.   This would make
smaller waterfront parks feasible on both islands
and preserve the Deer Island drumlin.

The division of the treatment plant, however,  would
not obviate the need  for the mitigating actions
described for the other  single-island alternatives.
48

-------
IV.  DECISION PROCESS

The SDEIS summary said of the process which EPA
proposed to use to select a site for secondary
facilities:

    "Six decision criteria have been identified.
    Each alternative will be evaluated to determine
    the extent to which it:

    1.  is consistent with and, if possible,
        promotes the fulfillment of the promise of
        Boston Harbor. ["Harbor Vision"]

    2.  can be implemented in a timely and
        predictable manner.  ["Implementability"]

    3.  minimizes the adverse impacts of the
        facility on neighbors, taking into
        consideration existing conditions, facility
        siting impacts and mitigation measures.
        ["Effects on Neighbors']

    4.  minimizes the impacts of the facilities on
        natural and cultural resources.  ["Impact on
        Cultural and Natural Resources"]

    5.  can be built and operated at a reasonable
        cost.  ["Cost"]

    6.  maximizes the reliability of the entire
        treatment system.  ["Reliability"]

    Public comment is sought on the adequacy and
    accuracy of all the material contained in this
    SDEIS including the decision making process.
    Are the decision criteria adequate?  How should
    the alternatives be rated against the decision
    criteria?  Which decision criteria are the most
    important?

    In addition, it should be noted that any of the
    seven options will have some impacts on some
    neighbors.  Some options locate most impacts on
    one site to the benefit of other sites.  Other
    options spread impacts among various sites.  We
    seek public comment on how the EPA and the
    Commonwealth should judge the combined
    consequences of each option."
                                                             49

-------
A.  Decision Criteria

EPA had made explicit the decision criteria as a way
to impose order on a mass of detail, and to focus on
those impacts which are relevant to the choice of a
site.  Public comment generally agreed that these
six criteria captured the premier issues that should
drive a siting decision, though there was strong
disagreement on the relative importance to be
accorded to each decision criterion.

B.  After the Close of the Public Comment Period

In light of the high degree of public acceptance,
EPA decided to retain its original six decision
criteria.  EPA also reviewed all the public comments
submitted to identify both those criteria-relevant
issues which needed further analysis prior to a
selection of a preferred alternative and those other
issues which related to the overall project, or were
otherwise not criteria-relevant, but which were
appropriate for inclusion in the FEIS or the MWRA's
FEIR.  EPA performed additional analyses on all
potentially site-relevant topics, such as noise,
odor, volatile organic compounds, feasibility of
barging and busing, feasibility of ferrying workers,
comparative recreation potential, preliminary site
layout, etc.

EPA and the MWRA agreed that it was appropriate for
each to pursue an independent decision making
process under their respective statutory mandates
but to do so in parallel and with a high degree of
coordination.  Accordingly, to ensure that both
agencies shared a common data base, as either agency
identified data needs or developed information, it
was shared with the other by exchange of technical
memoranda and through technical presentations at
meetings with EPA's Technical Advisory Group or with
the MWRA's Board of Directors or staff.

As additional data were received, EPA systematically
reviewed its entire data base using the decision
criteria suggested in the SDEIS and an evaluation
process described below.  This process evaluated
each piece of the mass of data in terms of one or
more of the appropriate decision criteria (was the
information relevant to the criterion and, if so,
how important?)  ensuring that the decision would be
based on current information and would be
objective.   EPA felt that each decision criterion
50

-------
was legitimate and was confident that sufficient
objective data existed to permit a reasoned judgment
as to the acceptability of the alternative sites.

To start this process, EPA scrutinized each decision
criterion carefully, in light of the technical
information then available, and identified the
specific impacts which were relevant to that
criterion.  For example, for the "Effect on
Neighbors* decision criterion, the principal
relevant impacts became the following:

  a.  Years of Construction      g. Pathogenic
  b.  Daily Construction Traffic    Aerosols
  c.  Operations Traffic         h. Chlorine
  d.  Construction Noise            Transportation
  e.  Odor                          and Use
  f.  Visual                     i. Volatile Organic
                                    Compounds

(For a list of the principal impacts relevant to the
other decision criteria, which EPA considered see
Appendix C.)

Then mandatory mitigation assumptions relevant to
that decision criterion were made an explicit part
of the impact analysis.  For example, EPA considered
to what extent barging and busing would reduce the
impact of construction traffic on "Effects on
Neighbors."

For each decision criterion, EPA performed the
following analysis:

    1.  EPA evaluated how severe each relevant
        impact would be if a particular site were
        chosen, e.g. how severe would construction
        traffic be in Winthrop if Deer Island were
        chosen?

    2.  EPA then evaluated the relative importance
        of each of the relevant impacts to the
        appropriate decision criterion.  For
        example, in a particular fact situation,
        what is the relative importance to "Effects
        on Neighbors" of construction noise impacts
        in Winthrop of a Deer Island plant, as
        compared with construction traffic impacts
        on Quincy of a Long Island plant.
                                                             51

-------
EPA reviewed its evaluations to identify areas of
possible technical misunderstanding or
miscommunication.  An effort was made to give
prominence to severe site-distinguishing impacts of
importance to a decision criterion, in order to call
attention to critical issues.  During this time,
additional pieces of technical information were
being received; these were continuously made part of
the evaluation and none caused a change in the
results of the evaluations already accomplished.

C.  Mandatory Mitigation Measures

Upon the completion of the review of each decision
criterion, the assumed level of mandatory mitigation
as set forth in the SDEIS/EIR was either confirmed
or, if appropriate, modified as the result of
further technical information.  EPA found that the
most critical need for mitigation was to reduce
impact on neighbors.

EPA adopted the following specific mitigating
actions to be required of the applicant.  These will
be required whichever site is selected  (except as
noted below):

    1.  Transportation of all bulk materials by
        barge.  Bulk materials, including earth,
        gravel, and reinforcing steel,  shall be
        transported to and from the site by barge.
        This action will require construction of a
        bulk materials loading pier at  the site, and
        associated terminal on-shore.

