VOLUME II

           TECHNICAL EVALUATIONS

         Final Environmental  Impact Statement

                        SITING
                             of
                  WASTEWATER
         TREATMENT FACILITIES
                            for
                BOSTON HARBOR
                                      t

                          Prepared by:
                        UNITED STATES
                ENVIRONMENTAL PROTECTION AGENCY
                           REGION I
                       Techjuca] Assistance by:
                    THIBAULT .' BUBLY ASSOCIATES
                    PROVIDENCE, RHODE ISLAND
^
  o
           MICHAEL P. 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 Genera.! 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 i-.-.~ •". «tate water
pollution control laws.

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                        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 acceptability of
                             alternative locations for the construction of new
                             wastewater treatment facilities for Boston Harbor.  The
                             FEIS recommends the construction 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
                             J.F.K.  Federal Building, Boston, Massachusetts 02203
COOPERATING AGENCY:
                             GENERAL SERVICES ADMINISTRATION
TECHNICAL CONSULTANT:
                             THIBAULT/BUBLY ASSOCIATES
                             235 Promenade Street, Providence, Rhode Island 02908
FOR FURTHER INFORMATION:
                             Mr. Ronald Manfredonia, Water Management Division, U.S.
                             EPA, Region I, J.F.K. Federal Building, Boston,
                             Massachusetts, 02203
                             (617-223-5610)
FINAL DATE BY WHICH
'COMMENTS MUST BE RECEIVED:

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                                  VOLUME II

                    Final Environmental Impact Statement

                            Technical Evaluations


I. Introduction

This document, Volume II of  the Final Environmental  Impact Statement  (FEIS)
on the Siting of Wastewater  Treatment Facilities in  Boston Harbor,  is one of
four volumes prepared to:

    respond to comments raised on the Supplemental Draft  Environmental  Impact
    Statement published on December  31,  1985,

    meet EPA's obligations under the National  Environmental  Policy  Act  (NEPA).

The other volumes of the FEIS are:

    Volume I    Comprehensive Summary

    Volume III  Public Participation and Response to Comments

    Volume IV   Public and Interagency Comments

Volume II of the FEIS contains technical reports on  analyses conducted
subsequent to the publication of the SDEIS.  EPA received numerous  comments
on the analyses contained in the SDEIS on  Siting of  Wastewater  Treatment
Facilities in Boston Harbor.   After  a careful  review of all  comments  received
(written and oral) the Agency developed  a  list of issues  which  required
further technical review and analysis.   (See Volume  III for  a summary of all
issues raised during the comment period  on the SDEIS).

Each of the technical evaluations in Volume  II begins with a summary  of the
issues requiring additional  work by  EPA  or the MWRA  for the  FEIS or FEIR.
Technical information contained in this  volume is the result of joint efforts
by EPA, the MWRA and their consultants.

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                                  VOLUME II

                            Technical Evaluations


                              TABLE OF CONTENTS
II-l   Traffic and Transportation
       A.  Background
       B.  Baseline Conditions
           1.  Deer Island
           2.  Long Island
           3.  Nut Island
       C.  Mitigation
       D.  Forecasts

       Appendix T-l:  Costs of Alternative Transportation of Construction
                      Workers

       Appendix T-2:  Potential Barge Transfer Stations

       Appendix T-3:  Feasibility Study:   Pier Facilities for Water
                      Transport of Construction Labor and Materials
                      to Deer Island and  Long Island, Boston Harbor,
                      Massachusetts

II-2   Odors
       A.  Background
       B.  Existing Conditions
           1.  Brief Literature Survey
           2.  Wastewater Characteristics and Collection System
       C.  Projected Conditions
           1.  Model Assumptions
           2.  Results and Discussion
       D.  Mitigation

       Appendix 0-1:  Mitigation Cost Estimates

II-3   Noise
       A.  Background
       B.  Baseline
       C.  Impacts
       D.  Mitigation

11-4   Recreation
       A.  Background
       B.  Comparison of Recreational Resources on Deer Island  and
           Long Island

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II-5   Legal and Institutional
       A.   Background
       B.   An Analysis of the Massachusetts Water  Resources  Authority
           Act and Its Application to the  Acquisition  and  Development
           of the Long Island and Deer Island  Alternatives
             I.  Introduction
            II.  Statement of Facts
           III.  Discussion
                 A.  General Structure of  the  Authority
                 B.  Limitations  on the Actions  of the Authority
                 C.  Prior Public Use Doctrine
                 D.  Article 97 of the Massachusetts Constitution
                 E.  Applicability of Chapter  742  of the Acts  of 1970
                 F.  Power to Acquire Property by  Eminent  Domain
                 G.  Power to Acquire Land by  Other than Eminent Domain
                 H.  Power to Relocate Property
                 I.  Relocation of Long Island Hospital
                 J.  Massachusetts Department  of Capital Planning  and
                     Operations Jurisdiction
                 K.  Other Statutory and Regulatory Impediments to
                     Facility Construction and Operation

            IV.  Conclusion

II-6   Air Toxics
       A.   Background
       B.   Executive Summary and  Conclusions
       C.   Suggestions for Future Assessment
       D.   Raw Data
       E.   Air Monitoring
       F.   Virtual Safe Dose
       G.   Limitations
       H.   Projected Annual Average Ground Level Concentrations
       I.   Assessment of the Annual Average Ground Level Concentrations
       J.   Risk Evaluation
       K.   Ozone
       L.   Controls

       Appendix AT-1:  Categorization of Overall Evidence

II-7   Water Quality Outfall Evaluation
       A.   Background
       B.   Outfall Location Evaluations

II-8   Cost Estimates
       A.   Background
       B.   New Estimates

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II-9   Facilities Layout Scenarios
       A.  Background
       B.  EPA Facilities Layout Studies
       C.  MWRA Facilities Layout Studies

11-10  Historical and Archaeological
       A.  Background
       B.  Management Survey:   An Archaeological  Reconnaissance  Survey
           of the Deer Island  Corrections Facilities
       C.  Memorandum:  Historic Survey of the Deer  Island  House of
           Correction and the  Deer Island Pumping Station

11-11  Chlorine Use Risk Evaluation
       A.  Background
       B.  Safety Evaluation
       C.  Modeling and Analysis of Potential  Chlorine  Hazard
       D.  Implications of Hazard Analysis for Siting of the Proposed
           Treatment Plant
       E.  Conclusions

11-12  Sludge Management Facilities
       A.  Background
       B.  Information on Sludge Processing in the SDEIS/R
       C.  Sludge Processing Units

11-13  Disposal of Properties  on Deer  Island by GSA
       A.  Background
       B.  Need for Action
       C.  Disposal Alternatives
       D.  Alternative Land Use's and Impacts
       E.  Preferred Alternatives
       F.  Memorandum of Agreement

11-14  Property Values
       A.  Background
       B.  The Impact of Sewage Treatment Plants  on  Local Property
           Values:  A Literature Survey
            I.  Overview
           II.  Findings

11-15  Airborne Transport of Pathogenic Organisms
       A.  Background
       B.  Conclusions
       C.  Aerosols from Activated Sludge Plants
       D.  Study of Microbial  Aerosols Emitted from  a Water
           Reclamation Plant
       E.  Effect of an Activated Sludge Wastewater  Treatment  Plant
           on Ambient Air Densities of Aerosols Containing  Bacteria
           and Viruses
       F.  Health Risks of Human Exposure to Wastewater
       G.  Wastewater Aerosols and Disease

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11-16  301(h)  Technical Decision
       A.  Technical Summary:   Revised  Application  for  Section  301(h)
           Modification, Metropolitan District  Commission, Boston,  MA

11-17  Draft NPDES Permit
       A.  Fact Sheet
       B.  EPA National Policy on Permit  Limitations  for  Toxic  Pollutants
              REPORTS PRINTED SEPARATELY  AND  AVAILABLE  FROM  EPA

  Report on Alternative Technologies  Potentially  Applicable  to Boston  Harbor
  Wastewater Treatment Facilities to  Reduce Facility  Size  (June  1985)

  Assessment of Volatile Organic  Compound Emissions'  Impact  on the  Siting  of
  a New Boston Wastewater Secondary Treatment Facility  —  Methodology  Report
  (September 1985)

  Interim Systems for the Transportation  of Sludge from Deer and Nut  Islands,
  Exploration of Alternatives:  Their Technical Feasibility  and  Costs
  (August 1985)

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	II-1
traffic and transportation

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II-l  TRAFFIC AND TRANSPORTATION


    A.  Background

        Comments on traffic  and transportation centered on three areas:

        1.   Were the existing conditions of the roadways to each of the
            alternative sites fairly and accurately described in the SDEIS?

        2.   Were the proposed mitigating actions designed to reduce projected
            traffic volumes  feasible?

        3.   Could over-the-road traffic be reduced even further than proposed
            in the SDEIS?

        4.   Were the forecasts of induced traffic remaining after
            implementation of the proposed mitigating actions reasonable
            estimates?

        Review of traffic and transportation, since receipt of comments
        indicates that  existing conditions, at least on the access roads to
        Deer Island through  Winthrop, East Boston, and Revere, are more severe
        than previously estimated.  However, the review also indicated that a
        greater percentage of the total traffic could access the construction
        sites by water  than  previously estimated, so that there could be even
        less traffic on the  local streets.  As a result, it was concluded that
        the proposed project would not add significantly to existing traffic
        problems.

    B.  Baseline Conditions

        The questions on existing roadway conditions centered primarily on
        access to the Deer Island site and included:  What routes would be
        used for access between the proposed sites and the regional expressway
        network?  Are there  truck restrictions?  Are there safety problems?
        Congestion?

        1.   Deer Island
            As  shown  on  Fig. T-l, all traffic access to expressways from Deer
            Island must  flow through the town of Winthrop using the town's
            network of residential and local commercial streets.  It can leave
            the town  by  only two exit roads, one along Short Beach into
            Revere, and  the other across the Belle Isle inlet into East
            Boston.   By  either route it is possible, by traversing residential
            areas in  Revere and/or East Boston, to reach either the Northeast
            Expressway in Chelsea or the central artery in downtown Boston.

            All automobile and small to medium truck traffic to the southern
            and western  portions of the metropolitan area would leave Winthrop
                                                                        Traffic - 1

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      •figure T- I  MC£X>-n PSe^ liLAWP
Traffic - 2

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via Main Street to Saratoga and Bennington Streets  in  East  Boston,
the East Boston Expressway, the Stunner Tunnel,  the  Central  Artery
and, from there, either the Southeast Expressway to the  south, or
the Massachusetts Turnpike to the west.  The heavy  truck traffic
would use Winthrop and Crescent Avenues through Beachmont to
Revere, to the Revere Beach Parkway,  the Northeast  Expressway, the
Mystic River Bridge, and the Central  Artery.

Light vehicle traffic to the northern metropolitan  area  from
Winthrop would traverse Saratoga Street to Boardman Street, then
follow Route 1A (McLellan Highway)  through Mahoney  (Bell) Circle
to Route 60 and ultimately to Route 1 in Saugus.  Alternate routes
to the north include the Winthrop Parkway to the Revere  Beach
Boulevard to Lynn, or Winthrop Avenue to the Revere Beach Parkway
and thence to Mahoney (Bell) Circle.

Most of the routes to Deer Island have some sort of truck
restriction, including weight limits  in the Sumner  Tunnel and on
most of the bridges, and a general  truck and bus exclusion on
Winthrop Parkway and the Revere Beach Boulevard in  Revere.  The
only route that appears to be entirely without  any  specific
restriction is fairly complicated,  by way of Winthrop  and Crescent
Avenues in Revere, both medium to high density  residential
streets, to Route 1A, then south to a jug handle turn-around at
the Revere/East Boston city line, then north back up Route  1A to
Bell Circle, around the Circle and  then back south  again and
finally west on the Revere Beach Parkway to the Northeast
Expressway.

As shown on Fig. T-2, these routes  include a number of safety
deficiencies, especially in Winthrop  and the Beachmont section of
Revere.  In a number of areas, the  routes traverse  narrow,
lightly-used, residential streets.   In such areas,  it  is difficult
for small children (a new crop of four-year-olds every year) to
recognize the hazard of running out into the streets and it is
difficult, without congestion, to keep all non-residents from
speeding through to and from their  places of employment.  Specific
areas of this hazard potential include Point Shirley and Beachmont
in particular.

Other hazard areas that appear to be  especially dangerous include
Shirley Street between Washington Avenue and Yirrel Beach and the
intersection of the East Boston Expressway ramp and Neptune Road
in East Boston.

On Shirley Street the problem is extremely short sight distance,
especially at the corner of Park Terrace opposite the  Winthrop
Yacht Club, complicated by a road curve so tight that  vehicles
have trouble staying in their own lanes, while  at Neptune Road,
traffic northbound to Winthrop, off the expressway  must  cross a
stream of very fast moving vehicles exiting the airport  around a
blind corner.
                                                            Traffic - 3

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           ROAD FROM DEER  ISLAND
           Single  lane  on  ramp  to  Central  Artery  Southbound
           ROAD TO DEEK ISLAND

           Taxi from Logan Airport, cutting across expressway  just  before  Neptune
           J-'.oac3 of f r amp.
Traffic •  J

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 ROAD TO DEE* ISLAND
 Orif'-way portio.-i of Tafts Avenue  at  local business area
ROAD TO  DF.EU  ISLAND
Twr>-w.iy  port ion  of  T;ift:.s Avenue;  No parking <•!'(>.•:  ..•;.!.•.
                                                                            Traffic -  5

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Traffic - 6

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In addition, it must be noted that the entire town of Winthrop is
accessible by only two two-lane roadways (one of which is closed
during' severe storms) and that the Point Shirley neighborhood is
accessible by only one roadway, conditions that could severely
compromise the ability of emergency services to perform their
functions (say if an airplane were to crash on Point Shirley) and
the ability of those services to evacuate threatened areas in the
case of toxic chemical spills.

And finally, fig. T-3 shows the most seriously congested and/or
constricted areas along the access routes,  routes travelled daily
by the residents of Winthrop, East Boston and Revere.
                                                             Traffic  -  7

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              ROAD  TO DEER ISLAND


              Shirley just south of  Washington  Avenue.   Left  turning automobile
in
                     L a TV .
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                                                          r-tr-Site-ffiiiiftsK, Sscs»f»-,ri _„, B _ . c __
Traffic

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On a local level the existence of congestion and/or constrictions
is attested to by the number of one way streets and the extensive
prohibition of parking along the "major" roadways.  Areas to be
noted include:

a.  Tafts Avenue in Point Shirley which is one way in one area to
    allow traffic to pass local business and "no parking" on both
    sides elsewhere to allow two vehicles to pass each other.

b.  Shirley Street north of Washington Avenue, again local
    business and narrow street.

c.  Winthrop Avenue in Beachmont, again local business and narrow
    streets.

On a somewhat larger scale of problem, special note must be made
of the intersection of Shirley Street, Washington Avenue and
Veterans Road, an offset intersection so narrow, with turning
radius so small that when it is occupied by a single MBTA bus, the
intersection is effectively full.

On a townwide basis, note should also be made of the problems on
Saratoga Street in East Boston.  This roadway is the most heavily
used accessway to the town of Winthrop and it is essentially
unavoidable in most of the comings and goings into and out of
Winthrop.  It is only two lanes wide, has parking on one side,
businesses (with poorly parked delivery trucks) near its
intersection with Bennington Street, and an MBTA train station
that generates peak bus and peak commuter parking lot cross
traffic at peak hours.

At morning rush hours, the traffic signal at St. Edwards Street
(the entrance to the commuter parking lot) can back traffic up
Saratoga Street, across the Belle Isle Bridge, through the
intersection of Pleasant Street and well onto Main Street, in all,
a full mile of stop and go congestion.
 In  the  afternoon,  no  similar  back  ups  were  observed  on
reconnaissance trips but  observation  of the  signal  at St.  Edwards
 Street  indicated  that its  green  time eastward  was  almost  fully
 utilized.

 And finally,  moving closer to Boston,  it  should  be noted  that all
 traffic from  Winthrop to the  southern  and western  portions  of the
 metropolitan  area must traverse  the  Sumner  Tunnel  and the Central
 Artery.  Access  to both  is chronically congested and beyond hope
 of  correction without a  direct harbor  tunnel  to  the  Massachusetts
 Turnpike.
                                                             Traffic - 9

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               2.  Long Island

                  From Long  Island,  all  automobile  traffic  can  reach  the  Southeast
                  Expressway near Neponset Circle by  roads  that,  for  the  most  part,
                  are non-local  and  non-residential  (see  Figure T-4).   These  include
                  the Long Island Bridge, Moon  Island Causeway, Dorchester  and East
                  Squantum Streets in  Squantum  (housing on  one  side only,  for  only
                  half their combined  length),  and  Morrissey  Boulevard, a heavily
                  travel ]e.-3, four-lanes-pius-paved-shoulders-plus-left-turn-storage-lanes
                  commuter road.  At Neponset Circle, there are direct  ramps  to and
                  from the Southeast Expressway to  the north  and  the  Massachusetts
                  Turnpike.  Access  to and from the  south requires  use  of Gallivan
                  Boulevard  from Neponset Circle to  Ballet  and  Hilltop  Streets to
                  Granite Avenue to  the  Expressway.
Traffic - 10

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ROAD TO LONG  ISLAND
Kor-'i:;sey Boulevard  in Quinoy  4-ianes  piu.-..  should-?:
Trucks excluded.
 ; )/M)  T< i !.' iNi". !S:.AN">
                      '•  ,  ..'..iin-y,  1'iokini f • -1111 M>M: i ••..•••'•>' H.M:
', i;:ii. •:  N.i Ml  Ai:  •> ' .1 ' i > i:, (M:>;i!h-i  K'iv) .11:  !<•!!
          1 ->ward squantum

               Traffic  - 11

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                   Trucks are prohibited on this  route (by the MDC)  on a portion of
                   Morrissey Boulevard that has no structures and no constrictions.
                   Alternative access to the Southeast Expressway for trucks, going
                   northbound, requires the use of East Squantum Street, a narrow,
                   winding,  two—lane street, and Hancock Street, a wider, general
                   purpose,  "main" street,  while Southbound access requires use of
                   East and  West Squantum Streets, both narrow, winding streets and
                   Granite Street, a wider, general purpose, intertown roadway.
    •figuriT-,5"
Traffic - 12

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As shown on figure T-5, these routes include a number of safety
deficiencies where they traverse narrow residential street,
creating the potential for lethal conflicts between playing
children and through traffic.  Specific areas of concern include
Dorchester Street, East and West Squantum Streets and Hilltop
Street in Dorchester.  Note should also be made of the sharp turn
on Dorchester Street in Squantum.

In addition, note should be made that the Squantum neighborhood is
accessible by only one roadway,  a condition that could severely
compromise its emergency services.