    2.  Use of roll-on/roll-off transport for heavy
        trucking.  In order to accommodate heavy
        trucking, a roll-on/roll-off barge loading
        facility shall be constructed at the site
        and at an onshore transfer station.

    3.  Busing and ferrying of workers  to the
        construction site.  Prior to the
        commencement of construction, the MWRA shall
        establish or cause to be established a bus
        and ferry service to provide transportation
        to and from the construction site.  The
        applicant shall ensure that all construction
        workers travel to and from the construction
        site only on said buses or ferries, except
        in cases of medical or other emergency.
 52

-------
4.  Control of odors.  To ensure adequate odor
    control, the applicant shall:

    a.  Conduct a baseline survey of the
        synchronous concentrations of malodorous
        compounds into the influent at Deer and
        Nut Islands, and in the air downwind of
        the existing wastewater treatment
        facilities.

    b.  Rigorously explore the technologies
        necessary to maintain concentrations of
        malodorous compounds in the air below
        the threshold of perception for the
        various compounds.

    c.  Design and construct appropriate
        facilities and/or equipment to control
        odor.

5.  Control of volatile organic compound
    emissions.  To ensure control of volatile
    organic compound emissions, the applicant
    shall:

    a.  Conduct a baseline survey of the
        synchronous concentrations of volatile
        organic compounds in the influent at
        Deer and Nut Islands, and in the air
        downwind of the existing wastewater
        treatment facilities.

    b.  Rigorously explore the technologies
        necessary to control the emission of
        volatile organic compounds.

    c.  Should the sampling program indicate, or
        if required by Clean Air Act, design and
        construct appropriate facilities and/or
        equipment to control volatile organic
        compound emissions.

6.  Liquid Chlorine.

    Liquid chlorine (i.e., liquified gaseous
    chlorine)  shall not be used at Deer Island
    unless the MWRA can demonstrate to EPA that
    there is clear and convincing need for the
    use of liquid chlorine and that this
    substance  can be transported, handled,
    stored, and used in a manner which will not
                                                         53

-------
        cause unacceptable risk  to the environment
        or to public health.   The MWRA shall provide
        EPA,  during further facilities planning,
        with  information on alternatives,  risk
        assessments, and methods of control
        sufficient for EPA to  complete its
        environmental review of  this issue of
        chlorine use.

    7.   Prohibition of the trucking of liquid
        chlorine through Winthrop.
        Through-neighborhood trucking of  liquid
        chlorine to Deer Island  is prohibited upon
        completion of the pier and associated
        staging called for in  this FEIS.

    8.   Exploration of alternative techniques for
        liquid chlorine use.   Giving due  regard to
        the hazards of liquid  chlorine, the
        applicant shall explore  alternatives to its
        use at the treatment plant as a headworks.

    9.   Exploration of alternative treatment
        processes.  The applicant shall identify any
        alternative treatment  processes that might
        be less space demanding,  less costly, or
        more  reliable under varying influent
        characteristics.   Such exploration is
        required under EPA's regulations  for
        facilities planning.

    10.  Exploration of recreational joint  use
        development of the wastewater treatment
        facility site.  The applicant shall  examine
        the feasibility of recreational development
        in conjunction with the  development  of  the
        new wastewater treatment  facility  site.
        This  exploration  is required under EPA's
        regulations for facilities planning.

    11.  Control of dust,  erosion,  and
        sedimentation.  The applicant shall
        implement the provisions  ordinarily  required
        by the City of Boston  and the Commonwealth
        of Massachusetts  for the  control of  dust,
        erosion,  and sedimentation.

    12.  Implementation of noise  control measures.
        While  noise levels during construction  are
        expected  to be within  acceptable  limits, due
        to the long duration of  this  project, all
54

-------
        practical noise reduction practices should
        be used.  These must include the excavation
        of the drumlin from the south.   These must
        also include the construction of a sound
        barrier to ensure compliance with noise
        standards at ground level outside the
        prison.  Because under the Nut  Island
        headworks options, short-term noise levels
        could be high at Nut Island during the
        relatively brief period of demolition of
        existing facilities nearest homes, MWRA must
        develop a noise mitigation plan including a
        scheduling of noise emitting equipment to
        reduce simultaneous impact on nearby homes.

Each of these mitigating efforts will be the subject
of detailed study by the MWRA as further facilities
planning explores these ways of achieving acceptable
levels of impact.  EPA welcomes this investigation
and the development of alternative, more innovative
and effective approaches which would achieve
equivalent impact reduction; EPA after  appropriate
environmental review is prepared to modify these
mitigation measures so that equal protection can be
achieved by better methods.

D.  Final Analysis

During the final analysis, it became clear that
three of the decision criteria, though  theoretically
important, no longer played site-distinguishing
roles.

    1)  On "Cost," a more detailed analysis revealed
        that the costs of the four alternatives were
        essentially equal.  The spread  of estimated
        costs among them was less than  had been
        realized and was less than the  inherent
        error factor of cost-estimating techniques
        of this nature.  Because of this, though the
        rank order remained the same and All
        Secondary Deer Island remained  the least
        expensive, EPA decided to regard this
        decision criterion as having neutral effect.

    2)  On "Reliability," though the reliability of
        the new plant or plants was of  great
        importance, further review could not
        identify any differences among the sites
        that could not be readily overcome by
        thoughtful design, segregation  of system
        flows, etc.  Each of the sites  permitted
        treatment plants of equal reliability.
                                                             55

-------
    3)  On "Impact on Cultural and Natural
        Resources," though this decision criterion
        included federally protected resources
        (wetlands, barrier beaches, recognized
        historical and archeological sites, etc.),
        the impact of plants on either Deer or Long
        Islands would be essentially equal.
        Preliminary site designs by both EPAs and
        the MWRA's consultants demonstrated that a
        treatment plant could be sited on either
        Deer Island or Long Island in such a way
        that either island's recognized or
        documented natural or archeological
        resources would be adequately protected
        though graves and possible historic
        structures on either island would be
        adversely affected in similar ways.  Thus
        the site-distinguishing significance of this
        decision criterion on the Deer-Long choice
        is eliminated.  On Nut Island, however, the
        Split Secondary Deer-Nut Alternative would
        involve the serious impacts of filling of
        tidal areas (unless homes were taken) and
        this was taken into account in the final
        decision.

"Effects on Neighbors," "Harbor Vision," and
"Implementability" remained as the principal
decision criteria for EPA.  EPA felt each of these
three criteria represented protection of important
public values of substantial weight.
56

-------
V.  Major Site-Relevant Criteria

A.  With respect to the 'Effects on Neighbors'
decision criterion, the populations of principal
concern are residential populations in proximity to
the three islands and their access routes.
Potential impacts on persons using the harbor for
recreation are principally evaluated under the
•Harbor Vision" Decision Criterion.  In the case of
Deer Island, potentially impacted residential
populations include, in particular, the staff and
inmates of the House of Correction, and the
residents of Point Shirley, Cottage Hill, and more
generally, the wider communities of Winthrop,
Revere, and East Boston.  Long Island, with its
central harbor location, has as its closest
"neighbors" many widely scattered but approximately
equidistant receptors including Hull, Hough's Neck,
Squantum, Thompson Island Education Center, South
Boston, the Deer Island House of Correction, and
Point Shirley in Winthrop.  (The Long Island
Hospital is not included in this analysis for, as
stated in the SDEIS/EIR, both Long Island secondary
alternatives assume that the hospital must be
relocated off-island.)  In the case of Nut Island,
principal attention is focused on Hough's Neck in
Quincy.

Should the  "no prison" variation of the All
Secondary Deer Island alternative be implemented,
EPA concludes that a treatment plant at either Deer
Island or Long Island would have acceptable and
essentially equal  impacts on its neighbors, with the
mandatory mitigation measures in place.

a.  As noted earlier, removing the prison not only
    eliminates a current source of adverse impact,
    but also permits the MWRA to implement the
    further mitigation it has proposed:   to contour
    the Island reducing even further construction
    noise levels and screening the facility from
    Winthrop's view.

b.  As to traffic, if Quincy Shore Drive were to be
    closed  to construction-related traffic, access
    was judged to  be equal in difficulty; if the
    Drive were to  be opened, access to Long Island
    would be better though this is somewhat balanced
    by Long Island's longer construction period.  In
    either event,  EPA concluded that the highly
    protective mandatory mitigation measures of
                                                              57

-------
     barging/busing/ferrying reduced traffic  impacts
     so  that  they were acceptable and essentially
     equal.

 c.   For such rare  odors as might occur, though Long
     Island is slightly more distant from its
     receptors than  the Deer Island site is from
     Point Shirley,  Long Island  is ringed by many
     equidistant potential receptors.  Odor impacts
     are-roughly equal, but Hull is the most
     frequently impacted community (from a Long
     Island plant)  and Winthrop  is impacted nearly as
     much from a Long Island plant as from a Deer
     Island plant.

 d.   All other neighborhood impacts were, as
     discussed, found not to be  significant or site
     relevant.

 However, if  the prison were to  remain on Deer
 Island,  EPA  concludes that a plant site on Deer
 Island  would have  a greater effect on its neighbors
 than a  site  on Long Island.  The prison adjoins the
 Deer Island  treatment plant site and, even with
 mitigation,  would  be subjected  to greater noise and
 odors than would Long Island's  more distant closest
 neighbors but these impacts were found to be
 moderate and acceptable.  The Point Shirley area
 would also be subject to somewhat greater traffic
 and  noise than Long Island's neighbors; Winthrop as
 a whole would be subjected to slightly greater
 traffic impacts than those in Quincy, but as
 discussed above, these and other neighborhood
 related impacts were found not  to be significant.

 EPA  did consider the issue of "fairness" earnestly
 advocated by the people of Winthrop.  Enough is
 enough, they said,  having experienced the
 uncertainty  of the  prison;  the  noise and risk of
 Logan's aircraft; the objectionable nature of the
 current wastewater  plant which  causes water
 pollution, odors, diesel exhaust fumes, and stack
 fires,  and which has experienced at least one
 potentially  serious chlorine leak.

 In addressing the issue EPA placed its principal
 emphasis on  an objective analysis of "Effect on
Neighbors" and considered issues of "fairness" in
 that context, including the mitigating effect of
moving the prison.   EPA believes that an upgraded
treatment plant with EPA's  mandatory mitigation will
58

-------
remove the adverse impacts associated with the
current facility and will improve water quality in
the Winthrop area.

EPA also considered the argument that the decision
maker must allocate within a metropolitan area the
inevitable burdens of regional responsibility
perhaps somehow offsetting them against the benefits
given a community by its location or by human design
so that the "pluses" and the "minuses" even out over
the entire area.  EPA concluded that in this case
the application of extraordinary mitigation that it
was requiring reduced the impact of the upgraded
facility so substantially that it could be
constructed despite the presence of the airport and
the prison.  EPA felt that removal of the prison was
desirable but not mandatory.

To summarize the issue of "fairness":  EPA has
engaged in a decision process which gathered
technical information, exposed it to extensive
public scrutiny, developed very stringent mitigation
measures, and evaluated the alternatives in terms of
disclosed decision criteria.  EPA believes this open
process has arrived at a fair and reasonable
conclusion that the upgraded treatment plant,
considered singly or in combination with other
conditions, will be constructed and operated with
acceptable environmental results.

The Split Secondary Deer-Long alternative would
involve major construction activity of approximately
the same perceived effect on the neighbors of each
Island as if the entire plant were being constructed
there.  Though those effects were found to be
acceptable, it was felt to be unwise to impact two
sets of neighbors unless there would be some benefit
to another decision criterion.

Split Secondary Deer-Nut imposed severe burdens on
its immediate neighbors on Hough's Neck without any
corresponding benefit to Deer Island and Point
Shirley.   It was found to be environmentally
unacceptable.