And finally, figure T-6 shows the most seriously congested and/or
constricted areas along the access routes.  The most serious
problem appears to be at Neponset Circle,  a major access point  to
the Southeast Expressway,  a regional facility now being rebuilt
and widened to alleviate a long-standing regional problem.   Other
areas of local congestion include East Milton Square and the
intersection of Squantum and Hancock Streets.
                                                            Traffic - 13

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                    LON-"- JSL,AN;>
                   janfu-. Str-^t. ,  looking  toward Quin.-y fro-  er.tranc-  to  Marina Bay.
                                      ; i toward .':•:•,• I  .•
Traf:

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                                                                    left
          OIC'
                     •'irst:  house  is  bt-Iow grade •  f  street.
.,.'.  T, , i .ON?:  ISLAND
            • n\ i nq  i ri  of ho>  rl i ''••• •'.••••'•.   5^1 rpo  n1: ir • i  i -i i !  in  tight center  of
             ,. wj.itu o:  -i  •         >  '•••'•	:'  *          '  lV1  right (first  house
             :: ! .ilk  f-;i..-   •
                                                                         Traffic - 15

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               3.  Nut Island

                   From Nut Island,  all traffic can  easily  reach  the  Southeast
                   Expressway and Route 128 by following  the  route described in the
                   SDEIS to the Southern Artery, then  up  Coddington Street  to the new
                   Burgin Parkway, a high-design-standard roadway that connects
                   directly to the Southeast Expressway and Route 128.  The
                   Coddington Street portion of this route  is a "main street"; it
                   runs right through the center of  the Quincy's  downtown and is
                   heavily travelled.  The Burgin Parkway,  in contrast, south of
                   Coddington Street, is a four-lane divided  semi-express road-way
                   that is almost fully separated from adjoining  land uses and
                   intersecting streets.  It connects  to  the  regional expressway net
                   at a point of exceptionally high  traffic capacity.

                   The portion of this route closest to Nut Island is residential
                   with streets on which children are  accustomed  to play.   Use of
                   these streets for through traffic could  constitute a potential
                   safety hazard.  The portions of this route further away from Nut
                   Island, however,  are more heavily travelled, are not used as play
                   areas and hence,  pose less likelihood  of construction traffic
                   related accidents.

           C.  Mitigation

               The feasibility of mitigating actions assumed  in the SDEIS,  i.e.
               barging of bulk materials and busing  of construction workers, was
               questioned.  The possibility of more  extensive over-water
               transportation, such as the ferrying  of workers and roll-on/roll-off
               transport, also was raised as an issue.

               Review of the mitigating actions described in  the  SDEIS indicated that:

               1.  They are reasonable.

               2.  More extensive over-water transportation is possible.

               Two major considerations determining  the feasibility of barging bulk
               materials are the existence of suitable sites  for  pier construction at
               the wastewater treatment plant site,  and available transfer stations
               to transport bulk materials.  A study by Thibault/Bubly Associates
               regarding potential transfer stations,  included as Appendix T-2,
               concluded that at a minimum, four potential  transfer sites exist.  A
               study by Lee Pare & Associations, Inc.  (a  civil engineering firm with
               considerable experience in waterfront facilities)  concluded  that pier
               construction is feasible at both Deer and  Long Islands.  Their report
               is appended hereto (Appendix T-3).
Traffic - 16

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The use of barges for construction access to island sites is a
well-established practice, and the existence of such large
facilities asthe House of Correction, the Long Island Hospital, Fort
Warren, and the lighthouses offshore demonstrate its feasibility.
Similarly, the use of buses for- transporting workers to sites with
limited parking is quite possible and has become increasingly common
in recent years.

The possibility of busing worker to either Deer or Long Island from
either Wonderland or a site on the South Shore was reviewed by
Grossman Engineering, Inc., traffic consultants.  It was concluded
that busing would be feasible; however, certain concerns were
expressed:

1.  During peak construction periods, traffic could be as much as
    1,000 automobiles, potentially causing short-term traffic
    impacts.  These impacts could be mitigated by using more than one
    parking lot, thus distributing the traffic.  In addition, the
    Wonderland site is accessible by MBTA, which could be used by some
    of the commuting workers.

2.  At least one intersection on the route to Deer Island provides a
    very tight passage for large vehicles such as buses.  In order to
    alleviate this problem, it might be advisable to have a police car
    lead the buses through the community, clearing a pathway through
    intersections.  A police escort would also ensure that buses
    proceeded at appropriate speeds through residential neighborhoods.

On the question of barging earth spoils from excavation and gravel for
construction, the really significant part of the potential truck
traffic, the assumptions in the SDEIS appear reasonable.  Excavated
earth that cannot be reused on the island would be likely to be
glacial till from the island or broken rock from the inter-island
tunnels.  Neither material is likely to have a ready market at the
quantities expected and so would have to be discarded.  The assumption
in the SDEIS, that it would be dumped in the ocean at the designated
"foul area" off Marblehead appears reasonable since such dumping would
be both environmentally acceptable and low in cost.

On the acquisition of gravel, the assumption that it would be shipped
to Deer Island by barge likewise appears reasonable since gravel is
expensive in the Boston area but inexpensive in Maine and New
Hampshire, and since the scale of the project makes the construction
of an unloading pier feasible.

Discussion of more extensive use of over-water transportation involves
two issues:  feasibility of roll-on/roll-off truck barging, and
ferrying of workers.  Analysis of available information shows both to
be reasonable.
                                                                Traffic - 17

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                On the expansion  of  over-water transportation to include all heavy
                trucking,  review  indicates that it was  not  proposed in the SDEIS
                because there  was no existing roll-on/roll-off terminal in Boston
                Harbor.  Construction of such a facility,  however, is feasible,
                requiring  only a  couple of acres of  land,  piled dolphins to secure a
                barge, and a  roll-on/roll-off ramp that could be supported by  either a
                float or a gantry crane.  Potential  sites  for such a facility  are
                available  along the  Chelsea and Mystic  Rivers in Chelsea and
                Charlestown,  and  possibly on the Fore River in Quincy.  With the
                provision  of  roll-on/roll-off terminals, virtually all medium  and
                heavy trucking could be accomplished over  water.

                The feasibility of ferrying workers  is  dependent .on a number of
                factors, including availability of suitable terminal sites,
                availability  of ferries of appropriate  size,  time required for ferry
                trips, harbor  regulations, existence of channels sufficiently  deep to
                permit passage of ferries, and cost.  Analysis of these factors
                indicates  that operation of a worker ferry  service would be possible.
                In addition,  access  to the terminals by workers must be considered.
                Terminal sites will  require nearby parking  for several hundred
                automobiles;  access  from public transportation would be desirable as
                well.  Possible ferry terminal locations in the south shore area
                include Marina Bay in Squantum, the  Neponset  Drive-in in Quincy,  and
                Hewitt's Cove  in  Hingham.  The cost  of  ferrying all workers during an
                8-year construction  period would be  approximately $30,000,000  (Table
                T-l).  It  should  be  noted that south shore  waterfront sites are  in
                demand for a  variety of uses, and that  the Authority should act  to
                obtain the use of appropriate land if it wishes to implement future
                over-water transportation of workers.
                                             Table T-l

                         Costs of Alternative Transportation of Construction Workers
Average                               Annual
No. of  Time Lost (Hrs. )  Rate    Annual      Cost
workers Per Day Per Yr. Per Hr.  Cost     Bus/Boat
                                                                            Total Cost
                                                                        1 Year
                                                                                  8 Years
All bus
All boat*
Mixed
600
600
600
0.5
1
0.5
125
250
125
                                               $17  $1,275,000 $  500,000  $1,775,000  $14,200,000

                                               17   2,550,000  1,200,000   3,750,000   30,000,000

                                               17   2,550,000    850,000   2,125,000   17,000,000
                 Assumptions :  See Appendix T-l
                  *300-passenger ferries were assumed.  Use of a greater number of smaller
                   vessels would increase costs, but  not to a significant degree.
Traffic - 18

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D.  Forecasts

    Assuming the mitigating actions described in Section C will be
    implemented, it was questioned whether the forecasts of traffic
    expected to be generated by the proposed project were reasonable.

    The estimate of eight heavy and medium trucks,  per day for 7 years,
    for materials not suitable for barging,  assumed that roll-on/roll-off
    transport would not be implemented.   This estimate is reasonable.
    With the addition of roll-on/roll-off barging,  this number could be
    reduced further, theoretically to zero.   It should be noted that even
    with maximum feasible over-water transportation, there would be
    additional traffic of smaller trucks carrying a variety of goods and
    services, but this traffic would be  essentially indistinguishable in
    quality and quantity from the existing traffic  to the prison and the
    existing treatment plant, and thus is not environmentally significant.

    The estimate of 13 to 26 buses per day also is  reasonable.  The exact
    number would vary depending on the number of workers employed at a
    particular time, and the percentage  of workers  that could be ferried
    to the site.
                                                                   Traffic - 19

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Traffic - 20

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                                 Appendix T-l

          Costs  of  Alternative Transportation of Construction Workers

Assumptions:

1.  Ferry time would average 45 minutes each way (7 miles).

2.  Bus time would average 15 minutes each way  (5 miles).

3.  All workers would get paid for time on bus.

4.  If all workers are ferried, all would get paid for ferry time.

5.  If only workers ferried are those who would be 'spared trip through
    downtown Boston, then all workers would be paid for 15 minutes of travel
    time each way (the bus trip time).

6.  Average worker pay rate would be $17/hour.

7.  Buses for all workers would average $500,000 per year.

8.  Perries for all workers would average $1,200,000 per year.
                                                                        Traffic -  21

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Traffic - 22

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                                 Appendix T-2

A.  Introduction

    A major consideration determining the feasibility of barging of bulk
    materials is the existence of transfer stations to transport bulk
    construction materials.  The following pages are excerpted from the report
    Interim Systems for the-Transportation of Sludge from Deer and Nut Islands
    (1985) prepared by Thibault/Bubly Associates for US EPA Region I.  The
    report outlines transfer stations that might potentially be available to
    MWRA in order to implement barging of bulk materials which is a grant
    condition of this project.  In order to adequately assess feasibility of
    barging, several factors need to be evaluated:

    1.  Navigational Restrictions

        Width of channel, amount of existing traffic, and any special
        restrictions that might apply were considered.  (For example, if the
        barges were to carry tractors as well as trailers, they would be
        classified as "ferries" and would be subject to Coast Guard
        inspection.)

    2.  Docking Facilities Requirements

        The two types of vessels considered for sludge transfer were:

            1000 ton self-propelled tank barge, 170' x 37' x 8' draft
            1000 ton self-propelled RO/RO barge, 170' x 37' x 6' draft

        The tank barge would require a finger pier  extending to water of
        suitable depth so that a barge could be docked in existing depth
        conditions without dredging and a row of dolphins to secure the
        barge.  The pier would support a pipe and access catwalk.

        The RO/RO barge would require a double row  of dolphins to guide the
        vessel up to the loading ramp and to secure the vessel.  The depth of
        water within the berth would have to be 6'  minimum at low tide.  The
        ramp would be extended to an existing 6' depth to avoid the need for
        dredging.  The loading ramp would be supported by a gantry or other
        suitable means to allow the outboard end to be raised and lowered to
        meet the barge deck.  Truck access to this  ramp would allow quick safe
        backing of the tractors onto the barge for  removing the full trailers
        and spotting the empty trailers.  Good lighting for safe efficient
        operation at night would be necessary.

    3.  Ownership

        The site should be in the possession of one owner who has clear title
        and who is ready and willing to sell or lease the site to the MDC for
        the planned transfer of sludge.
                                                                        Traffic  -  23

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       B.   Potential Sites

           Several alternative sites may be considered as transfer stations to
           transport materials to the site during the construction of the wastewater
           treatment facilities.  These sites will require more detail investigation
           to determine their feasibility.  They are:

           1.   Massport sites.  Massport has sites with water access in South Boston
               and in Charlestown.

           2.   Quincy sites.  The Quincy shipyard has excellent water access
               facilities.  To date, the future use of this site has yet to be
               determined.

           3.   Texaco Facility, 99 Marginal Street, Chelsea

               Two Texaco Oil Terminal Facility properties are located between
               Marginal Street and the Chelsea River; a garage is located across
               Marginal Street.  The total 5.5 acres are zoned for industrial and
               waterfront industrial use.  Assessed at a value of $2,757,300, the
               property is being actively marketed by its real estate broker.

               The site is bordered to the north by Marginal Street and to the south
               by 550 feet of the Chelsea River.  To the west is Quincy Oil, a small
               petroleum storage and transfer facility.  To the east are old ware-
               houses and docking facilities that are in disrepair.  There are some
               residential buildings set back about 200 feet that are visible along
               the truck route to the west.

               Truck access, loading, and dispatch facilities at the site are
               adequate in design and in excellent condition for continued use as
               part of a sludge transfer facility.  The property consists of five
               buildings, seven bulk storage tanks (10 million gallons total
               capacity), a loading rack, and a docking facility.  The structures
               include two warehouse buildings (16,600 square feet), a garage (10,600
               square feet), a small one-story brick foam house (336 square feet),
               and an electrical house (960 square feet).  The loading rack is
               capable of filling four vehicles with liquid product.  In addition,
               the facility is supported by all public utilities.  For more detailed
               descriptions, see Figure VII-2.

               When the facility was operating, an average of 40 tank trucks a day
               passed through the facility.  This is more than the 35 expected from
               operation of the sludge transfer facility.  Although the Texaco
               Facility is not now used, a considerable amount of truck traffic is
               generated by six other petroleum transfer and storage facilities,
               warehouses, and other industries on Eastern Avenue and Marginal Street.
Traffic - 24

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             APPENDIX T-3
          Feasibility Study

Pier Facilities for Water Transport of
 Construction Labor and Materials to
     Deer Island and Long island
     Boston Harbor, Massachusetts
            Prepared for:

           Bubly Associates
            Providence, RI
             Prepared by:

     Lee Pare & Associates, Inc.
           150 Main Street
         Pawtucket, RI  02860
                                             Traffic - 25

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                                TABLE  OF  CONTENTS


       EXECUTIVE SUMMARY

       1.0  PROPOSED  SITES

            1.1 Deer  Island
            1.2 Long  Island

       2.0  SITE SELECTION CRITERIA

            2.1 Water Depths
            2.2 Subsurface Geology
            2.3 Proximity to Worksite
            2.4 Adjacent Open Areas
            2.5 Existing Shoreline
            2.6 Storm Exposure
            2.7 Cable areas

       3.0  RECOMMENDED PIER DESIGNS  & COST  ESTIMATES

            3.1 Bulk  Materials  Pier
            3.2 Roll  on/Roll off Facility
            3.3 Commuter Pier

       4.0  PIER DESIGN CRITERIA

            4.1 Volume Capacities
            4.2 Environmental Considerations
            4.3 Storm Resistance
            4.4 Future Uses of  Pier

       5.0  OTHER CONSIDERATIONS

            5.1 Vessels for Transport During Construction
            5.2 Dredging & Disposal

       6.0  CONCLUSIONS
Traffic - 26

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                        EXECUTIVE SUMMARY
     This report examines  the  feasibility  of building piers at
Deer  or   Long  Island  in  Boston  Harbor  to  support  vessels
delivering men, materials and equipment to a wastewater treatment
plant  construction  site.  The proposed pier designs were to  be
capable  of handling 1200 workers,  10,000 c.y.  of bulk materials,
and 100 roll  on/roll  off  trailers  per  day.   Seven, variables
affecting site selection and four variables affecting pier design
were  evaluated.   As  with any major civil engineering  project,
designing  for  peak  demands,  volumes,  or 100 year storms  can
result in facilities oversized and  overpriced  .for  normal usage.
To minimize overdesign,  we  have separated the pier project into
three components based on the  types  of  vessels to be serviced:
commuter, bulk  and  roll  on/roll   off.   The   resulting  design
proposes   three  separate  sites  and  facilities;  each  easily
changeable to  meet fluctuating demands.  Since the need for most
of the  facilities  is  temporary,   they  are  designed  as such.
Options for the future conversion of the permanent bulk materials
pier into a sludge handling terminal are also provided.

     In  summary, construction of piers at either Deer Island  or
Long  Island  for  the  purpose  of  landing  men, materials, and
equipment is deemed feasible.  Construction costs for Deer Island
facilities are estimated at $5.2 million.   The  cost for similar
facilities  at  Long  Island  could vary by 15-20%  depending  on
siting and subsurface geological conditions.

     A  recommended  course  of  action  to  follow  after  final
selection  of  the  island  would include:  additional subsurface
investigation   at   the   proposed  sites;  bathymetric  surveys
(soundings) and bottom sediment sampling; development of accurate
estimates of quantities  of  men,   materials  and equipment to be
handled per day.

     With the above information, the second  level of preliminary
design could be accomplished.
                                                          Traffic - 27

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       1.0  PROPOSED SITES

            1.1 Deer Island
Fig. 1.
                The  proposed  siting plan of pier  facilities  at  Deer
            Island  is composed of three separate piers,  two  temporary
            and  one  permanent.   A temporary commuter  pier  would  be
            situated  about mid-island on the west shore, at an existing
            stone wharf (Site 1).

                A  permanent  pier  of  concrete  construction   and   a
            temporary ro/ro pier would be grouped together at a  site on
            the  west  shore near  the south end  of  the  island  at  an
            existing riprapped section of shoreline.   This site (Site 2)
            offers  deeper  water   nearer to shore  as  well  as  better
            subsoil conditions.
            1.2 Long Island
Fig. _2
                The  proposed  siting plan of pier  facilities  at  Long
            Island  comprises  a  3-pier  system  as  proposed  for  Deer
            Island.   Siting  would  center  around  the  existing  pier
            located mid-island  on  the  north  shore.   Due to a lack of
            soils information  and  a  site  survey,  exact siting is not
            proposed for each of the three piers.
Traffic - 28

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            DEER
            ISLAND
COMMUTER
PIER (SITE I)
           X    \
           \    V—SURVEYED
            N       9'CHANNEL
            \   10.

             \    \
            ROLL ON/ ROLL OFF PiER -
                PULK MATERIAL
                PiEn ( SITE 2) -
     Lee Pare & Associates, Inc.
PROPOSED  PIER SITES
     DEER   ISLAND
                            FIGURE i
                                                       Traffic  - 29

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            PROPOSED
            PIER SITE
                                    LONG
                                   ISLAND
              Lee Pare & Associates, Inc.
PROPOSED PIER SITE
    LONG  ISLAND
                                     FIGURE 2
Traffic - 30

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2.0  SITE SELECTION           Figs.  JL & 2^

     2.1 Water Depths & Dredging

         Existing nautical  charts (NOAA #13272) were utilized to
     determine  acceptable  locations  for  the  pier  or  piers.
     Previous work at Deer  Island  (GZA  Soils  Report) examined
     subsurface soil  conditions at two sites:  (Fig.  1):   Site  1,
     located  midway  along the island's west shore at an existing
     granite  block marginal wharf;  and Site 2, also  located  on
     the western shore near the southern end,  at an  existing rip-
     rapped  section   of  shoreline.   These  two  sites   and  the
     shoreline  between them constitutes the acceptable  locations
     for the proposed  marine  facilities based on nautical chart
     examination.