B.  Considering only the "Harbor Vision" decision
    criterion,  EPA concludes that though all four
    alternatives were acceptable, the All Secondary
    Deer  alternative was preferred under "Harbor
    Vision."
                                                             59

-------
     EPA's  principal  conclusion  as  the  result of  site
     investigations,  reports  and alternative site
     layouts  is  that  the  treatment  plant  could be
     built  on  Long  Island without seriously damaging
     the long-term  prospects  for public use of the
     Harbor because Deer  Island  could serve as a
     substitute  for Long  Island  as  the  Harbor's major
     island park resource.  However, EPA  participants
     did conclude that  Long Island  did  have greater
     current  potential  as a major island  park.  It is
     currently in much  better shape, has  more diverse
     cultural  features  and natural  habitats, has
     better access  for  visitors  and a central harbor
     location.  It  also has city and state support.

     A treatment plant  at either island risks causing
     severe visual  damage from off-island
     viewpoints. Though  this damage could be
     partially mitigated  by contouring  and screening
     in the case of a Long Island site  and a
     "no-prison" Deer Island  site,  any  visual damage
     that did occur at  Long Island  would  be more
     visible  due to Long  Island's central harbor
     location.

     Though EPA believes  that Deer  Island's size,
     topography, and  setting  give it acceptable
     long-term potential  for  rehabilitation as a  park
     resource, EPA  does conclude that while both  All
     Secondary Deer and All Secondary Long satisfied
     the Harbor Vision  decision  criteria, All
     Secondary Deer satisfied it better.

     Less acceptable  were the other two
     alternatives.  Though Split Secondary Deer-Long
     preserved significant potential recreation space
     at each  island,  EPA  agreed  with the  Commonwealth
     that an  entire island as park  was  preferable.
     Split  Secondary  Deer-Nut committed Nut Island to
     wastewater treatment without any corresponding
     benefit  at Deer  Island;  though Nut Island has
     not been a major part of a  harbor  park plan, it
     could  provide  locally important open space.

 C.   Considering only the "Implementability"  decision
     criterion,  the following issues were of
     principal importance to  EPA:

     a.   Permits and  Licenses.  EPA considers  the
         difficulties of  obtaining  the  required
         permits and  licenses to use either Deer  or
60

-------
    Long Island to be approximately equal.  In
    both cases it will be complex but can be
    done.  In the case of Nut Island, severe
    problems are anticipated in either the
    taking of homes or obtaining permits to fill
    since any of the other three alternatives
    avoids these impacts at Nut Island without
    increasing the impacts at either of the
    other islands.

b.  Boston.  The opposition of the City of
    Boston to the All Secondary Long Island and
    Split Deer/Long options and its lack of
    opposition to All Secondary Deer seriously
    affects "Implementability" of any Long
    Island plant site.  Both Deer Island and
    Long Island are within the corporate limits
    of the City and the City owns all of the
    Long Island site and necessary parcels on
    Deer Island, independent of whether the
    prison remains.  Boston states that it wants
    the Long Island Hospital to continue as its
    home for the chronically ill and as a refuge
    for the homeless.  EPA continues to believe,
    as expressed in the SDEIS that the hospital
    site must be used as part of the All
    Secondary Long Island and Split Deer/Long
    sites, if either is to be the choice, in
    order to avoid serious impacts to
    "Neighbors," "Harbor Vision" and "Cultural
    and Natural Resources."  Furthermore, Boston
    has declared its strong support that the
    remainder of Long Island should be an active
    part of the Boston Harbor Islands State
    Park.  Boston is opposed to Long Island's
    use as a treatment plant site.  Moreover,
    Boston has indicated to EPA its lack of
    opposition in principle to the transfer of
    lands needed for All Secondary Deer with or
    without the prison.

c.  Attitude of Agencies of the Commonwealth of
    Massachusetts.

    No agency of the Commonwealth supports a
    treatment plant on Long Island and some
    oppose it.  The MDC, in its Nut Island Site
    Options Study, the first phase facilities
    plan on which this FEIS based, proposes a
    large plant on Deer, and a small plant on
    Nut.  The Department of Environmental
                                                         61

-------
        Quality  Engineering  expresses  no
        preference.   The Massachusetts Historical
        Commission  is concerned  about  potential
        historic resources at  both  islands  and
        archaeological resources  on Long  Island.
        The Department of Environmental Management,
        which has authority  to veto land  transfers
        and construction of  structures at either
        island,  strongly favors  Long Island's use as
        a major  park.  The Governor, in a letter to
        the MWRA, does not express  a preference but
        pledges  his  support  to efforts to relocate
        either the  county prison  or the city
        hospital, depending  on which alternative the
        MWRA chooses.

        Legislative Approval.  The  SDEIS/EIR
        concluded that legislative  approval would be
        needed for  All Secondary  Long, but  might not
        be required  for All  Secondary  Deer.  Counsel
        for the  MWRA has determined that  it would be
        prudent  to  seek legislative approval
        whichever site is selected. EPA
        acknowledges that the  adamant  opposition of
        Boston and  Quincy to All  Secondary  Long and
        the absence  of any governmental support
        whatsoever  for Split Secondary Deer-Nut or
        Split Secondary Deer-Long casts doubt on the
        implementability of  these alternatives.
        Although it  is impossible at this time to
        predict  the result of  independent
        legislative  consideration of. the  merits of
        the sites,  it is the best judgment  of EPA
        that the remaining alternative, All
        Secondary Deer Island, is most likely to win
        legislative  approval.  Though  EPA believes
        federal  law  must be  complied with despite
        siting disputes, it  also  believes the
        current  violations of  federal  law would be
        corrected more quickly if a site  were chosen
        which would  be supported  by legislative
        approval.

        Summary  of  Implementability.  Thus  even
        prior to the July 10,  1985, vote  of the MWRA
        selecting All Secondary Deer Island as its
        tentative preferred  alternative,  EPA had
        concluded that under the  "Implementability"
        decision criterion the result  clearly
        pointed  to All Secondary  Deer  with  or
        without  the  prison.  The  July  10, 1985, vote
62

-------
of the MWRA, the proposing agency, which has
the statutory authority to build the
treatment plant and which controls almost
all of the land needed at Deer Island for
All Secondary Deer, confirmed EPA's already
firm conclusion that the All Secondary Deer
alternative was clearly more implementable
with or without the prison.