         Deer  Island  Site 1:   Located in close proximity to the
     existing  STP,  this   site  is   limited by 10'  water depths.
     Although  acceptable   for   shallow  draft  commuter  vessels
     (41 - 10'   draft), accomodating  tugboats  and  bulk barges
     (draft 10 - 12') would require  dredging approximately 80,000
     c.y.  of sediments.   Utilization of this  site for a commuter
     terminal only, would  not require dredging.

         Deer  Island  Site  2:   Deeper water   (12'+^  approaches
     within  200" of  the shoreline at this location.  The  cons-
     truction of a pile supported or  earth filled causeway across
     the  shallows to  reach  a  deep water pier is economically
     feasible.    Depending  on   numerous  factors  regarding  the
     physical  and chemical  makeup   of  the  sediments, causeway
     construction may be competitive  in cost with dredging,  with
     much less impact on the environment.

     Long Island Sites:

         Since proposed sites  at Long Island  based  on subsurface
     information  have  not  been developed,  we have  proposed  a
     general  location, based on shoreline topography  and  water
     depths.  Figure  2. The areas adjacent to the existing  pier
     on the west side  of   the  island offer suitable water depths
     (12*) within reasonable distances (400*  - 500') from shore.

     2.2 Subsurface Geology

         In  general,  suitable  soils or  rock  to  support  pile
     foundations  lie  deep  below  the surface at  Deer  Island.
     Based on existing  boring   information,  a layer of  till lies
     at -50' to -75'  (MLW)  at Site 2  and at -65 to -85'  (MLW)   at
     Site 1.
                                                         Traffic - 31

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                The difference of 12.5' in the average  pile  length  of
            approximately  400  piles  represents  a  cost difference of
            $260,000, making Site  2  more  attractive  for a large pier
            structure.   Without  offshore  soils  information  for Long
            Island, it is impossible  to  predict subsurface conditions.
            However, geologically, the two Islands are of similar origin
            and; therefore, soil profiles are assumed to be similar.

            2.3 Proximity to Work Site:

                Since all available sites on Deer  or  Long  Island  are
            within  a  mile of the construction work, proximity  between
            the pier and the  work  is not critical for moving equipment
            and materials.  It  is  critical,  however,  that workers be
            landed as close to  the  heart  of  the construction site as
            possible.  Deer Island Site 2 would require  an  average  20
            minute walk for  workers,  which based on 1200 workers would
            add  $5,000  -  $10,000  per day in added labor  costs.   If
            busing  were  to  be provided, a minimum  of  8  buses  with
            drivers  would  be  required,  adding  congestion  to  roads
            already heavily taxed by construction vehicles.

                Site 1 therefore is the logical choice  for  locating  a
            commuter vessel pier.

            2.4 Adjacent Open Areas:

                Due  to the high volumes of materials &  supplies  which
            will  be landed each day, large open areas for  laying  down
            cargo and storing trailers will be needed.  In order to keep
            pace with the rapid offloading and loading schedules  of the
            bulk barges, bulk  material  will  have  to be stockpiled on
            shore  as  close  to  the  pier as possible.   Empty trailers
            stored  near  the  ro/ro  pier for  transport  back  to  the
            mainland will facilitate the loadout operation.

                Large open areas to the immediate  north  and  south  of
            Deer  Island  Site  2  make this site well suited  for  bulk
            material and ro/ro operations.

                Deer  Island Site 1 and the proposed  Long  Island  site
            does not provide as much  open area.   Until definite  volumes
            of  materials  and  traffic  are  generated,    it  would  be
            guesswork to estimate the adequacy of these sites.
Traffic - 32

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2.5 Existing Shoreline Structures

    Rehabilitating or otherwise utilizing existing shoreline
structures can facilitate  the  work  and  possibly ease the
permitting  process  since these areas have been  previously
disturbed and altered.   Site  1  offers  a well constructed
stone wharf which  could  function as the link between shore
and a pier, either  temporary  or permanent.  Utilization of
this  structure saves approximately $250,000 in construction
costs.

    Site  2  offers  500  feet  of  bulkheaded  and  heavily
rip-rapped  shoreline.   This  shoreline   feature   can  be
incorporated  into  the  proposed plans  for  a  savings  of
approximately $50,000.

    An existing pier structure at the Long Island site could
be  utilized  as  a  commuter  pier for an estimated project
savings of $200,000.

2.6 Storm Exposure

    Of  the  proposed   sites,  under  normal  annual  storm
conditions,  the  Long  Island  site  can be considered most
exposed  and  Site  1  is  least exposed.  During  northeast
storms, refraction  of  large ocean swells aroung the tip of
Long  Island may present problems for commuter  vessels  and
the offloading of  ro/ro  barges at the proposed Long Island
site.

    Deer  Island  sites are well protected from northeasters
and would confront only wind drive waves from southerly  and
westerly winds across  the  fetch  of  Boston Harbor.   Under
average conditions, these waves should not pose problems  to
bulk and ro/ro operations proposed for Site 2.  Much  of the
energy in the larger waves will be dissipated in the shallow
approach  to Site 1; thereby offering a natural  measure  of
protection to the proposed commuter pier.

    In the event of a hurricane,  all these  sites  would  be
equally jeopardized,  with  any  natural  protection lost to
360  wind directions and 10'+ storm surges.
                                                     Traffic - 33

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            2.7 Cable Areas

                A designated cable  area occupies a portion of Site 2 at
            Deer Island.  According to information provided by the Coast
            Guard and the Army Corps of Engineers, these  areas  do  not
            present  a  problem  to pier construction.   During  WW  II,
            magnetic gaussing cables were laid across entrances to major
            harbors for detection of enemy submarines.   Most  of  these
            abandoned cables have been removed, but still appear  on the
            charts.
Traffic - 34

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3.0  RECOMMENDED PIER DESIGNS & COST ESTIMATES
     3.1 Bulk Material Pier
     3.1.1  Description
                   Fig. _3
         The  proposed  pier and causeway has a 12" concrete deck
     supported  by  24"  x  24"  prestressed concrete piles.  The
     causeway section (3001  x  30')  connects  the shore and the
     main pier (300* x 75).  A truck turn around area (80' x 90')
     is  located  at  the  end of the pier.   The  pier  has  the
     capacity to berth  four  bulk material barges simultaneously
     and unload as much as 10,000 cubic yds. of material per day.

     3.2.2  Cost Estimate - Concrete Pier
       ITEM
Piles:  24" x 24"
Pile Caps:  42" x
Deck:  12" CIP
Reinforcing Steel
Fender System
Mooring Devices
Utility Trench
Lighting
PS
24'
CIP
        UNIT
  LS
  CY
  CY
TONS
  LF
  EA
  LF
  LS
QUANTITY


 35,895
  1,015
  1,435
    318
   •850
     18
    690
                          COST
>    52
   320
   320
1,320
   265
3,500
    81
                                     Pier Sub Total
                        Engineering & Contingencies

                                              TOTAL
 TOTAL
(1000'S)

 $1,867
    325
    459
    420
    225
     63
     56
 	28

 $3,443
    690

 $4,133
     3.1.2  Optional Earth Filled Causeway

         A  substantial   cost   savings   may   be  realized  by
     constructing an earth  filled  causeway  rather  than a pile
     supported causeway  to  connect  the  main pier to the land.
     The  utilization of approximately 40,000 c.y.   of  excavated
     gravel material  from  the STP construction to create a 300'
     long  berm  (causeway)  results  in a potential  savings  of
     $468,500.
                                                         Traffic - 35

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B)
Ml
i-h
                                                                                    	CB_  .JQ	Ul_
                                                                                   — ->=T   V:	^—--,
                                                                         p TRAILCR irrpi -J     I



                                                                          Dl  A M           '  >
                                                                                                                 BULK  MATERIAL  PIER

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     3.1.3  Cost Estimate - Earth Causeway

       ITEM               UNIT     QUANTITY
Earth Fill                 CY
Road Pavement              SY
P.C. Curbing               LF
Shoulder Pavement          SY
Riprap                     CY
Sheetpile Wall             LS
Engineering & Contingencies
 40,600
  1,000
    600
  1,000
  4,133
 COST

    3
   21
   14
 4.50
27.50
  TOTAL

 $121,800
   21,000
    8,400
    4,500
  113,700
  243,100
  102,000

 $614,500
 -320,000

 $294,500

 $763,000

 $468,500
                                     TOTAL
       Less Excavation Spoil Disposal Cost

                                     TOTAL

  Cost of Pile-Supported Concrete Causeway

                         Potential Savings

     3.2  Roll On/Roll Off Pier      Fig.  £

     3.2.1.  Description

         The  proposed  pier consists of an earth-filled  landing
     wharf built out from  shore;  a  floating  barge (car float)
     which acts as a  causeway,  and 10 mooring dolphins.   Barges
     loaded  with trailers are mated and moored to the stationary
     car float and unloaded  with  tractors.    Ramps  connect the
     barges to each other and to shore.

     3.2.2  Cost Estimate
       ITEM               UNIT

Earth filled landing
  Wharf                    LS
Ramp                       LS
Barge Mating System        LS
Mooring dolphins           EA
Lease barge for 1 yr.      LS
Engineering & Contingencies
QUANTITY
 COST
   10
28,500
  TOTAL
$151,000
 125,000
  51,000
 285,000
  50,000
 132,000
                                               TOTAL   $794,000
                                                          Traffic - 37

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0>
l-h
o

I

U>
CD
                                                                                    /--WOOD me MOOOIHI~' ~?t '
                                                                                   / 119 P'Lf CLUSrfRltrrPI
                                                                         JPLAN
                                                                         SCALE  l'« 60'
                                                                                ELEVATION
                                                                                ""
                                                                                                           ROLL ON / ROLL OFF  PIER

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     3.3  Commuter Pier       Fig. 5^

     3.3.1  Description

         The proposed commuter  pier consists of a floating barge
     moored to an existing stone wharf.  The existing wharf would
     be  upgraded  by  the  addition  of gravel fill and pavement
     surfacing.  Four mooring  dolphins  are  required.   A clear
     channel would be  surveyed  and designated with marker bouys
     leading in from deeper water to the floating pier.

     3.3.2  Cost Estimates
       ITEM               UNIT.     QUANTITY     COST     TOTAL

Mooring Dolphins           EA          4       28,500  $114,000
Improvements to Exist
  Wharf                    LS                            14,000
Aluminum Boarding Ramps    EA          2        7,500    15,000
Survey Channel & Mark      LS                            24,000
Barge Lease/per yr.                                      54,000
Engineering & Contingencies                              44,000

                                                TOTAL  $265,000
                                                          Traffic - 39

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01
l-l)
fh
M-
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                                                                                                                                                                                            CHAHHfL
                                                                                                                                                                            \l  MA.-HtF.RS fSff NOTf 11
                                     - fjriSrrtvG GRANITE
                                       MARGINAL WHARF  TO 8£
                                       IVPROVtO  ISfENOTfSI
                                                                                                  CO MUTER  VfSSfL
                                                                                                                               riff ffNOCPS PROVIECO
                                                                                                                               \*IT" BARGt
                                                                                                                                       WOOD PILt MOCmHC OOLPHtVS
                                                                                                                                         f 19 PILC CLUSTCKtlTYPI
        FLOATING PlfK-
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                                                                                                                                                                        NOTES
                                                                                                                                                                 xre.ilrr wixiM b«  vstjblt^Scd by • b«-
                                                                                             WOOD PILt
                                                                                             UOOHINS  DOLPHINS
                                                                                             fIS PILf  CLUSTCRI
             PLAN
                                                                                                                     SCALE  I "= 60'
                                  FHISTIttG GOAWTf BLOCK	•   I
                                  MARGINAL *HiRF TO SC   - -.- '
                                             ifff *0'F >/
                                                                                                                                                                                  f>> jccoranodatc
                                                         valves .n the barte will be opened.


                                                                     >•» pr.-vlilrd to Allow ta-
                                                                  y)  ruf lojt inft.
                                                                                                                                                                            ;. :ud.-  .r.ivel till.
                                                                                                                                                                            'I'l  : ,r- I I-.;.  S . ,.
                                                                                                                                                                        '• i:-i  1..I :-. ,r-.  ruli-:-
                                                                                                                                                                   COMMUTER  PIER
                                                                                                                                                                                        FI&UHC  S

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4.0  PIER DESIGN CRITERIA

     4.1  Volume Capacities

     4.1.1  Bulk Pier

         As  designed,   eight 900 c.y.  bulk material barges could
     be  unloaded per day for a total  of  7,200 c.y.    Four  empty
     barges would be  removed  and replaced with four full barges
     during  lunch  hour   to  minimize  lost  time  for  operators
     standing by.

     4.1.2  Ro/Ro Pier

         Each  ro/ro  barge would consist of two car float barges
     (401  x 330') rafted   together  for a total carrying capacity
     of 42 trailers.  (Trailer = 45' x  8.5' @ 40 tons).   Assuming
     removal of a trailer every five minutes and  delivery  of  a
     2nd  ro/ro barge during lunch,  84  trailers could  be  landed
     per eight hour  day.

         Empty  trailers   would  be  stockpiled  in   an   adjacent
     staging area and then loaded out at  night.  Alternatively,  a
     second  ro/ro   facility   can   be    constructed  to  allow
     simultaneous unloading/loading  operations.

     4.1.3  Commuter Pier

         The commuter pier  consists of a single moored  car  float
     barge (401  x 330') providing 660'  of berthing space.   Eight,
     77'   high speed commuter vessels carrying 149   workers   each
     can simultaneously dock at this facility.

     4.2  Environmental Considerations

         The negative impact  of  steel  or concrete pile  supported
     structures  on   the   environment   is negligible  and  occurs
     primarily during construction.   During  this   time,   noise,
     vibration and disruption  of the  sea  bottom  scares marine
     life   from the  area.   However, piles quickly  become   fouled
     with  marine organisms and provide  a  natural  habitat  for  a
     variety  of new species as well as the original inhabitants.
     Studies  of  pile  supported oil  rigs on the  Gulf and West
     Coasts actually show  positive  impacts  on  the marine life
     ecosystem.
                                                         Traffic - 41

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                Fill projects rarely  contribute positive impacts to the
            marine environment unless designed specifically  to  do  so.
            To a certain degree, the negative impact is direclty related
            to the area filled; however, other factors such as runoff or
            disruption of tidal  currents  may  have  a more significant
            impact.

                The  proposed  designs attempt to limit not only overall
            cost  of  the  facilities  but the  impacts  on  the  marine
            environment  as well.  The use of temporary  floating  piers
            greatly reduces  the  size of the permanent structures.  The
            optional  earth  filled  causeway  is  proposed primarily to
            reduce  costs;  however, judging by shoreline  configuration
            and offshore contours,  the  impact is believed to be small;
            and material for its construction would be excavated  gravel
            which when utilized  as  fill  may  cause lesser impact than
            would offshore disposal.

            4.3  Storm Resistance

                Facility  design  requirements include the necessity for
            structures  to  withstand  a  100  year storm.   Preliminary
            analysis  of  the  proposed  concrete  pier based on assumed
            flood and wave conditions indicate that the pier can  safely
            withstand hurricane conditions barring a major impact from a
            large ship.

                The temporary floating  piers for the ro/ro facility and
            the commuter facility  will  have  the  unique ability to be
            flooded and sunk at their berths. Waves and storm surge can,
            therefore,   safely    pass   over   the   vessels.    Minor
            modifications to  the  barges would provide flood valves and
            pump out connections.   After  passage of the storm,  workers
            would connect pumps  and  refloat  the  barges.   This method
            would  provide  the  greatest assurance  of  safety  to  the
            barges.  An alternative  method  would involve designing the
            mooring equipment (dolphins, chains,  etc.)  to withstand  the
            estimated forces.  Construction and material costs would  be
            considerably higher for the overstrengthening thus required.
Traffic - 42

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4.4  Future Uses of the Pier

Recreation:

    Many   fundamental   design  differences  exist  between
recreational  marine  facilities   and   industrial   marine
facilities.  However,  it  is  not  unreasonable to consider
future conversion of the proposed bulk handling  pier  to  a
public recreational  facility.   Low cost modifications such
as the addition of railings around the perimeter of the pier
would   suffice   for   use   by  fishermen,  photographers,
sightseers, etc.

    A  recreational  marina could be economically created by
attaching floating  finger  piers  and  ramp walkways to the
pier.   The  viability of such a conversion largely  depends'
upon the development of shoreside facilities and services.

Sludge Terminal:

    The  proposed  permanent  pier  is  sited  and  designed
ideally for future utilization as either a roll on/roll  off
sludge tank truck facility, or as a deep draft sludge tanker
terminal.  Shallow draft sludge barges could be handled most
economically of all.

Ro/Ro Facility:

    Fig. _6, Option 1, shows a plan  for  conversion  of  the
pier to a ro/ro facility suitable for handling tank  trucks.
The ro/ro ramp from the temporary facility can be moved  and
installed  on  the  end  of  the pier.   Two  high  strength
breasting/mooring  dolphins would be constructed to complete
the facility.  Estimated Total Cost:               $250,000

    Depending on the  type of vessel utilized as a 'tanker',
conversion costs vary dramatically.   Since  water  depth  at
the end of the pier  is  estimated to be a minimum of 20', a
shallow draft (12') fuel barge could be used for bulk sludge
transport.   Cost  of  conversion would be  limited  to  the
pipes, pumps, and hoses necessary for loading.
                                                    Traffic - 43

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                Fig.  j6  Option 2, shows the addition of a pipe rack and
            walkway  bridging  the  150'  distance  from the pier to the
            President  Roads  Anchorage.   With  the construction  of   3
            breasting dolphins, the resulting 40" deep berth is  capable
            of handling 600'+ tankers.

            Estimated Cost:          $850,000

            Other Uses

                A  broad  range of alternate future uses of the pier can
            be considered.  Among  them  are:  docking for tugs or pilot
            boats which service  Boston  Harbor; docking for Coast Guard
            or other government and rescue vessels; and  fuel  dock  for
            commercial and/or recreational boats.
Traffic - 44

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                                           69O
                                           FROM SHOR£~
                                                        . - RO/RO RAMP

                                                                            •- PRESIDE*? ROAPS ANCHORAGE
                                                                              HO WATCH OCPTHI
                                        BUL X PlCR
                                                                             ROS RO BAROf CAPACITY
                                                                             APPRO* iO TANKTRiJCKS
                                                              TJ
                                                                          I
                                      OPTION I! RO/RO TANK TRUCK FACILITY
                                      NOT TO SCALE
                                                                                    — MOORING OOLPMWS
                                                                        D
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                                                                       a
                                                         - f/ff HACK a
                                                          WALKWAf
                                                            UOORIH6
                                                            DOL PHirvS - -
SLUDCC
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                                    OPTION 2! DEEP DRAFT TANKER FACILITY
                                    NOT TO SCALE
                                                                                                   FUTURE SLUDGE  TERMINAL
                                                                                                            OPTIONS
n
i

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        5.0    VESSELS FOR TRANSPORT DURING CONSTRUCTION

             5.1.1  Commuter Vessels

                 High speed (over 20 knots) commuter vessels are commonly
             built in three classes based on passenger capacity:  49, 149
             and 300 passengers.