In summary, with mandatory mitigation,

    1.  EPA found Split Deer-Nut to be
        environmentally _unacceptable because of its
        severe impact on its "Neighbors" at Nut
        Island and on 'natural resources," and
        strong barriers to "Implementation."

    2.  EPA found Split Deer-Long to be
        environmentally acceptable; but EPA also
        found it to be undesirable because it
        spreads impacts on "Neighbors" and "Harbor
        Vision" to two islands without any benefit
        deemed valuable to a decision criterion.  It
        also was unlikely to be "Implemented."

    3.  EPA found both All Secondary Long and All
        Secondary Deer to have an acceptable impact
        on "Neighbors" and "Harbor Vision."

        a.  "Neighbors.'  With mitigation, the
            impact of a Deer Island plant on its
            "Neighbors" is either equal to (without
            the prison) or slightly worse than (with
            the prison) a Long Island plant.

        b.  Harbor Vision.  The impact of a Deer
            Island plant on the public benefits from
            and uses of Boston Harbor causes less
            harm than a Long Island plant.

Between these two acceptable and closely balanced
alternatives,  EPA acknowledges that building a
treatment plant on Deer Island (with or without the
prison) was clearly more implementable than building
a Long Island plant.
                                                      63

-------
VI. DECISION

With required mitigation as a condition of federal
funding, EPA's recommended FEIS decision based on
the foregoing analysis is that its preferred
alternative is All Secondary Deer.  All Secondary
Long is also environmentally acceptable and is
preferred over the two other alternatives, Split
Secondary Deer-Long and Split Secondary Deer-Nut.
The only alternative which EPA finds is unacceptable
is Split Secondary Deer-Nut.
VII.  COMPLETION OF BIS PROCESS

The  issuance of this FEIS starts another phase of
environmental review.

After a public hearing process and public comment
period, EPA will issue its final record of decision
on the siting of wastewater treatment works for
Boston Harbor.
64

-------
appendices

-------
APPENDIX A
HEADWORKS

Several of the alternatives described in this EIS
call for the reconstruction of an existing primary
treatment facility to a "headworks."  At Nut Island,
this change would include demolition of most of the
existing plant except for the chlorination facility
now under construction and connection of the site to
the new wastewater treatment plant, probably by
tunnel.

At Deer Island, this change would be similar but it
would include retention of the existing pumping
station and, probably, a new disinfection facility
at the influent end of the tunnel to Long Island.

Neither of these prospective changes has raised, nor
is expected to raise, any significant controversy,
in large part because they represent reductions in
the overall size of wastewater treatment facilities
at their respective locations.

It should be noted, however, that neither is without
adverse effect during construction or without the
potential for adverse effect afterward.

During construction, demolition of existing
facilities would generate significant levels of
noise, generally, about 10 decibels higher than
those estimated in the SDEIS, while the demolition
and the digging of the tunnels would generate spoils
that may require disposal off-site.

The high noise levels of demolition are likely to be
of fairly short duration and hence are not
unacceptable.  However, because they are expected to
be briefly high, a mandatory mitigation measure
requires the scheduling of construction activities
to reduce the number of high intensity activities
operating simultaneously near the affected homes.

The construction and tunnel wastes, if removed over
the road, over a 4-year period would generate an
average of 10 truckloads per day, a slight to
moderate impact.

Following construction, the only significant effects
of this much smaller facility are possible odor and
the possible hazard of liquid chlorine.  These
issues, as they affect the relatively smaller
headworks are not site-relevant to the siting of the
major treatment works, and will be the subject of
further studies by the MWRA.
                                                             65

-------
APPENDIX B
PRIMARY TREATMENT ALTERNATIVES

The Clean Water Act requires that wastewater
treatment plants be constructed which will provide
"secondary" treatment unless EPA, under strict
statutory guidance, grants a 301(h) waiver
permitting a lesser "primary" degree of treatment
with a deep ocean discharge.  EPA has twice denied
the MCD's request for such a waiver but because
final rights of appeal have not expired EPA has
decided in this FEIS to resolve, under NEPA the
siting of a primary treatment plant as well as the
siting of a secondary treatment plant.  The
following discussion will examine the impacts of a
primary treatment facility.

The treatment facilities in all primary alternatives
would be limited to simple sedimentation, the
process now in use at Deer and Nut Islands, but
would differ from the existing facilities in two
important characteristics, i.e., the sedimentation
tanks would be enlarged, increasing the settling
time and, as a result, the percentage of solids
removal, and the settled sludge would not be
discharged to the harbor, or to any other nearby
waterbody under any circumstances.

Though a modern primary treatment plant for Boston
Harbor would be half the size of a new secondary
plant, it would still be twice the size of the
existing Deer and Nut Island facilities, and would
total approximately sixty acres of treatment works.
This would be a major public works project requiring
the same scale of mandatory mitigating measures as
have been adopted for a secondary plant.  It would,
as a result, not substantially differ in impact from
a secondary plant.  Principal differences would
occur in a somewhat shorter construction period,
somewhat fewer construction worker buses, reduced
air emissions of volatile organic compounds, and
less land used, potentially reducing conflict with
other plans such as recreation.  Other impacts such
as construction noise and odor are essentially
equivalent to a secondary plant.  The matrix
attached displays the details of the impacts.

Though the reduced acreage may appear to give some
opportunities for mitigation by permitting location
of the smaller plant away from its neighbors, it
must be remembered that any 301(h) waiver under the
66

-------
Clean Water Act permitting primary treatment is
temporary and conditional; therefore a primary plant
must be conceptually considered as the -first phase
of an eventual secondary plant.  Thus, the impact
conclusions used in analyzing a secondary plant
remain relevant here.