                 Vessels in the 49  and 149 passenger class are available
             with   totally  enclosed,   heated  passenger   compartments,
             suitable for all weather operation.  The 300 passenger class
             vessels often accommodate  up to 150 passengers  on  an  open
             upper deck.  These  vessels  would  require  modification to
             enclose the upper deck and then recertification by the Coast
             Guard.   A  greater  number  of smaller vessels  capable  of
             slightly higher cruising speeds and much lower docking times
             may  prove  most  cost  effective  if workers are to be paid
             while enroute.

                 Assuming 1200 workers/day transported over water 20 - 30
             miles round trip  at  an average speed of 22 miles per hour,
             preliminary cost  estimates  range from $8 - $14 per man per
             day.  Varying factors include the number of vessels  (vessel
             trips),   contract  duration  in  years,   liabilities   and
             penalties for down time, etc.

             5.1.2  Roll On/Roll Off Vessels

                 Large barges 330'  x 40" x 10' known as "car floats" are
             commonly used for transporting trucks, rail  cars  or  other
             vehicles.  Load capacity is approximately 2,000 tons.   Deck
             space will accommodate  21-28  trailers.  These barges lease
             for approximately $4,500/month from Hughes  Bros.,  Inc.  of
             New York among others.

                 The  attractive  feature of these vessels is the ability
             to simply lease  more  or  less of them as the demand varies.
             Two barges can be  rafted   together  and  still managed by a
             single tug, effectively doubling the capacity.

             5.1.3  Bulk Barges

                 Bulk barges are available in a variety of capacities and
             dimensions.  Hughes Bros,  offers a barge 130'  x  40'   x 11'
             with a capacity of about 900 c.y.  for lease at  approximately
             $3,500/month.   Deck  barges  can  effectively    carry  bulk
             materials such as steel rebar or palletized materials.   Dump
             scows for offshore disposal are available with  an 1,800 c.y.
             capacity for lease at approximately $15,000/month.
Traffic - 46

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5.2  Dredging and Disposal

    The  facilities  proposed herein do not require dredging
for implementation.  The use of shallow draft barges and the
siting of the facilities eliminates the need for dredging.

It is possible that the sediment at Site 2 would qualify for
offshore   disposal,  were  dredging   required.    Sediment
analysis was conducted  by  the  Army  Corps of Engineers in
1980  on samples from the President Roads Anchorage abutting
Site  2.   Contamination  levels were  found  to  be  within
Federal  limits,  and the dredged material was  subsequently
disposed of offshore.

    Dredging  at  Site  2  would  allow  shortening  of  the
causeway connecting the Bulk Pier to the Island.  Shortening
the causeway by  200"  would result in a savings of $500,000
from  pier construction, but would require the  dredging  of
approximately  40,000  c.y.   of  material.    An  additional
savings  of  approximately  $160,000  would  result from the
shorter pile lengths  required  for the main pier structure,
for a total savings of $660,000 on pier construction.

    Dredging and disposal  costs for 40,000 c.y. of material
would approach $400,000.   Engineering  and  the  permitting
process  would add another $50,000 and require approximately
six  months.    The net project savings from dredging  would,
therefore, only be approximately $200,000.

    It  must  be  noted  that  until  the  proposed  dredged
material is sampled  and  analyzed, it is somewhat uncertain
if dredging would be permitted at all.  It is  possible  that
a six month design  and  permitting process could ultimately
end in a denial of the permit and considerable loss  of time
and money.
                                                    Traffic - 47

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             6.0 CONCLUSIONS

                 The  facilities  recommended for Deer Island within this
             report  are  economically and practically feasible.   Water-
             borne  transport of labor and materials to Deer  Island  vs.
             land transport will  not  delay  construction  schedules and
             will not disrupt  the  lives of residents in the vicinity of
             Deer Island.   The construction cost for waterborne transport
             may be higher than for land transport, but  that  cannot  be
             determined with certainty within the scope  of  this  study.
             Construction   costs  for  the  pier   structures  have  been
             estimated herein.

                 Long Island has similar features  and  geology  to  Deer
             Island and is also deemed suitable for delivery of labor and
             materials via water.   Cost  estimates  for  construction of
             pier  facilities  at  Long  Island have not  been  developed
             because  of  a  lack of subsurface information,  but  it  is
             anticipated that costs  would  not  vary  greatly from those
             estimated for Deer  Island.   Long  Island  is slightly more
             exposed   to    storm  conditions,   which  could  result   in
             additional  lost  time  during  delivery   and  handling  of
             materials.

                 It  has  been  determined  that  a  separation  of  pier
             structures according to use is preferable to construction of
             one multi-use pier.  This scheme has the added benefit  that
             commuter and  ro/ro piers can be temporary,  and can be easily
             enlarged  during  construction and removed thereafter.   The
             permanent bulk handling pier is adaptable to many uses after
             construction  of the treatment plant is completed.

                 Dredging  is not required for construction  of  the  pier
             facilities  recommended  herein.   Very  little  economic or
             logistic benefit could  be  derived  from  dredging;  and the
             environmental risks and potential  delays for permitting  may
             prove to be very expensive in the  long run.
Traffic - 48

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II-2
odors

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II-2  ODORS

    A.  Background

        The issues raised pertaining to the odor impacts of the facility
        subsequent to  the EIS draft, can be divided into three general areas:

        1.   What  are the sources and what is the nature of sewage plant
            odors? How are odors measured and what are the effects on human
            health and well-being?  Do other treatment plants experience odor
            problems?

        2.   How do odors disperse, and how can this be analyzed?

        3.   What  specific mitigation methods can be applied, and what is the
            reliability and cost of each?

        In  order  to answer these questions, a brief literature search and a
        computer  modeling exercise were performed.  The conclusion drawn from
        this study are:

        1.   Certain specific characteristics of the Boston sewage collection
            system have been shown to result in the formation of high levels
            of  hydrogen sulfide, methyl mercaptan, and other odorous compounds.

        2.   The magnitude of wastewater to be treated will result in the
            release of substantial amounts of these compounds to the environ-
            ment.

        3.   Computer air dispersion modeling predicts the odor impacts on
            nearby communities to be significant regardless of the siting
            option chosen.

        4.   In  order to assure an effective and reasonable mitigation of odor,
            removal or destruction must be 99.9 to 99.99 percent complete.

        5.   Such  mitigation is obtainable by careful application of reasonably
            available  technology and by designing to achieve a high degree of
            efficiency.

    B.  Existing  Conditions

        1.   Brief Literature Survey

            Virtually  all wastewater treatment facilities have the potential
            to  emit offensive odors at some time.  Surveys conducted both in
            the United states and other countries indicate that forty percent
            (40%)  to sixty (60%) of the existing wastewater treatment facili-
            ties  have  received complaints about odor.

            Odor  can arise in treatment plants from any number of sources and
            a variety  of causes, among them:
                                                                        Odor - 1

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                 - septic  wastewater
                 - toxic "slug"  loads  in  the wastewater
                 - high concentration  of  volatile organics in wastewater
                 - incomplete treatment of wastewater
                 - raw or  incompletely treated waste sidestreams
                 - organic overload due to return of highly concentrated recycle
                   flows
                 - screenings, grit and skimmings with high concentrations of
                   putrescible matter
                 - gas emissions from  treatment processes, manholes, pump stations,
                   outfalls,  digesters, etc.
                 - chlorinated water containing phenols
                 - incomplete sludge stabilization
                 - incomplete oxidation of sulfur compounds

                 One of the most common sources of odor in sewage treatment plants
                 is the formation of gases within the collection system itself.
                 Inorganic gases resulting from biological activity within the
                 collection system include hydrogen sulfide (H2S) and ammonia
                 (NHj) as  well as a number of odorless gases including carbon
                 dioxide,  nitrogen, oxygen, and methane.  Organic odors, which may
                 occur due to biological  activity or from direct chemical addition
                 from industrial sources, include mercaptans, indoles, and
                 skatoles. These odors will occur due to the anaerobic decompo-
                 sition of nitrogen and sulfur bearing compounds.  Other odor
                 sources include phenols, aldehydes, organic acids, and ketones.

                 Table 1 is a list of  common odor-causing substances in municipal
                 sewer systems  (1).  Hydrogen sulfide (H2S) is the most commonly
                 known malodorous gas  emanating from domestic wastewater collection
                 and treatment facilities.  It is highly soluble (2 800 mg/1 at
                 30°C to 5 650 mg/1 at 5°C) in normal domestic wastewater (2).  In
                 addition  to  its rotten-egg odor, I^S can cause highly corrosive
                 conditions and  is an  extremely toxic substance.

                 The toxicity of H2S is on the same order of magnitude as
                 hydrogen  cyanide (HCN),  and death has been known to result when
                 exposed to an H2S concentration of 225 ppm by volume in air,
                 such as can  occur in  confined areas such as sewer manholes.  Such
                 potentially  lethal concentrations would not occur in open areas,
                 however.   The maximum permissible 8-hour concentration is about
                 20 ppm.  Hydrogen sulfide can be dangerous because a person's
                 ability to sense large concentrations is quickly lost.  If the
                 person ignores  the first notice, the olfactory senses will become
                 numbed and no longer  give warning.

                 At a pH of approximately 9.0, hydrogen sulfide dissolved in water
                 is over 99%  in  the form  of the nonodorous hydrosulfide ion (HS),
                 while at  pH  5.0,  only one percent (1%) is in the nonodorous form.
                 As the pH of septic sewage is between 5 and 7.0, most of the
                 sulfide generated is  in  the form of H2S.
                 Hydrogen sulfide  is produced by reduction of the sulfate ion
                 by anaerobic  sulfate-reducing organisms.  Sulfate may be present
Odor - 2

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as inorganic sulfates either  from  industrial sources, or from
seawater intrusion (seawater  contains  appreciable concentrations
of sulfate).  These bacteria  thrive at  low oxidation-reduction
potentials (ORPs)  of -0.20  to -0.30 V,  pH's of approximately 6.0
to 9.0, and temperatures  near 30 degrees  Centigrade.  The ORP of
fresh wastewater is usually too high during the  first one or two
days in the collection system for  significant production of
H2S.  However,  anaeorbic  slime growths  and sludge deposits that
accumulate  in sewer lines  usually have lower ORPs than the
wastewater, making them more  conducive  to H2S production.
Hydrogen sulfide may thus be  produced even through the wastewater
contains up to about 0.3  mg/1 of oxygen (02> and the ORP of the
wastewater is not  sufficiently low to support sulfate-reducing
organisms (3).

Waltrip (4) has reported  levels of sulfide approaching 20  mg/1
from a long collection system with a high seawater intrusion rate
and making extensive use  of force  mains (as in Boston), and high
levels of sulfide  have been reported in a North  Chicago system
with long residence times and a high level of sulfate resulting
from slaughterhouse operations discharging to the sewer (5).

For sulfate to be reduced to  sulfide requires a  medium completely
devoid of free oxygen or  other oxidizing  agent.  The stream of
wastewater in a partly filled sewer is  usually not anaerobic
because it is exposed to  the  sewer atmospheres.  Oxygen absorbed
at the surface of the stream  generally  reacts with sulfides quite
rapidly, and in large sewers  the sulfide  concentration in waste-
water, therefore,  is held to  a very low level, particularly if the
sewer is well ventilated.

Strictly anaerobic conditions can  develop in the slime layer that
forms on the submerged portion of  the pipe wall.  This layer is a
matrix of filamentous microbes and gelatinous material (zoogleae)
embedding various  smaller bacteria.  If oxygen is present in the
stream, it diffuses into  the  slime layer, but only to a very short
distance.  Except  where oxygen concentrations in wastewater are
high, the aerobic zone is less than 0.25  mm (0.01 in.) thick.
Beneath the aerobic zone  the  slime layer  is anaerobic; it is there
that sulfide generation generally  occurs. The thickness of the
sulfide-producing  zone is generally of  the order of 0.25 mm
because of the lack of a  nutrient  supply. As long as the surface
of the slime layer is aerobic, sulfide  diffusing out of the
anaerobic zone will be oxidized there  and no sulfide will be found
in the wastewater stream  unless it is  from some  extraneous or
upstream source.

However, if the oxygen concentration in the wastewater drops to a
low level, generally a few  tenths  of a  milligram per litre, not
enough oxygen will enter  the  surface of the slime layer to oxidize
all the sulfide that is produced and some can escape into the
wastewater.
                                                              Odor - 3

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                                             TABLED
                                        ODOROUS  SUBSTANCES
                                  Formula
                          Characteristic Odor
                            Odor
                          Threshold
                          	(ppm)
    Acetaldehyde

    Allyl  Mercaptan

    Ammonia

    Amyl  Mercaptan

    Butylamlne

    Chlorine

    Chlorophenol

    Dibutylamlne

    Dlmethylamlne

    Dimethyl  Sulflde

    Diphenyl  Sulfide

    Ethylamlne

    Ethyl  Mercaptan

    Hydrogen  Sulflde

    Indole

    Methylamlne

    Methyl Mercaptan

    Propyl Mercaptan

    Pyrldine

    Skatole

    Sulfur Dioxide

    Tert-Butyl Mercaptan

    Thiophenol

    Triethylamlne
CH3 * CHO

CH2 * CH * CH2 * SH

NH3

CH3 * (CH2)3 * CH2 * SH

C2H5 * CH2 * CH2 * NH2

C12

Cl C6H50

(C4H9)2NH

(CH3)2NH

(CH3)2S

(C6H5)2S

C2H5 * NH2

C2H5 * SH

H2S

C8H6NH

CH3KH2

CH3SH

CH3 * CH2 * CH2 * SH

C6H5N

C9H9N

S02

(CH3)3C * SH

C6HSSH

(C2H5)3N
Pungent fruity            0.004

Strong garlic, coffee     O.OOOOS

Sharp pungent             0.037

Unpleasant, putrid        0.0003

Sour, ammonia-like

Pungent, suffocating      0.01

Medicinal, phenolic       0.00018

Fishy                     0.016

Putrid, fishy          .   0.047

Decayed vegetables        0.001

Unpleasant                0.000048

Ammoniacal                0.83

Decayed cabbage           0.00019

Rotten eggs               0.00047

Fecal, nauseating

Putrid, fishy             0.021

Decayed cabbage           0.0011

Unpleasant                0.000075

Disagreeable, irritating  0.0037

Fecal, nauseating         0.0012

Pungent, irritating       0.009

Skunk, unpleasant         0.00008

Putrid, garlic-like       0.000062

Ammoniacal, fishy         0.08
Odor - 4

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In order to determine what type of  odor  control  technology will be
required it is necessary to evaluate  the potential  adverse impacts
of odors emanating from possible alternative  treatment plant
sites.  This involves identifying and quantifying the character-
istics of odor that are the most important.

Unfortunately, odor evaluation is not a  well-developed science,
and there are no standard methods.  What is known is that odors
and their perception are very complex.   They  vary from compound to
compound and from person to person.   There are different
thresholds of perception for each compound and significant
variance in human reaction to increasing levels  of  specific odors
among people.

It has been suggested that- four independent factors are required
for the complete characterization of  an  odor:  intensity, charac-
ter, hedonics, and detectability.  To date, detectability is the
only factor used in the development of statutory regulations for
nuisance odors (6).

Odors can be measured by sensory methods, and specific odorant
concentrations can be measured by instrumental methods.  Under
carefully controlled conditions, the  sensory measurement of odors
by the human olfactory system can provide meaningful and reliable
information.  Therefore, the sensory  method is now  used most often
to measure odors emanating from wastewater treatment facilities.

In the sensory method, human subjects (often  a panel of subjects)
are exposed to odors that have been diluted with odor-free air,
and the number of dilutions required  to  reduce an odor to its
threshold of detection concentration  are noted.  The detectable
odor concentration is reported as the dilutions  to  the odor
threshold.  Thus, if four volumes of  diluted air must be added to
one unit volume of sampled air to reduce the  odorant to its
threshold, the odor concentration would  be reported as five
dilutions to the threshold concentration.

In recent years, a number of regulatory  agencies have established
odor discharge standards on the basis of such dilutions.  Fortu-
nately, it appears that the composite odor of sewer gases corre-
lates well with the hydrogen sulfide  concentration.  Thus the use
of hydrogen sulfide appears to be satisfactory for  defining the
overall odor level in the air for the purpose of this modeling
exercise.

Human perception of increases in odor is not  linear, but relative
or logarithmic (7).  As for noise and light,  it  takes much more
than a doubling of concentration to create a  perception of twice
as strong an odor; but unlike noise and  light, the  ability to
perceive can diminish rapidly with  time  on any given exposure and
constant exposure can lead to an inability to perceive.  And
finally, again like sound, between  the threshold of perception and
the point at which the stimulus can do physical  harm, there is a
broad grey area of increasing nuisance,  increasing  discomfort and
increasing interference with normal and  reasonable  human activity.

                                                             Odor  - 5

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              2.  Wastewater Characteristics and Collection  System

                  The present municipal wastewater  collection  and  treatment  system
                  serves 43 communities in the Boston  regional area.   The total flow
                  and load estimates,  taken from the 1982  site options study (8) are
                  as follows:

                               Projected Average Flows (MGD)

                                                                            Total
                                                                          Average
                    Sewered    Res.  &            Special            Infil.     Daily
      Year            Pop.     Comm.    Ind.     Comm.     Until.   Inflow     Flow

      1980        1,900,700     134       44      25        4      253        460
      1990        1,950,645     137       44      27        4      273        485
      2010        2,034,400     142       43      31        4      280        500

                  The Infiltration/Inflow component is projected to be the majority
                  contributor to the total wastewater  load.  Historically, there has
                  been a significant flow increase  during  wet weather  periods.
                  Additionally there is evidence of saltwater intrusion into the
                  collection system, which has the  impact  of damping tte peak flows
                  and also changing  the characteristics  of the influent wastewater,
                  most notably by providing the higher sulfate levels  necessary to
                  bacterial sulfide  production.

                  The industrial component is estimated  at approximately nine
                  percent (9%) of the  total wastewater load.  The  impact of  the
                  industrial wastewater is primarily a function of its character,
                  rather than its volume.   Compliance with the ongoing wastewater
                  pretreatment program is necessary to reduce  the  loading of toxics,
                  organics, and shock  loads of a wide assortment of industrial
                  chemicals.

                  In addition to the wastewater component  loads itemized above, the
                  collection system  accepts septage from numerous  communities within
                  the services area.  In many cases, the septage is discharged into
                  the system at relatively remote extensions of the collection
                  system.  This particularly common from communities which are
                  partially sewered.

                  Due to the geographic expense of  the collection  system, a  signi-
                  ficant portion of  the sewage has  a much  longer detention time
                  within the collection system than might  normally be  expected.  It
                  has been estimated that  some wastewater  may be retained for two
                  (2) days prior to  discharge to the wastewater treatment facility.
                  This tends to enhance the opportunity  for  formation  of malodorous
                  compounds.
Odor - 6

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        The result of this is  that  both  the  influent to the existing Deer
        Island plant and the sewage in the High  level Sewer have been
        reported to contain high  f^S levels, at  times as high as 10 mg/1
        (8).  Although this data  base cannot be  regarded as complete or
        definitive, the figure of 10 mg/1 was  used  in the modeling for
        lack of better information.   Any future  work on odor impacts or
        mitigation should at the  outset  include  sufficient influent
        sampling and analysis  to  completely define  the extent of sulfide
        buildup.

        While the exact level  of  sulfide may be  subject to fluctuation
        based on any number of factors,  a survey (admittedly not scien-
        tific) conducted by the Winthrop Concerned  Citizens Committee
        contains many references  to  severe odor,  lending support to the
        frequent presence of objectionable levels of sulfide and/or other
        odorous compounds.   In addition, Deer  Island House of Corrections
        personnel describe objectionable odors on numerous occasions.

        It was for these reasons  that a  more formal appraisal of the odor
        impacts was conducted.

C.  Projected Conditions

    1.   Model Assumptions

        In order to predict the odor impact of the  prosed action on
        surrounding areas,  it  was decided to model  odor as a chemical
        species dispersing in  the environment much  the same as any other
        pollutant, using a Gaussian  plume dispersion computer model.
        Precedent for the use  of  such a  model for odor has been published
        by Hogstrom (9), who developed a Gaussian fluctuating-plume model
        to predict odor emission  from a  paper mill  in Sweden, and
        Clarenburg (10), who refined a Gaussian  plume model to predict
        odor complaints surrounding  a chemical plant in Holland.

        Gaussian dispersion models  essentially use  empirical formulas to
        predict dispersion coefficients  as a function of downwind distance
        and prevailing meteorological conditions.   These coefficients are
        then used to calculate concentrations at specific downwind
        receptors.

        The major shortcoming  of  this approach is that, calculated on an
        averaging period of, say, one hour, the  model predicts an average
        concentration resulting from dispersion  but does not take into
        account the random wandering of  a plume  over short-term (ca. 30
        seconds) averaging times.  The net result of this shortcoming is
        that Gaussian plume models  overpredict average concentrations, but
        would underpredict the number of occurrences of that concentration
        exceeding a particular value (i.e., odor threshold), since the
        concentration of odorous  matter  can  exceed  a value several times
        during a period when the  hourly  average  concentration is below the
        value.
                                                                 Odor - 7

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                  Another imperfection in this approach is that an odor  threshold
                  concentration must be specified for the compound of interest,  and
                  the threshold will naturally vary from individual to individual.

                  With these variabilities in mind, the analysis of odor impacts
                  using Gaussian dispersion models should be regarded as giving  only
                  approximate (probably high), estimates of average concentrations
                  and approximate (probably low)  estimates of the number of  per-
                  ceived "odor events.'  Correlations with actual observations of
                  odor events showed approximately twenty percent (20%)  error  (on
                  the low side) for the models above.  The ISC model and available
                  data are sufficiently accurate  for comparison of the relative  odor
                  impacts from a Deer Island or Long Island treatment plant, however.

                  The model chosen for this study is the Industrial Source  Complex
                  — Short-Term (ISC-ST) model, an extended version of the  single
                  source CRSTER model developed by the Meteorology Laboratory of the
                  United States Environmental Protection Agency (U.S.E.P.A.) in  1971
                  (11).  It is one of the few computer dispersion models able to
                  predict hourly concentrations from a number of area sources.

                  The ISC-ST model is designed to calculate concentration or
                  desposition values for incremental time periods of one (1) to
                  twenty-four (24) hours.  With incorporation of a year  of  sequen-
                  tial hourly meteorological data, this model'will calculate and
                  point out annual, daily and hourly concentrations in a variety of
                  formats.

                  The area source algorithm in the ISC-ST model is based upon
                  equations for a continuous and  finite crosswind line source.   The
                  general Briggs plume-rise equations are used to calculate
                  plume-rise as a function of the downwind distance.  These equa-
                  tions also can include momentum factors.

                  The source of meteorological data used was a tape of computerized
                  hourly surface observations recorded at Boston Logan Airport,
                  coupled with upper air (mixing  height) data taken simultaneously
                  at the Portland, Maine National Climatic Center Station.

                  The emission rates calculated were based upon a maximum 10 mg/1
                  concentration by hydrogen sulfide in the influent reported in  the
                  Site Options Study and an influent flow rate of 500 MGD.   If it is
                  assumed as a worst case that one hundred percent (100%) of the
                  influent sulfide is released in the plant, a total emission rate
                  can be calculated.  This was the emission rate modeled.

                  To select a specific compound to be used in this evaluation, the
                  likely emission rates of hydrogen sulfide, ammonia and methyl
                  mercaptan were estimated and compared with the thresholds  of
                  perception of each compound-.  Table 2  shows the estimated  emission
                  rates in grams per second, the  threshold of perception stated  in
Odor - 8

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            micrograms  per  cubic meter, and the ratio between the two.  The
            compound with the  highest  ratio (H2S) would be the most perceiv-
            able,  and those with lower ratios would tend to be "masked" by the
            stronger one.
                                   TABLE  2
              COMPARISON OF ODOR POTENTIAL OF SELECTED COMPOUNDS

                        Emission Rate*      Threshold**     Relative Ratio

                             g/sec              ug/m         Emission/Threshold
     H2S                     220                 .6                366
     NH3                     2400               26.0                 92
     MM                        46                4.0                 11.5
 Concentration  in  influent X flow per second.

"Converted from published volumetric threshold values in ppmv of .00047 for
  H2S,  .037 for  NH3, and  0.002 for MM.
            Odor  modeling was performed for four (4) sources in the proposed
            wastewater treatment facilities.  This analysis assumed instal-
            lation  of the conventional activated sludge system as proposed in
            the Site Options Study, draft EIS and other documents.  The
            process components studied included:

                                aerated grit chamber
                                 primary clarifiers
                              secondary aeration tanks
                                  sludge  thickeners

            In order to partition the overall emission rate among the four
            sources above, data reported by Ando (12) for concentrations of
            H2S above typical unit operations was used; emissions were
            assumed to be proportional to relative concentrations on a unit
            area  basis.

            Areas for the four component operations were taken from Option 1
            to the  Site Options Study, "All Deer Island Secondary," and were
            calculated in accordance with ISC area source instructions to
            correspond to "presented areas" aligned with the north-south
            axis.  These four area sources were then modeled as four
            co-located sources with their centers at the center of Deer and
            Long  Islands, respectively.

            The ISC-ST program was then run in a concentration mode with
            results given in micrograms per cubic meter.  Discrete receptors
            were  modeled to correspond to areas where odors are of concern.
            The eleven (11) discrete receptors are shown in Figure 1  and
            include:
                                                                     Odor - 9

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    RECEPTOR AND PLANT LOCATIONS FOR
         ODOR DISPERSION MODEL
           BEACHMCNT
                         DEER 'SLAKQ PRISON
                         DEER ISLAND
                           W.W.T R
                                         COiNT ALLERTQNJ
Odor - 10

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               Deer  Island House of Correction
                   Point Shirley (Winthrop)
                        Winthrop Beach
                        Winthrop Beach
                      Beachmont  (Revere)
                         South Boston
              Thompson Academy (Thompson  Island )
                           Sguantum
                     Houghs Neck (Quincy)
                        Peddocks  Island
                             Hull

Results and Discussion

Introductory to remarks on the results of  this study,  it should be
pointed out that  this analysis predicts the  impacts of an  'uncon-
trolled" plant.  EPA and the  Commonwealth  of Massachusetts are
committed to odor control to  the maximum feasible extent; this
analysis is, therefore, used  to  predict the  extent of  control
necessary, and not to illustrate the situation which will be in
existence.

The resultant data were evaluated by comparing each concentration
to the threshold  value reported  earlier.   A  concentration equal
to, or exceeding  the threshold value, for a given receptor, was
recorded as an odor event during which the receptor would find the
odor objectionable.  An "odor event" can then be defined  as a
concentration above the threshold of perception at a particular
receptor, arising from the treatment plant,  and carried to the
receptor by the meteorological conditions  recorded during that
hour.

Table 3 is a tally by month of odor events occurring at each
receptor for a facility located  on Deer Island.  Table 4 is a
similar tally for a Long Island  facility.

In terms of total odor events, no distinct advantage can be seen
to locating the facility at a given location, as an odor would be
detected at a populated receptor a substantial amount  of time with
the plant located at either site.

It is interesting to note that,  in some circumstances, the effect
of a Long Island  treatment plant on Winthrop is as great or
greater than the  effect of a  Deer Island plant.  This  is due to
the southernly direction of the  prevailing winds in summer and the
fact that the two plants lie  along a slightly different compass
bearings.

In order to determine that this  effect was real, three-hour
concentration averages for June  of three other years  (1975-1977)
were obtained, and approximately the same  effect was noted.
                                                             Odor  -  11

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                                            TABLE 3
                             DEER ISLAND WASTEWATER TREATMENT PLANT
NUMBER OF HOURS PER YEAR DURING WHICH ODOR WOULD BE DETECTED
MONTH
% of
123 4 56 789 10 11 12 Total Year
Deer Island Prison
Cottage ParX
Squantum
Hull
Point Shirley
Beachmont
Hough's Neck
Thompson Island
Winthrop Beach
South Boston
Peddock's Island
21 22 80 85 128 59 87 102 94 44 69 74
11 13 44 45 76 31 46 64 53 21 42 25
32 13 17 24 57 7 29 31 20 30 38 9
23 163 66 107 43 7 33 26 55 52 70 44
16 17 51 54 90 33 58 75 61 17 47 31
10 6 35 23 43 26 20 32 31 7 24 41
66 40 35 16 18 11 30 49 46 31 87 19
26 17 19 26 59 14 33 39 27 28 35 12
18 7 45 27 52 34 22 32 42 11 26 39
32 13 31 31 68 29 31 67 32 27 33 7
51 54 38 34 17 18 22 38 64 58 69 13
865 9.8
471 5.4
307 3.5
689 7.9
550 6.3
298 3.4
448 5.1
335 3.8
355 4.1
401 4.6
476 5.4
                                                                                  5195
Odor - 12

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              TABLE A
LONG ISLAND WASTEWATER TREATMENT PLANT
NUMBER OF HOURS PER YEAR DURING WHICH ODOR WOULD BE DETECTED
MONTH
% of
123 4 56 78 9 10 11 12 Total Year
Deer Island Prison 26 7 53 27 61
Cottage Park 19 2 33 23 44
Squantum 34 18 23 32 72
Hull 125 212 157 150 77
Point Shirley 26 7 42 22 51
Beachmont 21 3 38 23 46
Hough's Neck 57 62 45 39 22
Thompson Island 15 12 32 39 71
Wlnthrop Beach 25 8 45 20 47
South Boston 6 15 30 33 63
Peddock's Island 67 147 66 106 43

104 59 37 54 41 28 30 527 6.0
31 13 25 36 7 23 33 289 3.3
27 30 57 27 28 34 9 391 4.5
109 64 64 42 79 18' 207 1304 14.9
41 24 15 51 11 27 31 348 4.0
29 15 15 37 4 23 29 283 3.2
19 24 40 70 61 81 9 529 6.0
46 49 18 40 46 35 9 412 4.7
. .1
54 33 23 53 17 26 28 379 4.3
39 50 50 28 52 29 12 407 4.6
63 33 32 75 70 73 17 792 9.0
5661
                                           Odor  -  13

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                  In terms of  the  magnitude of odor generated from each operation,
                  secondary treatment  is  responsible  for only approximately five
                  percent (5%)  of  the  H2S generated.  Since a 500 MGD source was
                  modeled, as  opposed  to  the  current  350 MGD at Deer Island, the
                  predicted situation  at  Deer  Island  should be only slightly worse
                  than the current situation.  In  fact, the history of odor com-
                  plaints directed to  the Deer Island facility would seem to support
                  the need for an  odor control program at the existing plant.

                  In addition  to the number of odor events for each receptor, an
                  analysis of  the  severity of  these "odor events" must be made.  In
                  order to do  this, two types of counts were done.  Table 5 shows
                  percentages  of the predicted odor events for each receptor which
                  are above 600 and 6000  ug/m  , which might correspond to
                  "probable strong complaint"  and  "severe interference with normal
                  activity" levels (13).  While only  a few receptors show extreme
                  concentration, almost all of the receptors suggest a significant
                  amount of odor complaints, and some receptors (i.e., Deer Island
                  plant to Deer Island House  of Corrections) suggest a severe odor
                  problem (with no controls in place  as discussed above).

                  It should be recognized that not all of the sulfide will neces-
                  sarily be released,  due to  the tendency for sulfide to oxidize in
                  water containing dissolved  oxygen.  In experiments at Hampton
                  Roads, Virginia,  Waltrip reports a  release of twenty-five percent
                  (25%) of influent H2S in an  aerated prestripping process, the
                  remainder being  oxidized.   Control  of the prestripping was by
                  maintaining  7 mg/1 of dissolved  oxygen in the tank; up to fifty
                  percent (50%) release can be obtained if less oxygen is trans-
                  ferred.

                  Since the exchange coefficient of H2S is reported to be
                  seventy-two  percent  (72%) of the oxygen exchange coefficient (2),
                  and oxygen was transferred  in excess of the amount of sulfide
                  oxidized in  the  above experiments,  evidence would seem to indicate
                  that, while  direct calculations  of  sulfide release are impractical
                  due to the uncertainties in design, a figure of twenty-five (25)
                  to fifty (50) percent release is not impractical.  In fact, the
                  equilibrium  value of H2S in air  in  contact with a 10 mg/1
                  solution of  H2S  at pH 7.0 and twenty (20) degrees Centigrade is
                  2730 ppm (2), or twenty-seven percent (27%) volatilization into an
                  equal volume of  air.

                  Figures 2 and 3  show the percent of total hours at which a
                  positive concentration  was predicted, as a function of logio
                  H2S concentration (in other words,  every unit change to the
                  right on the x-axis  represents a multiplication of ten) for
                  selected receptors for  a Deer Island and Long Island facility,
                  respectively.
Odor - 14

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                                          TABLE  5
                                                   EENTSWOnLDEXCEED
Deer Island Prison





Point Shirley




Hinthrop Beach




Cottage Park





Beachmont




South Boston




Squantun





Hough's Neck




Peddock's Island





Hull




Thompson Island
                     TWO CONCENTRATIONS OF H ?S AT SELECTED RECEPTORS





                        FROM^ALTERNATIVE_TgEATMENT_PLANT_LOCAT10NS








                                      Treatment Plant Location
                              Deer Island
	Long jsj.and
600* ug/m3 6000** ug/m3
8.1 % 4.3 %
1.5
1.0
0.5
1.3 0.3
0.4
__
0.6
0.5
1.3
0.3
iP_2_E2/5l*. 6000 ug/m3**
1.2 %
0.7 0.2 %
1.0 0.2
0.3
0.5
._
1.2
2.3
1.7
2.2
1.6 1.0
                          *  Probable strong complaint




                          ** Severe interference with normal activity
                                                                      Odor  -  15

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Odor - 16
                                                                            Pb

-------
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-------
                  Figures 2 and 3 have been adjusted to reflect an emission  rate  of
                  25% of the incoming sulfide.  The effect of this is shift  the
                  maximum of the curves about half a log unit to the left.   The
                  significance of this is that by adjusting the emission rate to
                  reflect a more realistic release concentrations predicted  for some
                  receptors are still at best three orders of magnitude above
                  commonly accepted threshold values.

                  For both situations,it can be seen that the majority of time
                  during which H2S could be detected, concentrations would be
                  approximately three (3) to four (4) orders of magnitude over the
                  reported threshold.  For the situation at Deer Island facility's
                  impact on the Deer Island House of Corrections, the data suggests
                  that concentrations are often well above the range at which
                  complaints would be expected, and approach the level at which some
                  physiological reactions could be expected.

          D.  Mitigation

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

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

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

              3.  A thorough investigation of state-of-the-art odor control  tech-
                  nologies undertaken as part of the facilities planning process.

              By making every effort to apply reasonably available technology
              designed to achieve a high degree of efficiency, it is the opinion  of
              the authors that a reasonable and effective mitigation of odors can be
              achieved.  Due to the proximity of the Deer Island House of Correc-
              tions, it is possible that odor could reach levels at which complaints
              could arise; however, should the above mitigation strategy be  applied,
              it is expected that these occurrences would be  rare.

              Literature available on the control of odors from municipal wastewater
              treatment facilities is limited, and often takes the form of state-
              ments such as "properly designed and operated sewage works employing
              good housekeeping practices should not pose an odor problem."   While
              these are important factors in helping to control sewage plant odors,
              the preceding analysis demonstrates that the incoming 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.

              Control of the impacts of odors can include designing the wastewater
              collection systems to minimize odor generation, or the application  of
              effective odor control technologies and procedures.
Odor - 18

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The collection system in the greater Boston  metropolitan  area  has  been
described earlier as contributing greatly to the  magnitude  of  the  odor
problem.  Since it is already in place,  however,  little can be
accomplished in terms of mitigating design.   Relocation of  people  and
activity would be an expensive and inappropriate  solution in Boston
Harbor due to the large area affected.

It is therefore apparent that the application of  specific technologies
for odor control should be explored. These  control  strategies can
take the form of (a) prevention of odor  formation or chemical  destruc-
tion of odor within the collection system itself,  or (b)  treatment of
odor by a specific process for that purpose  at the plant, either by
collection and treatment of odorous gases or treatment of the  bulk of
the wastewater.

The preceding analysis has projected that the odor impacts  of  a
combined wastewater treatment facility in Boston  Harbor would  be
significant regardless of the siting option  chosen.  The  concentra-
tions of hydrogen sulfide predicted by the modeling  range from 3 to 4
orders of magnitude above the reported odor  threshold for significant
amounts of time.  The level of "removal'  or  "treatment" of  odor is a
difficult number to specify and depends  to some degree on the  legal
and sociological ramifications of the odor problem (i.e., odor ordi-
nances, etc.).  No specific guidance on  "acceptable" odor levels is
available in Boston, but in order to meet a  level  of mitigation such
as that required to produce a result as  described above,  a  removal
efficiency of 99.9 - 99.99 percent must  be obtained, and  the discus-
sion which follows should be evaluated in that context.
                                                                  Odor  -  19

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              Treatment or prevention within the sewer system takes the form of
              addition to the sewers of chemicals which act as oxidizers,  chemicals
              that raise the oxidation-reduction potential (ORP),  bactericides, or
              masking agents.