EPA did evaluate, following its secondary treatment
analysis, and using a similar process, four primary
treatment options:

                  All Primary Deer
                  All Primary Long
               Split Primary Deer-Nut
               Split Primary Deer-Long

    1.  EPA concluded that Split Primary Deer-Nut
        was environmentally unacceptable for the
        same reason Split Secondary Deer-Nut was
        unacceptable — it caused severe impact to
        "Neighbors," "Harbor Vision," and
        "Implementability" at Nut Island without
        reducing impact elsewhere or benefiting
        another decision criterion.

    2.  EPA concluded that Split Primary Deer-Long
        (with the hospital remaining) was
        environmentally acceptable under "Neighbors"
        and "Harbor Vision" but unlikely to be
        implemented.  Again, impacts were spread to
        a second island without any appreciable
        reduction of impact at Deer Island or
        benefit to another decision criterion.  This
        option also had no support.

    3.  EPA concluded that All Primary Long (with
        the hospital remaining) was environmentally
        unacceptable and unlikely to occur.  A sixty
        acre treatment works immediately bordering a
        chronic disease hospital and in direct
        conflict with plans of all governments was
        in severe conflict with the "Neighbors,"
        "Harbor Vision," and "Implementability"
        decision criteria.  Any site analysis which
        assumes the hospital would be removed faces
        essentially the same severe difficulties of
        implementability as the All Secondary Long
        alternative, though it is environmentally
        acceptable under the "Neighbors" and "Harbor
        Vision" and other decision criteria.
                                                             67

-------
    4.  For reasons of "Implementability," EPA
        concluded that, unless there were some
        compelling other reason, its approval of a
        primary treatment plant site should be
        consistent with its approval of a secondary
        treatment plant site at Deer Island.
        Because a 301(h) waiver grants only
        temporary relief from the Clear Water Act's
        requirement of secondary treatment, it is
        prudent to site a 301(h) primary plant at a
        location which will permit eventual
        expansion to secondary treatment, if
        required, without causing unconsidered harm
        to decision criteria.  Furthermore, EPA felt
        there was a short-range "Implementability"
        advantage to having a common island site
        selected for primary and secondary treatment
        plants, for it permitted facilities planning
        and design to proceed without distraction.
        For reasons similar to its decision for All
        Secondary Deer, EPA found All Primary Deer
        to be acceptable under "Harbor Vision,"
        "Neighbors" and "Implementability."

    5.  Thus, EPA concluded that All Primary Deer
        Island was its preferred primary treatment
        alternative.  All Primary Long (without
        hospital) and Split Primary Deer-Long are
        environmentally acceptable.  Split Primary
        Deer-Nut is environmentally unacceptable.
68

-------
APPENDIX C
PRINCIPAL RELEVANT IMPACTS FOR EACH DECISION
CRITERION

1.  Implementability

    a.  Attitude of public owner(s) of needed
        property.
    b.  Liklihood of legislative approval.
    c.  CZM/DEM consistency.
    d.  Corps/DEQE wetlands permits
    e.  Mass Historic Commission et. al. re:
        archaeology/cultural/graves
    f.  Conflict with or need to relocate hospital
        and/or prison.
    g.  (In case of primary plant) compatibility of
        site with site chosen for secondary
        treatment.

2.  Effects on Neighbors

    a.  Years of construction
    b.  Daily construction traffic
    c.  Operations traffic
    d.  Construction noise
    e.  Odo r
    f.  Visual
    g.  Pathogenic aerosols
    h.  Chlorine transportation and use
    i.  Volatile organic compounds

3.  Harbor Vision

    a.  Preserves a significant opportunity on an
        island NOT the site of a treatment plant.
    b.  Permits significant opportunities for
        multiple use on the treatment plant
        is land(s).
    c.  Harbor-wide visual impacts.

4.  Cost

    a.  Capital
    b.  Operation, maintenance, and replacement.

5.  Reliability — no difference in impact.
                                                             69

-------
6.  Effect on Natural and Cultural Resources

    a.  Wetlands
    b.  Barrier beaches
    c.  Historic sites
    d.  Archaeological sites
    e.  Graves
70

-------
APPENDIX D
ADDITIONAL ENVIRONMENTAL REVIEW RELATING TO BOSTON
HARBOR CLEANUP

EPA'anticipates that further environmental review
relating to the cleanup of Boston Harbor will
consist of study of the following items:

1.  Sludge disposal

2.  The construction of piers and staging areas at
    the treatment plant site to allow for barging of
    bulk construction materials, equipment, and work
    crews during construction.   In the event that an
    existing pier cannot be located on the mainland,
    an additional pier or piers and staging area or
    areas would need to be constructed there.

3.  The construction of an under-harbor tunnel or
    pipeline to transport wastewater, sludge or
    effluent from one island to another, depending
    upon the location of the secondary treatment
    plant site and associated headworks.

4.  The construction of an outfall pipe or pipes
    through which effluent will be discharged.

5.  The possible disposal of earthen or dredge
    materials which might need to be removed from
    the site of the secondary treatment plant prior
    to construction.

6.  The possible transport, handling, storage, and
    use of chlorine at the secondary treatment
    plant, depending upon the outcome of studies by
    MWRA regarding the environmental acceptability
    of its transport, handling, storage and use.

7-  Combined sewer overflow projects.
                                                             71

-------
                                                      SUMMARY OP MITIGATED  IMPACTS OF  SECONDARY  TREATMENT
UASTEWATER TREATMENT PLANT ACREAGE

YEARS OP CONSTRUCTION
WORK FORCE
1. Construction (avg/peak)
2. Operations (total/peak shift)

TRAFFIC, Construction
1. Trucks (avg/day) with barging
2. Buses (avg/peak day)
3. Impact Assessment (avg/peak)


NOISE, Construction (long term)
1. Nearest Residence dBa (LlO)
   Impact Assessment
2. Prison
   Impact Assessment