              The most common additive is chlorine.  Its effectiveness depends
              primarily on its bactericidal and oxidizing properties when  added to
              sewers to control sulfide formation.  By maintaining the ORP at
              positive (150-200 mv) levels, the inhibition of sulfate-reducing
              bacteria is accomplished, usually with less chlorine than that
              required to theoretically oxidize sulfide present.

              Chlorine can be added as a gas or as hypochlorite solutions.  Sodium
              hypochlorite, the usual solution, would be preferred as the  handling
              of chlorine gas may present maintenance problems and safety  risks if
              done in residential areas.  Trade-offs in its use include higher cost
              and somewhat lower effectiveness than chlorine.

              Reports on the use of chlorine for odor control in sewers are mixed.
              While several authors report it to be effective in smaller systems,
              particularly all gravity sewer systems, Waltrip noted a rapid regrowth
              of sulfide-reducing bacteria and concomitant increases in sulfide
              concentration within one or two miles of the addition point, in a
              sewer system described previously as being more similar to Boston's.
              Waltrip also evaluated the addition of chlorine directly to  the
              incoming wastewater, and concluded that, while capable of reducing
              sulfide levels to zero, this method required large volumes of chlorine
              and is precluded by expense.

              Determining an appropriate scheme for addition is largely a
              trial-and-error process for each individual collection system.  The
              remote headworks in the Boston system have been reported as  sources  of
              odor, so any evaluation of chlorine addition should include  addition
              directly to the headworks.

              In terms of expense, an assumption of the addition of chlorine or
              hypochlorite directly to the headworks of the plant would most likely
              be the worst-case assumption.  At a chlorine cost of $0.15/lb deli-
              vered in tank cars, and assuming 10 mg/1 of hydrogen sulfide, chemical
              cost for this option would be on the order of 20 million dollars
              annually; addition of chlorine upline could be on the order  of 25 to
              50% of that figure.  The cost of appropriate metering and delivery
              systems would add to that figure based on location(s) of addition.

              The expense of hypochlorite use in place of chlorine would depend on
              where addition would take place.  Upline addition could add  approxi-
              mately 25% to the chemical cost, while savings could be achieved at
              the plant by on-site generation of hypochlorite from seawater.  Such
              an analysis is beyond the scope of this document.
Odor - 20

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In terms of other chemical additions upline,  permanganate  and  hydrogen
peroxide have been attempted.   Waltrip reported  that  hydrogen  peroxide
addition was much more costly  than chlorine  (ca.  45%)  due  to a higher
peroxide consumption than theoretically assumed,  probably  due  to
sulfide being oxidized primarily all the way  to  sulfate.

In summary, methods of treatment upline in the sewer  system can be
costly, and in terms of the removal necessary to  eliminate off-site
odors, could not be relied upon consistently  as  the only means of odor
control.  Such methods may be  appropriate as  supplemental  control
measures in the event of very  high sulfide levels or  as control
methods at the remote headworks;  however, treatment within the plant
can take the form of precipitation of sulfide in  the  wastewater liquid
or containment and treatment of odorous air.

Precipitation with Ferrous Sulfide was evaluated  by Waltrip.   Incom-
plete sulfide removal was obtained at costs equivalent to  peroxide
addition; the iron also contributed to clinker formation in subsequent
sludge incineration.

Containment and treatment of odorous air can  be  accomplished either by
covering all of the odorous operations at the plant and scrubbing the
captured air, or by aerating the wastewater  in a  process specifically
designed to strip volatile and odorous compounds.  Both of these
options would have as their limiting efficiency  the efficiency of the
scrubber proper.  Differences  in cost would primarily  be the cost of
extensive cover area for the first option traded  against the expense
of the separate covered aeration basin for the second.  In either
case, however, costs are likely to be similar to  those for total
chemical treatment as described above:  costs for covering the plant
and scrubbing with sodium hypochlorite are estimated  at 18 million
dollars as opposed to approximately 13 million for the preaeration
process; these costs are only  order-of-magnitude  estimates of  pur-
chased equipment costs exclusive of engineering  costs, minor pipework,
etc., and contractors' fees and contingencies, .and should  be regarded
as being plus or minus fifty percent.

Scrubber efficiencies depend on the chemical  reaction  chosen and the
feed rate of that chemical; the Water Pollution  Control Federation
reports in its Manual of Practice No. 22 that typical  hypochlorite
scrubbing can be expected to remove 98% of hydrogen sulfide and 90% of
mercaptans.  If the option chosen is preaeration,  then slightly more
than two orders of magnitude of reduction could  be expected, or 99.5%
of the influent sulfide would  be released, leaving 0.5% as a point
source to.the atmosphere.  This reduction would  not necessarily be
sufficient to ensure that no odor would be detected offsite, as the
distribution of odor events is skewed toward  the  high  concentration
(see Figures 2 and 3).

It is possible that some prechlorination followed by  an air stripping
process could reach effective  removal rates.  Moreover, the design of
                                                             Odor  -  21

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             scrubbers to removal efficiencies well beyond those dictated by
             conventional economic trade-offs could also achieve three-order-
             of-magnitude removals, but likely at order-of-magnitude higher costs.

             This  assessment has not included any mention of control of volatile
             organic compounds.  It is likely that any such compounds present would
             also  be air-stripped along with the sulfide, but would not be effec-
             tively removed in a hypochlorite scrubber.  Inclusion of an activated
             carbon system after the scrubber could control VOC's as well as
             function a a polishing column for the scrubber tail gas.

             The authors feel reasonably confident that the installation of such a
             system (i.e., hypochlorite scrubbing followed by activated carbon
             polishing) can achieve the degree of mitigation necessary.  Costs for
             such  an integrated system are difficult to assess without a detailed
             analysis such as will be necessary during facilities planning, but
             should be no more than fifty percent (50%) higher than those estimated
             for scrubbing alone.  As further investigation proceeds as part of the
             facilities planning process, other options and refinements will
             doubtless become available.

             A  detailed economic analysis of the cost and benefits of all of these
             systems is beyond the scope of this evaluation.  The preceding
             discussion does, however, serve to illustrate that the odor impacts of
             such  a facility in Boston Harbor are severe, and that conventional
             add-on technology may not be sufficient to mitigate these impacts.

             The applicant should be required to complete a thorough examination of
             odor  control technologies including appropriate pilot-scale work, if
             necessary, and subsequently present a detailed plan for odor miti-
             gation.
Odor - 22

-------
APPENDIX 0-1
                                   Odor - 23

-------
                 Option 1:  Covered Plant, Hypochlorite Scrubbers
  1.  Air Flows

      a.  Preliminary Treatment
              Grit chamber 400' long x 4.5 CFM/L.F. =              1,800
              Assume from sewer gas                               10,000
              Grit & screen 50'xlOO'x20' - assume 6 air chgs/hr   10,000
                                                                  22,000

      b.  Primary Treatment

              Area = 385,000 ft.2
              Assume:  31 freeboard.
                       1 air chg/hr                               20,000

      c.  Secondary Aeration

              Air at 1500 ft3/lb. BOD5
              BOD5 at 600,000 Ib/day
              Assuming 145 mg/1                                  625,000
                                                                 667,000 cfm

   2.  Covers

          Preliminary treatment area                10,000 ft2
          Primary treatment area                   385,000
          Secondary treatment area                 495,000

                                                   890,000 ft2

          Fiberglass sandwich panels 314.75/ft2 (1) =        313,100,000

   3.  Scrubbers

      a.  Glass-reinforced polyester
          50,000 cfm capacity = S100,000<2)
                                x 14 scrubbers =              $1,400,000

      b.  Installation including inlet/outlet piping
                                factor of 2.5 =                3,500,000

      c.  Piping, duct work, fans, controls
                                10 x 60,000 cfm(3) =             300,000
                         assume 1000' x 30'(1) =                  40,000
                                4000' x ID'*1* =                  26,200
                                                                 366,200
Odor - 24

-------
4.  Total Capital = 318,366,200

5.  O&M

        Chemicals(4)                          $2,345,000
        Power Est.                                50,000
        Labor Est.                                30,000
        Maint. Est.                               30,000
                                              $2,455,000


References:

          Construction Cost Data, 1985.

          from Stationary and Mobile Sources.

    Plant Design and Economics for Chemical Engineers.
                                                                     Odor - 25

-------
                         Option 2;   Preaeration,  Scrubbing
  1.  Tankage
          45 min. detention time x 500 MGD = 15.6 million gallons
              4x4 M.G. = $3,750,000<2)

  2.  Blowers, Diffusers

          Blower fans, 10 x 12,500 cfm(3)                      3,000,000
              2.5 x for controls, installation                 7,500,000
          Diffusers est.                                       1,000,000
                                                             $11,500,000

  3.  Covers 20' x 312' x 10' depth
             20' x 312' = 6250 ft2 X $14.75/ft2 =                $92,000

  4.  Scrubbers

          @ 250 cfm/MGD = 125,000 cfm
              Assume 3 x 50,000 cfm capacity =                   300,000
              Installation 2.5 factor =                          750,000
          Piping, ductwork, controls (factored from Option 1)     80,000
                                                               1,130,000

  5.  Total capital = 312,720,000

  6.  O&M assumed similar to Option 1.
Odor - 26

-------
                                   REFERENCES
1.  R. Leffel, ed.; "Odor Control for W.astewater  Facilities,"   Manual of
    Practice Number 22; Hater Pollution  Control  Federation (1979).

2.  "Process Design Manual  for Sulfide Control  in  Sanitary Sewerage Systems,"
    U.S. Environmental Protection Agency  Technology  Transfer  (October 1974).

3.  P. Cheremisinof f , R. Young; lnd^H£i.£i.£i_2l££_Ze-£llH£i22Z._*££.e.§.£EeJll'  *nn
    Arbor Science Publishers, Inc., Ann  Arbor,  Michigan  (1975).

4.  G. Waltrip, E. Snyder;  "Elimination  of Odor  at Six Major  Hastewater
    Treatment Plants," presented at the  57th  Annual  Conference of the Water
    Pollution Control Federation, New Orleans,  Louisiana  (1984).

5.  Personal communication, H.W. Byers,  General  Manager of the North Shore
    Sanitary District, Gurnee, Illinois  (August  1985).

6.  G. Leonardos; "A Critical Review of  Regulations  for the Control of  Odors,"
    JAPCA, Volume No. 5 (1974).
7.  L.E. Source, B.R. Efcstrand; P£^cho^o2£_t_Jt^s_P£^ncJL2a^s_and_Mean^£2£ /  Holt,
    Rinehart and Winston  (1978) .

8.  "Nut Island Wastewater Treatment  Plant  Facilities  Planning Project, Phase I
    - Site Options Study," Metcalf and  Eddy  (June  1982).

9.  U. Hogstrom; "A Method for  Predicting Odor  Frequencies  From a Point
    Source," Atmos . Environ . 6:103-121  (1972).

10. L.A. Clarenburg; "Penalization of  the Environment  Due to Stench.   A Study
    of the Perception of Odorous Air  Pollution  by  the  Population," Atmos.
    Environ. 7:333-351  (1973).
11 •  °£££l£_H£JJH£i_i£I_Sln3le_Source_^CRSTER]__Modei,  EPA-450/2-77-013,  D.S.
    Environmental Protection Agency  (1977).

12.  S. Ando; "Odor Control of Wastewater  Treatment  Plants,"  Journal WPCF, Vol.
    52, No. 5 (1980).

13.  C. Koe, D. Brady; "Quantification  of  Sewage  Odors,"  NTIS PB-84-1 16169.
                                                                              Odor - 27

-------
II-3
 noise

-------
II-3  NOISE

    A.  Background

        Comments on noise  can  be divided  into three categories:

        1.   Were baseline  noise conditions in Winthrop measured properly?
        2.   Were the forecasts of  noise done fairly and accurately?
        3.   Would noise mitigation be feasible during construction, and later
            during operation?  By  what means?

        Review of the issues indicates that the Havens and Emerson measure-
        ments for Winthrop, as reproduced in the SDEIS, do portray existing
        conditions accurately, and that the forecasts of construction noise in
        the SDEIS appear to be somewhat understated.

    B.  Baseline

        Comments on baseline conditions centered around the methods used to
        measure existing noise levels, as described in the SDEIS.  Three
        specific aspects of the data were questioned:

        1.   Were ambient noise levels at  Point Shirley overstated?

        2.   Was noise from the Deer Island Pump Station the cause of high
            early morning  noise levels at Point Shirley?

        3.   Were noise levels  within the prison high enough to negate the
            impact of construction noise?

            a.  Ambient Noise  Levels at Point Shirley

                To explore the first question, several sets of measurements
                were made  including three 24-hour periods at Deer Island,
                Point Shirley, and Cottage Hill by Cavanaugh Tocci Associates,
                Acoustic Consultants on September 1985 and a series of fifteen
                readings were  made in the Point Shirley area, i.e., by
                Thibault/Bubly Associates, on June 12, 1985, from 12:46 a.m.
                to about 2:00  a.m.  The results are shown in Table N-l and
                N-2.   The  Cavanaugh Tocci measurements show the quietest
                conditions observed during the stated time periods; the
                Thibault/Bubly measurements show the average of five minute
                observations at the stated time periods.  Most of the readings
                were higher than those reported in the SDEIS (Havens and
                Emerson readings)  and indicate that the SDEIS reports for
                Point Shirley  did  not overstate the ambient conditions.
                                                                        Noise - 1

-------
                                      Table N-l
                    LOWEST MEASURE Lgg NOISE LEVELS AND APPLICABLE
                         LIMITS AT NOISE MONITORING LOCATIONS
                                        (dBA)
       Locations
    1.   Engineer1s  Res.

    2.   Tafts St.
    3.   Terrace Ave.
  Zoning
Residential/
Industrial
Residential
Residential
Lowest
Measured
    hour)

 Daytime^
 48 dBA
 49 dBA
 49 dBA
    City of
Boston Limit2
   65 dBA
   60 dBA
   60 dBA
    1.   Engineer's  Res.

    2.   Tafts St.
    3.   Terrace Ave.
Residential/
Industrial
Residential
Residential
                                               Nighttime
 44 dBA
 34 dBA
 39 dBA
   55 dBA
   50 dBA
   50 dBA
    1 7:00 a.m.  to 6:00 p.m.
    2 Noise Code for the City  of  Boston  (Chapter 11)
    Source:   Cavanaugh Tocci  Associates,  Inc.
Noise - 2

-------
                                  Table N-2
                 Early Morning Outdoor Ambient Noise Levels
                      In the Vicinity of Point Shirley*
                                    (dBa)
      Site                12;46 am**         1:36  am**            1;58  am**

First House                  46               47                   47

End of Shirley Street        46               48                   46

Seawall @ Yirrell Beach      54               51                   36

Brewster Ave. @ Bayview      43               41                   44

Mugford                      40               38                   39
 *A-weighted Leg levels recorded by  Thibault/Bubly  Associates during
  Wednesday, June 12,  1984.   All readings  were  taken  between aircraft  flights.

**Noise readings were  begun  at this  time.   After  a  five minute  reading at
  1 site was taken,  Thibault/Bubly Associates proceeded to  the  next site.

Source:  Thibault/Bubly Associates
            b.  Noise Contribution  of  Pump  Station

                To explore the possibility  that  the  Deer  Island  Pump Station
                contributed significantly to  the ambient  night-time noise at
                Point Shirley, noise  levels were measured along  the roadway
                from the pump house to the  first house on August  7, 1985
                between 3:00 A.M. and  4:50  A.M.

                Figure N-l shows  the measured noise  levels  (solid  line), and
                the maximum levels  that could be attributed  to the Pumping
                Station (dashed line).  The maximum  levels are based on the
                normal attenuation  of  a close-in reading  with distance.  The
                reading at the first house  is approximately  9 decibels higher
                than the level that could be  attributed to Pumping Station
                noise; therefore, the  Pumping Station is  not likely to be a
                major contributor to  ambient  nighttime noise at  Point
                Shirley.  Possible  sources  of the background noise suggested
                by the data collector  included the lapping of waves on the
                nearby riprap shoreline and the  general urban background noise
                across the harbor.
4678f         .           '                                                Noise - 3

-------
              90
              70
              SO
                                                                                 Figure N-L
                                                                   X = ^(XIWP LSVEW MEWUKEP * /trf ^ ftftr B--hy
                                                                               utf < Kjur t^^t it30
                                                                                 /
-------
        c.   Noise Levels  in the  Prison

            Finally on the level of  noise  within  the prison, a survey was
            made on August 24, 1985,  between  9:30 a.m. and 11:45 a.m.
            Twenty-two measurements  were made,  (see Table N-3) scattered
            through the various  buildings, on all floor levels and in a
            variety of room uses.  The  median indoor noise level was 55
            dBA, with 50% of the measurements between 51 and 61 dBA.  The
            quietest areas were  unused  spaces,  the chapel and the infir-
            mary.  The noisiest  were a  dining hall, a kitchen, and an
            administrative office (typewriters  and telephones).

            These levels  are below the  66  dBA that would impede communi-
            cation (Beranak, Leo L.,  Noise and  Vibration Control, 1971),
            and appear to be typical  for institutional buildings.

C.  Impacts

    Three areas of forecasted noise  were questioned:

    1.  The cumulative effect of multiple  pieces  of construction machinery.

    2.  The effect of increased  traffic along truck routes.

    3.  Operational noise of a secondary plant.

        a.   Construction  Noise

            Analysis of noise of construction machinery indicates that the
            levels predicted in  the  SDEIS  may be  less than would probably
            occur.

            The SDEIS based its  estimate of average noise that would be
            generated during construction  on  an assumption of 10 pieces of
            heavy equipment, each generating  75 dBA (at 50 feet), working
            simultaneously and then  compared  the  result with the require-
            ments of the  City of Boston Noise Control Regulation which
            permits up to 75 decibels 10%  of  the  time.
                                                                    Noise - 5

-------
                                                       Table  N-3
                               NOISE LEVELS RECORDED AT DEER  ISLAND HOUSE OF CORRECTION
                           MEDIUM SECURITY PRISON ON DEER ISLAND, WINTHROP, MASSACHUSETTS
                                Measurements taken 8/29/65 between 9:30 and  11:45  p.m.
                                    by Peter Bates using a Bruel & KJaer Type 2230
                                       Precision Integrating Sound Level Meter,
                                           Serial #1033258. tested 4/23/85.
Building
HII 1 Prison
Hill Prison
Hill Prison
Hill Prison
HI 1 1 Pr Ison
HIM Prison, W Wing
Hill Prison, W wing
HIM Prison. W king
HII 1 Prison, W Wing
HIM Prison. W Wing
HII 1 Prison, W Wing
Dora 1
Dorm II
Admin. Building
Admin. Building
Admin. Building
Admin. Building
Admin. Building
Admin. Building
Rom
Bel 1 To»er
Dorm 16, Lev. 1
Dorm to. Lev. II
Dorm ft. Lav. II
Inflrirary
1st Tier
2nd Tier
Vd Tier
4th Tier
5th Tier
Inmates ' Dining Hell


SC03E Roan
Admin, and Records
Super Int. 
-------
To test the validity of the conclusion,  two  independent
evaluations were made.  On one,  an examination  was  made  of
both the number of pieces of heavy equipment likely to be used
10% of the time and of the noise that each piece  of  equip-
ment would be likely to emit.