ODOR (with mitigation)
1. Nearest Residence
2. Prison

VISUAL IMPACTS

RECREATION
1. Existing Facilities
2. Planned Facilities
 3. Open Space/Recreational
    Potential
CULTURAL
1.  Historical Resources
    Impact Assessment
 2. Documented Archaeological
   Resources Affected
 ENVIRONMENTALLY SENSITIVE AREAS
COSTS
1. Construction  (million dollars)
2. Operation, Maintenance and
    Replacement  (million dollars)
All Deer Island Split
Deer Nut
115-140 2
7 3-4
650/1300 50/75
200/100 20/10
8 8
13/26 1/2
Slight/ Slight
moderate
59-63
Slight •
69-75
Moderate
Slight Slight
Moderate
Severe Slight
None None
No active No plans
plans
Loss of Potential
long-term local open
park space
potential benefit
Pump None
house;
poten-
tially
prison
Possible
adverse
impact
None None
No effect No effect
1135
50
Deer Island/Nut Island
Deer Nut
115-140 18
7 5
650/1300 100/125
200/100 100/50
8 4
13/26 2/3
Slight/ Slight
moderate
59-63
Slight •
69-75
Moderate
Slight Moderate
Moderate
Severe Severe
None None
No active No plans
plans
Loss of Loss of
long-term local open
park space
potential potential
Pump None
house;
poten-
tially
pr ison
Possible
adverse
Impact
None None
No effect Requires
filling bay
1285
50
                                                                                             All Long Island
Deer
5
5
Nut
2
3-4
Long
115-140
8-9
                                                                                                                          Split Deer  Island/Long  Island
75/100
40/20


8
2/2
Slight
          50/75
          20/10
          8
          1/2
          Slight
59-63
Slight    *
69-75
Moderate


No effect Slight
Slight
                    650/1300
                    200/100


                    8
                    13/26
                    Slight/
                     moderate
                    No effect

                    No effect

                    Slight
Slight
          Slight
                    None
                    Severe
                     conf1ict
                     w/draft
                     plans
Potential Potential Total loss of
None      None
No active No plans
 plans
 recrea-
 tion
 benefit
           local
           open
           space
           benefit
None
          None
                                                                                                             immediate
                                                                                                             park
                                                                                                             potential
                    Grave sites
                     It Civil War
                     cemetery;
                     potentially
                     hospi ta 1
                    Possible
                     adverse
                     impact

                    None
No effect No effect No effect
            1180

              50
Deer

52

5-6


300/400
100/50


6
6/9
Slight
                                    59-63
                                    Slight
                                    69-75
                                    Moderate
Hut

2

3-4

50/75
20/10

a
1/2
Slight
650/1300
200/100

8
13/26
Slight/
 moderate
                     No effect

                     No effect
           Slight    Slight

Moderate   Slight    Severe
                                    Slight
                                    Moderate
                                    None
                                    No active
                                     plans
                                    Partial
                                     loss of
                                     park
                                     potential
                                                                                                                            Poten-
                                                                                                                             tially
                                                                                                                             pr ison
                                    Possible
                                     adverse
                                     impact

                                    None
                                    No effect
 •Unmitigated noise during the brief period of demolition during construction of the Nut  Island  headworks  could  approach  82  dba
  homes.  MWRA  is required to develop a mitigation plan which will include the scheduling of  noisy activities  to reduce  impact.
           None      None
           No plans  Severe
                      conf1ict
                      w/draft
                      plans
           Potential Total loss
            open      of immedi-
            space     ate park
            benefit   potential
                                               None      Grave sites
                                                          t Civil War
                                                          cemetery;
                                                          potentially
                                                          hospital
                                                         Possible
                                                          adverse
                                                          impact

                                               None      None
                                               No effect No effect
                                                  1365

                                                    50

                                               at the nearest

-------
                                                       SUMMARY OF MITIGATED IMPACTS OP PRIMARY TREATMENT
HASTEWATER TREATMENT PLANT ACREAGE  62

YEARS OP CONSTRUCTION
WORK FORCE
1. Construction (avg/peak)
2. Operations (total/peak shift)
TRAFFIC, Construction
1. Trucks (avg/day) with barging
2. Buses (avg/peak day)
3. Impact Assessment (avg/peak)
NOISE, Construction (long term)
1. Nearest Residence dBa (L10)
   Impact Assessment
2. Prison
   Impact Assessment
ODOR (with mitigation)
1. Nearest Residence
2. Prison

VISUAL IMPACTS
RECREATION
1. Existing Facilities
2. Planned Facilities
3. Open Space/Recreational
    Potential
CULTURAL
1. Historical Resources
   Impact Assessment
2. Documented Archaeological
   Resources Affected

ENVIRONMENTALLY SENSITIVE AREAS
COSTS
1. Construction (million dollars)
2. Operation, Maintenance and
    Replacement (million dollars)
All Deer Island Split Deer Island/Nut Island
Deer
62
5-6
590/655
136/66
7
12/13
Slight/
slight
59-63
Slight
69-75
Moderate
Slight
Moderate
Nut
2
3-4
55/70
20/8
8
2/2
Slight/
slight
*
Slight
Deer
52
5-6
305/465
118/53
6
6/10
Slight/
slight
59-63
Slight
69-75
Moderate
Slight
Moderate
Nut
18
5
95/125
83/37
4
2/3
Slight/
slight
•
Moderate
All
Deer
52
6
305/430
118/53
6
6/10
Slight/
slight
59-63
Slight
Moderate
Long Island
Nut
2
3-4
65/75
20/8
8
2/2
Slight/
slight
*
Slight
Long
18
6
190/245
63/28
4
4/5
Slight/
slight
No effect
Slight
Split Deer Island/Long Island
Deer
5
5
85/100
34/14
8
2/2
Slight/
slight
59-63
Slight
69-75
Moderate
No effect
Slight
Nut
2
3-4
65/75
20/8
a
2/2
Slight/
slight
*
Slight
Long
52
7
675/750
102/46
6
14/15
Slight/
slight
No effect
No effect
Slight
Moderate w/
hospital
                                    Moderate
                                                Slight
                                                              Moderate   Severe
                                                                                        Moderate   Slight    Moderate
                                                                                                                           Slight
                                                                                                                                      Slight
None
No active
plans