To determine the number of pieces of equipment,  it  was assumed
that all or nearly all of the  equipment  on the  site could be
in use 10% of the time.  A review was then made in  R.S.  Means,
Building Construction Cost Data,  1985, of  the ratio of
construction equipment to construction workers  for  the kinds
of construction activities likely to be  on the  site.  Overall,
this ratio appeared to be 1 to 7  or 8.   Application of the
ratio to the 600 workers (average) estimated for  the project
in the SDEIS yields about 80 pieces of equipment.   (It should
be noted that the exact number is not important since doubling
the number would increase the  perceivable  noise by  only  3
decibels and halving the number  would reduce the  perceivable
noise by only 3 decibels. )

To verify the noise levels of  individual pieces of  equipment,
telephone contacts were made with Caterpillar Tractor and John
Deere Company, manufacturers of  the kinds  of equipment
typically used in heavy construction. Caterpillar  supplied
noise levels expected to be emitted by a range  of their
current products.  These levels  were in  the  mid-801s range.
                                                         Noise - 7

-------
                                       Table N-4
                          Noise  Levels of Representative Pieces
                       of Heavy Construction Equipment,  1984-1985
                              (Sound Pressure Level  §  50')

     Front Loader                 1984-85 Models  (dBA)        Earlier  Models  (dBA)

         973                             86                           87
         953                             86                           90

     Dozers

         D7g                             84                           84

     Graders

         14g                             82
         12g                             84                           88

     Scrapers

         631                             84                           89
         621                             85                           90
         633                             86                           86

     Source:  Catepillar Tractor Company
                 To calculate the effect of eighty pieces  of  equipment,  each
                 emitting, 85 dBA at 50 feet,  a  virtual  peak  was calculated for the
                 center of the construction site using Weber-Fechner's Law of
                 Perception and then attenuated  off-site for  distance, as a point
                 source.

                       i.  85 dB = 10^-5 relative sound  energy  units  (by defini-
                           tion of the decibel)

                      ii.  10^*5 x 80 = lol°'4 relative  sound energy  units

                     iii.  1010-4 relative sound energy  units = 104 dB

                 At the distance of the closer side of the prison this virtual peak
                 would moderate to about 75 dBA; at the  first house in Point
                 Shirley to about 62 dBA;  and  to the northwesternmost house in
                 Point Shirley to about 53 dBA,  taking into account the  shielding
                 effects of the intervening houses.

                 In the second evaluation, sound power levels were calculated for 2
                 specific mixes of equipment expected to be used during  construc-
                 tion.  Table N-5 shows the mixes of equipment, while Table N-6
                 shows their anticipated noise impacts under  various  assumptions of
                 equipment use and site conditions.

                 Table N-7 compares the two evaluations.

Noise - 8

-------
                                  Table N-5
               Construction  Equipment Sound Power Levels for the
                    Most Significant Site Preparation and
                         Building Construction  Phases
Equipment
  Items
Source-3
Lw in dBA
re:  Ipw
(per item)
30 yd. trucks             114
Misc. Matl. trucks        114
12 yd. cone, trucks       114
Headache Ball for Crane
  use for Demolition
Loaders
Track Drills (rock)
4 yd. shovel
Scraper
D8-Dozer
(119)
60 Ton Crane
600 HP Portable
Compressor Dewatering
  Equipment Including
  Emergency Portable
  Generator               107
Portable 200 kw
  Generator               102
Dock Conveyance
  Facilities              100
Concrete Pump             111
1000 yd/day Concrete
  Batch Plant             110
Form yd. Sawmill
  Carpenter Shop          109
Total A-Weighted
  Sound Power Level
  in dBA Re:  1 picowatt
Usage-
Percent

  50
  50
  50
111
121
111
114
114
111
102
100
50
50
50
100
100
50
               100 (24 hrs.)

               100 2

               100
                50

               110

               100
*Total Quantities of Equipment given in  parenthesis.
Construction Scenarios
  Phase I
    Site
 Preparation*
                                  (15)  123
                                   (4)  124
                                   (4)  114

                                   (2)  117
                                    4  (105)
                      1 (100)
                                  127
Phase II
Building

(10) 121
(12) 122
 (6) 122
                                                (2)  114
                                  (4)  (117)
                                   3

                                   4 (117)
                  1 (107)

                  6 (110)
                                  (1)  110

                                  (1)  109


                                 127 4
Notes:

 ^Impact noise level not considered  a  problem

 2Two generators running 24 hours.

 ^Noise levels for "Quiet Products,  Level  1,"  from  BBN  Report  2887.

 4If total quantities of equipment were  operating the total  sound  level
  would be 3 dB higher.
                                                                         Noise  - 9

-------
                                       Table N-6
                   Construction Equipment Sound Power Levels for the
                         Most Significant Site Preparation and
                             Building Construction Phases

                                                    Range of
                                 Lowest            Estimated            Total
                                Measured          Const. Noise          Noise
     Location                    L^n (Ihr)^-        Levels - dBA         Level^

     Daytime

     Engineer's Residence          58                44-54               58-59
       (Deer  Island)
     Tafts Street  (Pt. Shirley)    60                41-51                  61
     Terrace  Ave.  (Cottage Hill)   63                30-40                  63
     Prison                        60 3              59-68               63-69

     Source:  Cavanaugh Tocci Associates.

     Notes;

     ^Without aircraft noise.
     ^Applicable to noise at site.
     3Estimated.
                                       Table N-7
                              Expected Construction Noise
                                Deer  Island & Vicinity

                                       TBA Evaluation         CTA Evaluation

     Power Level  (all equipment)            131 dBA                130 dBA
     Equipment in use at least 10%
      of time (100% - deduct:               -0
                 50% - deduct:                                      -3

     Local, on-site shielding
                 50% - deduct:               -3
                 75% - deduct:                                      -6

     Sound Pressure Level 50'
      from virtual center                  104                     94

     Noise Level  @ Point Shirley
      effects of distance  (3200'^)         -42                    -43
                                            59                     51

     Noise Level  @ Prison Effects
      of distance (1,000'i)                -26                    -26

                                            75 dBA                 68 dBA
Noise - 10

-------
    At the prison,  with all  heavy earthwork  shielded  by  the
    drumlin, assuming that it is excavated from  its southern  side,
    construction noise out-of-doors would not  exceed  the Boston
    Noise Control Regulations for construction (75 dBA).  Indoors,
    this increased  noise would be about  ten  decibels  above the
    median existing noise levels if the  windows  were  open  and not
    above it at all with windows closed.

    At nearby and beachfront portions  of Point Shirley,  construc-
    tion noise would not exceed the City of  Boston construction
    noise standard, whatever set of assumptions  is used, and
    therefore is considered  acceptable to EPA.

    At Nut Island,  an adjustment of 10 dBA added to the
    non-pile-driver noise levels calculated  in the SDEIS to
    account for the louder equipment likely  to be used,  would
    produce some 82 dBA in the adjoining residential  neighbor-
    hood.  This noise level  is seven dBA above that allowed by the
    Boston Noise Code and is considered  unacceptable  by  EPA for
    the five year construction period  that would be required  for
    the Split Deer  Island/Nut Island alternative but  acceptable
    for the shorter construction periods at  Nut  Island associated
    with demolition of existing structures for headworks options.

b.  Noise Impacts of Construction Traffic

    With all bulk materials  required to  be barged, the maximum
    normal traffic  to be induced by construction is not  likely to
    average more than 25 truck and bus round trips per day.   With
    each vehicle perceivable above background  noise levels for
    less than one minute per trip, the cumulative impact would not
    be significant.

    Lighter vehicle traffic  (automobiles, pick-up trucks,  etc.)
    would be generally indistinguishable in  character from
    existing traffic.  Since it requires a doubling of such light
    traffic to increase background traffic noise by three  decibels
    and since no such traffic increase will  occur, there can  be no
    perceptible change in background traffic noise.

c.  Operational Noise

    The noise generated by operation and maintenance  of  a  second-
    ary treatment can be significant.  However,  any plant  that is
    built will have to conform to the  City of  Boston  Noise Control
    Regulations, i.e. not over 50 dBA  in residential  areas at
    night and 55 dBA in institutional  areas.  It is feasible  to
    design the plant with adequate noise control to meet those
    requirements, enclosing the stationary machinery  that  produces
    most of the sound, so that no adverse operational noise
    impacts are anticipated.
                                                            Noise  -  11

-------
       D.  Mitigation
           Opportunity for mitigation of the anticipated construction noise
           levels at Deer Island is severely limited by the geometry of the
           site.  At the prison, shielding of outdoor ground level activities can
           be accomplished by a continuous wall immediately adjacent to the
           outdoor activity areas.  Relatively quiet areas, out-of-doors,  might
           be provided on the far sides of the larger buildings,  extended  into
           more effective barriers with new walls.

           Similarly, for the houses at Point Shirley, some shielding does appear
           possible by the construction of earthen mounds,  if sufficiently high
           and wide.  A relatively short barrier to shield  the closest group of
           houses built just below the former Shirley Gut,  from shore to shore,
           would not shadow noise very far beyond those closest houses.

           If the prison were to be partially or totally removed,  or if the sea
           adjoining the neck could be filled (see attached figure),  such  a mound
           could be made both higher and longer, improving  its effectiveness and
           reducing noise impacts over a larger area, and since it would be built
           of spoils that would otherwise have to be removed from  the island at
           relatively great expense, the mound would have little  (or even
           negative) cost.  (It should be noted that the construction of any
           noise barrier will by itself create substantial  but short lived noise
           in the areas to be protected.)
                 £   'Pdnt
                  % Shirley
                   • • •
                                              '"riloctrTed drv/ntin \
                                                       ff '
                                                            Deer "' "  ;
                                                         Res ' -.
               POSSIBLE NOISE MITIGATION BUFFER

                  POINT SHIRLEY / DEER ISLAND
Fort pWes
      \   •-
Noise - 12

-------
	II-4
recreation resource comparisons

-------
II-4  RECREATION
    A.  Background
        Comments on the  SDEIS  concerning  recreation centered around one main
        issue:

            Was the inherent recreational potential of Long Island, inde-
            pendent of park plans, actually greater than that of Deer Island?

        Evaluation  of the  opportunities for recreational development at Deer
        and  Long Islands shows that the two islands are approximately equal
        in value as potential  recreational resources.  While the type of
        opportunity offered by each island differs, and different segments of
        the  public  would be interested in visiting them, the two islands have
        comparable  overall recreational potential.
    B.   Comparison  of  Recreational Resources on Deer Island and Long Island

        The SDEIS assumed  that Long Island offers great recreational poten-
        tial and that  there  is no similar potential on Deer Island.  A
        question was raised  as to the validity of this assumption.  To test
        this assumption a  systematic evaluation of the recreational potential
        of the two  islands was undertaken.

        OEM's letter of comment on the SDEIS presents a basis of a method for
        such systematic evaluation, i.e. that appropriate waterfront recrea-
        tional activities  or values could be identified and that each island
        could be scored for  its suitability for each of these activities or
        values.  Appropriate recreational activities/values for these two
        islands include regional use such as viewing the surrounding sea-
        scapes, access to  shoreline fishing, historic displays, etc. as well
        as local use such  as playfields where not incompatible with regional
        activities.

        As a basis  of  such a systematic evaluation a brief series of maps
        were prepared  and  analyzed, including:

        1.  Site evaluation  of Deer Island

        2.  Site evaluation  of Long Island

        3.  Views from the bunker at the Southern end of Deer Island

        4.  Views from Long  Island head.

        Both islands are about the same size and both are located close to
        the harbor  entrance, both have glacially deposited "till uplands and
        both have lowlands that have been filled in by the sea.  Both are
                                                                   Recreation  -  1

-------
              accessible by a single roadway  and  both are about the same distance,
              by road or by boat from the congested  central  neighborhoods of Boston.

              The shoreline of neither island is  particularly well suited to
              swimming;  neither island adjoins any water sufficiently sheltered for
              small boat mooring in  bad weather,  but both could be accessed by
              visitor boats off President Roads.

              Both islands could be  used for  shoreline fishing, particularly if a
              deep water pier were constructed, and  at least some parts of both
              islands would easily be developed into ballfields or similar usage.

              Both islands, in their present  state,  contribute to the beauty of
              Boston Harbor, as viewed from other islands, the mainland and boats,
              but both are esthetically blighted  by  large buildings that are
              out-of-scale with the  natural terrain  (the drumlins) and with the
              general pattern of development  found elsewhere in the harbor (the
              mosaic of  small multicolored houses that hug the smooth oval forms of
              Cottage Hill, Allerton and Squantum).  Deer Island's parklike, grassy
              drumlins and bunkers are overburdened  by the monumentality of a large
              county prison and Long Island is home  to an array of hospital
              buildings  whose refuse cascades down the long ochre escarpments that
              are the hallmark of the island.  Overall, Long Island presents a
              greater aura of remaining natural settings.

              The differences between the islands, as recreational resources, for
              the most part, are matters of detail and of the various segments of
              the public that might  visit them.

              Long Island does contain some features not found on Deer Island
              including  a late 19th  century fortification on Long Island Head,
              totalling  12 acres; a  wetland and barrier beach area totalling about
              30 acres near the southwestern  end  of  the island, and a very attrac-
              tive CCC pine plantation totalling  about 12 acres, at the south-
              western tip.  None of  these by  itself  is unique; the adjoining
              George's Island contains larger late 19th century fortifications as
              well as some late to middle 19th century ones  and the largest middle
              19th century fort in North America, while the adjoining Thompson
              Island contains much more extensive and less disturbed wetlands,
              barrier beaches and sand spits.  Taken together, however, with a
              connecting walk along  the shoreline or the top of the bluffs, a
              picnic ground and a children's  play area, the  island could offer a
              most pleasant outing.

              In a similar manner, Deer Island does  offer some recreational
              opportunities not available on  Long Island, centering mostly on its
              location at the only well defined entrance point to Boston Harbor.
              It offers  a set of vistas of exceptional variety and interest.  As
              the gatepost of the harbor,  it  offers  back-to-back vistas of the open
              seas and the full extent of the harbor, both penetrated by a broad
              parade of  islands that ranges from  Castle Island to the Graves, with
Recreation - 2

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a skyline dominated to the southwest  by  the  silhouette of the Blue
Hills and to the west by downtown Boston.  No  similar view exists on
Long Island, no similar platform to see  the  relationships between
Boston, its harbor and the sea.

If the treatment plant were to be put on Deer  Island and Long Island
becomes a park, the most prominent view  from the northern end of Long
Island would be the sewage treatment  plant on  the leveled Deer
Island, unless creative siting and design were carried through to
retain a drumlinoid silhouette and buffer.   Conversely, a treatment
plant on a leveled Long Island would  dominate  the view southwesterly
from Deer Island.  In addition,  such  a plant on Long Island would be
visible not only from the ship channel as would one on Deer Island,
but also would intrude on the scene from Quincy Bay.

Looking at the islands from the  point of view  of their potential
visitors, their local neighbors,  the  surrounding regional population,
and visitors to Boston from afar,  it  can be  seen that each of these
groups has differing needs,  and  parkland would play a different role
for each.  In general, outside visitors  want to see something unusual
or that tells them something about the place they're visiting.
Metropolitan residents are interested in a pleasant, but not neces-
sarily unusual destination for a day-trip that provides an oppor-
tunity for a few recreational activities.  Local residents are more
likely to use nearby parkland frequently, in an informal manner.  For
local use, Deer Island would appear to be the  greater resource.  It
is easily accessible for field sports, fishing, walking and
sight-seeing, while there are no local residents within 1.5 miles of
Long Island.  For regional residents, either island would be a
desirable destination with Long  Island having  a slight advantage
because of its greater length of shoreline,  more extensive natural
landscapes, and the resulting opportunities  for walking.

But for the visitor from afar, as well as for  local students of
history and geography, Deer Island would appear to be a potentially
important resource.  Its specialness  as  a platform for seeing
Boston's relationship to the sea makes it also a special opportunity
for explaining, to visitor and local  student alike, how Boston came
to be a great city; that it all  started  on a group of sheltered
islands on which the original settlers could be safe from the
depredations of the Indians on the mainland; that it grew to become
the second city of the British Empire, inland  beyond cannon range,
protected by its island batteries from the French fleet just to the
north at Louisbourg; that it was selected as the principal northern
base for the infant United States Navy,  over competing New York and
Philadelphia because it was defended  by  its  islands against the
British Navy in an era when British squadrons  could and did establish
bases at Provincetown and Nantucket at will; that Boston was started
and that it grew great because of its special  place between the land
and the sea.
                                                             Recreation - 3

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                    Views from Deer Island
                                  VI y
                    Views  from  Long  Island
Recreation - 4

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                        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 acceptability of
alternative locations for the construction of new
wastewater treatment facilities for Boston Harbor.  The
FEIS recommends the construction 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
J.F.K. Federal Building, Boston, Massachusetts 02203
COOPERATING AGENCY:
GENERAL SERVICES ADMINISTRATION
TECHNICAL CONSULTANT:
THIBAULT/BUBLY ASSOCIATES
235 Promenade Street, Providence, Rhode Island 02908
FOR FURTHER INFORMATION:
Mr. Ronald Manfredonia, Water Management Division, U.S.
EPA, Region I, J.F.K. Federal Building, Boston,
Massachusetts, 02203
(617-223-5610)
FINAL DATE BY WHICH
COMMENTS MUST BE RECEIVED:

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	II-5
legal and institutional

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II-5 LEGAL AND INSTITUTIONAL ISSUES

     A.    Background

          Comments on the SDEIS raised questions about the possibility that
          the SDEIS, in characterizing the legal obstacles as "severe,"
          exaggerated the legal difficulties of acquiring the Long Island site
          for a treatment plant.  In response to these comments, EPA requested
          the Boston law firm of Warner and Stackpole to analyze the power of
          the Massachusetts Water Resources Authority to acquire necessary
          land and construct wastewater treatment facilities on both Long
          Island and Deer Island.  What follows is the firm's memorandum of
          law addressing these issues.
                                                                     Legal  - 1

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                        WARNER & STACKPOLE
                                EST. 1874

                            28 STATE STREET

                      BOSTON, MASSACHUSETTS O2IO9

TELECOPIER: (OI7) 3Z3-4BB7                                           TELEPHONE: (OI7) 725-I4OO
   TELEX: B4OI3B                                                 CABLE: WARSTACK
          AN ANALYSIS OF THE MASSACHUSETTS WATER RESOURCES
        AUTHORITY ACT AND ITS APPLICATION TO THE ACQUISITION
   AND DEVELOPMENT OF THE LONG  ISLAND  AND DEER ISLAND ALTERNATIVES
                            July  15,  1985
                             prepared by

                         Warner &  Stackpole

                                 for

                      Thibault/Bubly  Associates
                                                                 Legal -  2

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I.   INTRODUCTION



     We have been requested to conduct research and analysis of




Chapter 372 of the Acts of 1984, the Massachusetts Water Resour-



ces Authority Act (the "Act"), specifically with regard to the



provisions of the Act concerning the acquisition of land and the



development of wastewater treatment facilities by the Massachu-



setts Water Resources Authority (the "Authority").  The original



memoranda regarding the Long Island alternative, dated August 28,



1984 and the Deer Island alternative,  dated November 27, 1984,



set forth a preliminary overview of the legal and institutional



constraints affecting the acquisition and use of certain areas of



Long Island and Deer Island as the site for a sewage treatment



facility serving the Metropolitan Boston area.  Because the Act,



signed into law on December 19, 1984,  had not been enacted at the



time the original memoranda were submitted, it was not possible



to discuss the specific legal issues which would confront the



Authority in facility siting and implementation.  Also, at the



time of the original submission, certain issues involving the



presence of barrier beaches on the islands were not clearly de-



fined.   This supplemental memorandum is intended to address these



matters, and will serve to update the original memoranda.