Some loss
of park
potential

Pump
house;
poten-
tially
prison
Possible
adverse
impact
None
No plans



Potential
open
space
benefit
None







None
No active
plans


Some loss
of park
potential

Pump
house;
poten-
tially
prison
Possible
adverse
impact
None
No plans



Loss of
open
space
potential
None







None
No active
plans


Some loss
of park
poten-
tial
Pump
house;
poten-
tially
prison
Possible
adverse
impa ct
None
No plans



Potential
open
space
benefit
None







None
Slight
conflict
w/draft
plans
Minor loss
of park
resource
potential
None affected







None
No active
plans


Potential
recre-
ation
benefit
None







None
No plans



Potential
open
space
benefit
None







None
Moderate
conflict
w/draft
plans
Small loss
of park
resources

Grave sites
t Civil War
cemetery;
potentially
hospital
Possible
adverse
impact
                                    None        None
                                    No effect   No effect
                                             1090

                                               34
No effect  Requires
            filling bay


         1230

           34
                          None       None       None  affected
                          No effect  No  effect  No effect
1365

  34
                        None        None       None
                        No  effect   No  effect  No  effect
1285

  34
 •Unmitigated noise during the brief period of demolition during construction of the Nut Island headworks could approach  82  dba  (L10)  at  the nearest
  hones.  MHRA is required to develop a mitigation plan which will include the scheduling of noisy activities to reduce impact.

-------
list of prcparcrs and reviewers

-------
LIST OF PREPARERS AND REVIEWERS
U.S. Environmental Protection Agency (EPA). Region I:  Preparation of Final
Environmental Impact Statement prior to authorization of expenditure of
federal funds.

Ron Manfredonia, Chief, Environmental Evaluation Section, Project Officer
Robert Mendoza, Boston Harbor Coordinator, Water Management Division
Kathleen Castagna, Project Monitor, Environmental Evaluation Section
Steve Ells, Policy Review and Guidance, Office of Governmental Liaison and
     Environmental Review
Donald Porteous, Chief, Water Quality Branch
Richard Kotelly, Deputy Director, Water Management Division
David Fierra, Director, Water Management Division
Cynthia Greene, Air Management Division
Dorothy Allen, Environmental Evaluation Section
Paul Marschessault, Southern N.E. Grants Section
Jeffrey Fowley, Attorney, Office of Regional Counsel
David Gravallese, Attorney, Office of Regional Counsel
Steven Koorse, Attorney, Office of Regional Counsel

U.S. General Services Administration, Region I:  Cooperating Agency

Massachusetts Water Resource Authority (HWRA), Boston MA:  Project proponent
and facilities operator; sponsor of State EIR.

Thibault/Bubly Associates, Providence, RI:  Environmental consultants to EPA,
Region I.

Daniel Bubly, P.E., A.I.C.P., L.A., Project Manager
James Thibault, P.E., M.S.C.E., Project Management
Richard Hittinger, M.S., Project Director
Randel Stong, M.S., Air Quality Specialist
Janet Hutchins, B.S., ASLA, Technical Writer/Editor, Graphics, Contract
     Administration
Michael Hester, B.A., Technical Writer
Gloria Bubly, B.S., Graphics
Dale Raczynski, B.S., Engineer
Andrew Konnerth, B.S.M.E., Environmental Engineer
Victoria Hittinger, M.S., Toxicologist
Robert Ferrari, P.E., Environmental/Sanitary Engineer
Richard Beach, M.S., Water Quality Specialist
Peter Bates, M.S., Computer Modelling
Glenn Almquist, B.S., Water Quality Specialist
Brenda Enos, B.S., Water Quality Chemist
Ralph Penney, M.S., Engineer
Mary Louise Keefe, Technical Assistant
David Martin, Technical Assistant

-------
 LIST OP PREPARERS AND REVIEWERS (cont'd)

 Subconsultants to Thibault/Bubly Associates

 Barry Lawson Associates, Concord,  HA:  Public Participation  Program;  Preparers
 of Vol. Ill and Vol. IV

 Barry Lawson, Ph.D., President
 Ann Jacobson, Public Participation Coordinator
 Edward lonata, Public Participation Coordinator

 Robert Weygand & Associates, Rumford, RI:   Visual  Quality  Analysis

 Robert Weygand, AS LA, APA, Principal

 Lee Pare & Associates, Inc., Pawtucket, RI:  Pier  Facility Feasibility  Study

 Robert L.  Pare, P.E., President
 Ernest Rabideau, P.E., Engineer
 Richard Casella, P.E., Engineer

 Crossman Engineering, Inc., Pawtucket, RI:   Traffic  Assessment

 E. Raymond Crossman, P.E., President

 C.E. Haguire, Inc.,  Providence, RI:  Supplemental  Draft EIS

 Abt Associates. Inc., Cambridge, MA;  Social and Economic  Analyses

 Peter Wolff, PhD., Project Director
 David Berry, PhD., Technical Director
 Richard Wells, Manager of Environmental Research
 A. Stoeckle, Analyst
 M. Heissberg, Analyst
 John Reinhardt, Analyst
 R. Roethlisberger, Analyst

 New England Environmental Mediation Center,  Boston,  MA

 William Humm,  Executive Director

 Warner & Stackpole,  Boston, MA: Legal and  Institutional Analysis

 Michael Leon,  Attorney

 Verbatim Word Processing Services,  Providence, RI:   Word Processing

 Joshua Bell
 Lynne Bell

 Other Subconsultants

 David Stong,  Ph.D.,  Toxicologist:   Air Toxics
 Dr.  K.  Keshavan,  P.E.;   Alternative Treatment Technologies
 Dr.  F.  L. Hart,  P.E.:   Alternative  Treatment Technologies

Camp,  Dresser,  and HcKee,  Inc.,  Boston, MA:  Consultants to the MWRA

Subconsultants  to Camp,  Dresser, and  McKee
Boston Affiliates, Inc.
Cavanaugh Tocci Associates,  Inc.
The Public Archaeology  Laboratory,   Inc.

-------

-------
                      /INTERNATIONAL
 mr&m
  k^-;*-- ..-/-^i

  >S-A ^-g^v^L-a^
.Y>?4!Kt'.- -2US ,•

-------