II.  STATEMENT OF FACTS



     It is useful to reiterate certain facts regarding Long



Island and Deer Island when considering the legal impacts of the



Act and any other statutory constraints that may affect the
                                                              Legal - 3

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     transfer of ownership or future  use  of these properties.   Accord-




     ing to the Authority,  all of Long Island with the exception of the




     light house is held in fee by the City of Boston,  under the care,




     custody and control of.the City  of Boston Department of Public



     Health and Hospitals (Health and Hospitals).   Long Island cur-




     rently contains a functioning hospital for the chronically ill,



     and also contains historic and archaelogic artifacts including up




     to 2,000 unmarked graves which may be  scattered across  the island.



     A formal cemetery containing the remains of Civil War soldiers



     has also been identified on one  section of the island.   In the



     event that a siting decision is  made that involves the  sale of



     Long Island,  the care and co.ntrol of the island will revert from



     Health and Hospitals to the City of  Boston Public Facilities Com-



     mission (Public Facilities) for  disposition.   Certain of the



     treatment plant siting options which have been considered for



     Long Island would require removal of the hospital and the Civil



     War cemetery.



          Deer Island contains the Deer Island House of Correction,



     also known as the Suffolk County House of Correction,  which is



     run by and is under jurisdiction and control  of the City of



     Boston Penal Institutions Department.   According to the Author-



     ity,  certain parcels of land outside the perimeter of the cor-



     rectional facility itself are also under the  custody and control



     of the Boston Penal Institutions Department.   Deer Island also



     contains a decommissioned military installation (Fort Dawes)



     which covers the southeastern quarter  of the  island,  and which is
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currently owned by the United States Navy.  The federal General




Services Administration ("GSA") holds other federally-owned par-



cels on the island.  Other parcels of property on Deer Island are



owned by Metropolitan District Commission ("MDC"), and include




the Deer Island Wastewater Treatment Plant presently in opera-




tion.  Should facility siting on Deer Island involve land owned



by the Navy, disposition will occur through the GSA.  Under Sec-



tion 4(c) of the Act, the Authority has full rights to use and



improve real property owned by the MDC for sewer and waste treat-



ment purposes.




III. DISCUSSION



     This memorandum will first discuss the important elements of



the Act,  and then review the manner in which the Act enables the



Authority to acquire the necessary land to develop a wastewater



treatment facility in Boston Harbor.   The Act provides new powers



and limitations to the Authority which were not applicable to the



MDC, including new provisions exempting the Authority from cer-



tain state laws, and subjecting the Authority to new legislative



controls.  These distinctions will be discussed as they may affect



the ability of the Authority to undertake its mission to construct



new facilities.



     A.   General Structure of the Authority



     Under Sections 1 and 3 of the Act, the Authority is estab-



lished within the Executive Office of Environmental Affairs (EOEA)



to operate, regulate, finance and improve the delivery of water
                                                             Legal - 5

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      and  sewage  collection,  disposal  and  treatment  systems  and  servi-




      ces  and  to  encourage water  conservation.  On July  1, 1985, under




      Section  4(a)  of  the Act,  the Authority  officially  assumed  control




      over the current MDC water  and sewer system.   The  watershed divi-




      sion of  the MDC, however, was not  transferred  to the new Auth-




      ority and will operate  independently.




           The Authority is governed by  an eleven-member Board of Di-




      rectors,  whose meetings are subject  to  the  state open  meeting law




      (M.G.L.  c.  30A,  §11 1/2), regulations for the  preservation of



      public records (M.G.L.  c. 30, §42),  and the state  Freedom  of In-




      formation Act (M.G.L. c.  66, §10).   The Board  of Directors in-



      cludes the  Secretary of the Executive Office of Environmental



      Affairs  as  an ex officio member, and certain other specified in-




      dividuals appointed by  the.Governor  and the Authority's Advisory



      Board.   The Advisory Board, under  Section 23,  is composed  of rep-



      resentatives  of  the municipalities served by the Authority, whose



      votes are determined on a weighted basis according to  the  charges



      for  services  in  each community.  The powers of the Board of Di-



      rectors  and the  Authority are set  forth in  Sections 5  and  6 of



      the  Act,  with the administration of  the Authority  provided by an



      Executive Director, as  provided  in Section  7.  The Board of Di-



      rectors  has appointed a Transition Director to oversee the trans-



      ition staff prior to the Authority's formal and complete organi-



      zation.



           The Authority is authorized under  Sections 5(d) and 15 to




      issue up to $600 million of revenue  bonds and, under Section 8(i),
Legal - 6

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is deemed to be a "public entity" eligible to receive grants under

the Massachusetts Clean Waters Act and any other federal and state

statutes.

     Under Section 10(a), the Authority must set its rates and

charges to provide adequate revenue,  pay its debts and expenses

and to promote water conservation.  Section 8(e) specifically

terminates the prior practice of volume discounts.

     B.   Limitations on the Actions of the Authority

     Because of the supremacy of federal law, the Authority, like

all other state and local entities,  must obtain all necessary

federal permits and approvals to discharge emissions to air and

water, and conduct activities in the waters of the United States.

The earlier memoranda assumed the general applicability of state

environmental law to the actions of the MDC in constructing and

operating a facility on Deer or Long Island.  Because the Author-

ity was intended to be an independent public entity, however,  the

Authority is not constrained by the complete body of state law.

With respect to state law,  the Act provides, at Section 3(a),

that:

     [the Authority] shall be an independent public author-
     ity not subject to the supervision or control of the
     executive office of environmental affairs or of any
     other executive office, department, commission, board,
     bureau, agency or political subdivision of the common-
     wealth except to the extent and in the manner provided
     in this act.

Certain transactions, however, such as acquisitions of property,

are specifically made subject to other.governing laws,  by the
                                                             Legal - 7

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      provision of language stating that the transaction is to be con-




      ducted in accordance with the applicable laws and procedures.




      Section 4(c) of the Act, for example, provides that lands devoted




      to public use shall not be used or disposed of "except in all




      instances in accordance with the laws and Constitution of the




      Commonwealth."




           The majority of the environmental laws and restrictions to




      which the Authority is subject are listed in Section 8 of the




      Act.  Under Section 8(i), the Authority is subject to regulation




      under the Massachusetts Wetlands Protection Act,  M.G.L.  c. 131,



      §40; the Wetlands Restriction Act, M.G.L. c. 131,  §40A;  the Mas-



      sachusetts Environmental Policy Act ("MEPA"),  M.G.L. c.  30,



      §§61-62H; the Massachusetts Historic Preservation Act, M.G.L.



      c. 9, §§26C and 27C; the Ocean Sanctuaries Act, M.G.L.,  c. 132A,




      §§13-16 and 18; the Coastal Zone Management Act,  M.G.L.  c. 21A,



      §4A; the Water Resources Commission, M.G.L. c. 21A,  §§8A-8F; the



      Hazardous Waste Facility Siting Act, M.G.L. c. 21D,  §§3, 4, 7,



      10, and 14; and regulations for waste treatment and disposal,



      M.G.L. c. 21C, M.G.L. c. Ill,  §§150A and 150B.  It should be



      noted that Section 8(i) of the Act also contains certain general



      language, stating that the foregoing statutes and regulations



      apply "without limitation on other public health or environmental



      regulations over the Authority exercisable pursuant to other law



      without conflict with the Authority's purpose of serving critical



      public needs on a broad geographic basis . . . ."
Legal - 8

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     The Act,  in Section 8(i),  specifically identifies the pro-

grams administered by the Department of Environmental Quality

Engineering (DEQE) to which the Authority shall be subject.

These programs are:

     Air Pollution

     o    M.G.L.  c. Ill,  §2B (Air Pollution Emergency)

     o    M.G.L.  c. Ill,  §§142A to 142E (Air Pollution Regu-
          lations)

     Water Pollution

     o    M.G.L.  c. 21,*  §14 (Works of Improvement Regulated)

     o    M.G.L.  c. 21,*  §27 (Water Pollution Control)

     o    M.G.L.  c. 21,*  §§30A  to 34C (Water Pollution and
          Wastewater Treatment)

     o    M.G.L.  c. 21,*  §37 (Reimbursement to MDC)

     o    M.G.L.  c. 21,*  §40 (Entry to Investigate Pollu-
          tion)

     o    M.G.L.  c. 21,*  §§42 to 46A (Penalties and-Permits
          for Discharges  into Waters of the Commonwealth)

     o    M.G.L.  c. 21A,  §14 (Dredging Permits)

     o    M.G.L.  c. 91 (Waterways Statute)

     o    M.G.L.  c. Ill,  §2C (Enforcement of Statutes, Regu-
          lations, etc.,  relative to Pollution)

     o    M.G.L.  c. Ill,  §5E (Application of Chemicals;  Lic-
          enses,  Regulations and Penalties)

     o    M.G.L.  c. Ill,  §5G (Water Supply Treatment Facili-
          ties)

     o    M.G.L.  c. Ill,  §17 (Advice as to Disposal of Sewage)
     Section 8(i) of the Act,  as passed by the Legislature
     and signed by Governor Dukakis,- actually refers to §§14,
     27, 30A to 34C, 37, 40,  42-46A of Massachusetts General
     Laws Chapter 21A,  and not Chapter 21.
                                                              Legal - 9

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          o    M.G.L.  c.  Ill,  §31D (Provision of Facilities for
               Disposal of Contents of Privies,  etc.)

          o    M.G.L.  c.  Ill,  §160 (Examination of Water Supply
               and Rules and Penalties)

          o    M.G.L.  c.  Ill,  §160A (Cross Connections between
               Public  Water Supplies and other Water Supplies)

          o    M.G.L.  c.  Ill,  §160B (Violations of Water Quality
               Standards or Regulations)

          o    M.G.L.  c.  Ill,  §165 (Entry on Premises  to Ascertain
               Water Pollution,  etc.)

          Hazardous Waste

          o    M.G.L.  c.  21C,  Hazardous Waste Management Act,  §4
               (Powers and Duties of DEQE Division Hazardous
               Waste)

          o    M.G.L.  c.  21C,  §6 (DEQE Regulatory Authority over
               Hazardous Waste)

          o    M.G.L.  c.  21C,  §7 (License Requirements and Facil-
               ity Siting)

          o    M.G.L.  c.  21C,  §9 (Remedies for Violations of Haz-
               ardous  Waste Regulations)

          o    M.G.L.  c.  21D,  Hazardous Waste Facilities Siting
               Act, §3 (Powers and Duties of DEM)

          o    M.G.L.  c.  21D,  §4 (Hazardous Waste Facilities Site
               Safety  Council)

          o    M.G.L.  c.  21D,  §7 (Notice of Intent to  Construct
               or Operate Hazardous Waste,Facilities)
                                         \
          o    M.G.L.  c.  21D,  §10 (Preliminary and Final Project
               Impact  Reports)

          o    M.G.L.  c.  21D,  §14 (Compensation to Abutting Com-
               munity  paid by Developer)

          o    M.G.L.  c.  21E,  "Superfund Act," §4 (Response Action
               to Release or threatened Release of Oil or Hazard-
               ous Materials)

          o    M.G.L.  c.  21E,  §6 (Prevention or Control of Release
               of Hazardous Material)

          o    M.G.L.  c.  21E,  §7 (Notice Requirements)
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     o    M.G.L. c. 21E, §9 (Orders by Department, Contain-
          ment and Removal Actions, Sampling, etc.)

     o    M.G.L. c. 21E, §10 (Notice,  Adjudicatory Hearings,
          and Persons Aggrieved by DEQE Determination)

     The applicability of local bylaws and regulation is expressly

limited by the above-cited provision of Section 3(a) referring to

control by a political subdivision of the Commonwealth.   The Act

does not contain any reference to local law or regulation to which

the Authority will be subject.

     Under Section 4(f), the Act purports to exclude the Author-

ity from all liability in tort or for water pollution arising

prior to July 1, 1985.  The Authority cannot enter into  any con-

sent decree according to Section 27 without the prior approval of

the Governor and the Legislature.  The Authority, under  Section 24,

shall be represented in legal matters by the Attorney General

pursuant to M.G.L. c. 12.  Section 24 also provides that enforce-

ment actions by the Authority shall be filed in Superior Court,

and that the Massachusetts Supreme Judicial Court has jurisdic-

tion over any matter in which the Authority is a defendant and

water pollution is an issue.

     Finally, the last sections of the Act contain several refer-

ences to specific special acts intended to apply to the  Authority.

For purposes of this discussion, it is interesting to note that

neither Chapter 742 of the Acts of 1970, nor M.G.L. c. 114, sec. 17,

the "burial grounds statute" are made specifically applicable.  A

discussion of these acts, and their applicability, follows in a

later section.
                                                             Legal - 11

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           C.    Prior Public  Use  Doctrine

           Under the state  common law doctrine  of  Prior  Public  Use,

      public  lands  devoted  to one public use  cannot be diverted to  an-

      other inconsistent public use  without a majority vote  of  approval

      by the  Legislature.   Robbins v.  Department of Public Works, 335

      Mass. 328,  330 (1969).   The Act contains  several provisions apply-

      ing the Prior Public  Use doctrine to actions of the Authority.

           The first mention  of the  Prior Public Use doctrine is made

      at Section 4(c)(ii) of  the  Act,  which provides that:

           .  .  .  no lands devoted to a public use  shall  be divert-
           ed to another inconsistent public  use,  except in  all
           instances in accordance with the laws and the Constitu-
           tion of  the Commonwealth.

      The doctrine  is referred to again in Section 9, which, at Subsec-

      tion 9(a),  restricts  the Authority's eminent domain power:

           .  .  .  no property  or rights already  appropriated  to
           public use shall be so taken without the prior approval
           of the governor  and, general court.

      With respect  to selling, leasing or disposing of Authority prop-

      erty, the Authority was also made explicitly subject to the Prior

      Public  Use doctrine under Section 9(c).

           The provisions of  Section 9(a) are important  because they

      modify  the traditional  requirements of  the Prior Public Use doc-

      trine to require gubernatorial approval,  as  well as legislative

      approval,  of  proposed changes  in use.   Theoretically,  approvals

      of use  changes governed by  the Prior Public  Use doctrine  (as  well

      as acquisition of lands protected by Article 97) could, with  an

      adequate legislative  vote,  overcome a governor's veto  of  initial

      legislative approval.   With respect to  the Authority,  however,
Legal - 12

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gubernatorial approval, as well as legislative approval, is a




prerequisite for such changes in use.




     The fact that the Authority is made subject to the Prior



Public Use doctrine also lends support to the argument that, not-




withstanding the absence of explicit language in the Act regard-



ing the applicability of M.G.L. c.114, §17, the Authority must




comply with the provisions of that law if it acquires land con-



taining burial grounds for its treatment facilities.  M.G.L.-



c.114, §17 is considered to be a codification of the Prior Public



Use doctrine as it applies to cemeteries (land devoted to ceme-



tery use),  and requires approval of the Legislature.  By analogy,



therefore,  the Authority would require legislative and guberna-



torial approval prior to appropriating publicly-owned burial



grounds for Authority purposes.  Further, M.G.L.  c.114,  §17 is



one of the laws of the Commonwealth referred to in Section



4(c)(ii) of the Act as applicable to lands devoted to a public



use.



     The previous memoranda assumed the existence of a Civil War



cemetery on Long Island, which would be affected by a new treat-



ment facility.  As public land committed to a prior public (cem-



etery) use, it appears that legislative and gubernatorial approval



would be necessary to appropriate the cemetery.  On Deer Island,



however, the applicability of the Prior Public Use Doctrine is



less clear with respect to cemeteries.  It has been reported that



there are hundreds of smallpox victims in unmarked graves located



in the vicinity of the prison.  Early maps of the island also
                                                             Legal - 13

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     indicated the presence of a cemetery near Fort Dawes.  However,




     because the federal government has indicated that the cemetery




     near the fort was relocated off-island, and because the location




     of smallpox victim graves has not been confirmed during the ar-




     chaeological research conducted during EIS preparation, it is




     unclear whether the Prior Public Use Doctrine provisions of the




     Act would apply to Deer Island because of cemetery use.




          As stated in the previous memorandum regarding Long Island,



     the Long Island Hospital is subject to the protections afforded




     by the Prior Public Use Doctrine, and the hospital grounds could




     not be diverted to sewage treatment use without the approval of



     the Legislature and Governor.  While the Deer Island House of



     Correction cannot be taken or acquired by the Authority to expand



     sewage treatment facilities without legislative and gubernatorial



     approval, it is not yet clear whether the Doctrine applies to



     land beyond the prison perimeter.  The Authority staff has sug-



     gested that some parcels lying outside the prison fence were



     acquired specifically for prison purposes.  However, some ques-



     tion remains with respect to whether the outside parcels are now



     "dedicated or devoted" to prison use.  If further research con-



     firms that these parcels are presently dedicated to prison use,



     the Doctrine may apply, as such, unless a wastewater treatment



     facility were considered "consistent" with that use, legislative



     and gubernatorial approval would have to be obtained by the



     Authority to acquire and use these parcels for treatment facility



     development.
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     D.   Article 97 of the Massachusetts Constitution

     Article 97 of the Massachusetts Constitution (amending Arti-

cle 49 of the Constitution) provides that public land taken or

acquired for conservation, scenic, historic or recreation pur-

poses, may not be used for other purposes or otherwise disposed

of without a two-thirds vote of the Legislature.  Op. Att'y.  Gen.

April 12, 1976, 157.  Article 97 is applicable only to those pub-

lic uses specifically enumerated in the Article, and is therefore

narrower in scope than the Doctrine of Prior Public Use.

     Article 97 is first mentioned in the new Act in Section

4(c)(i), which states that "no lands or easements taken or

acquired for the purpose authorized by Article 97 of the Amend-

ment to the Constitution of the Commonwealth shall be used for

other purposes or disposed of ... except in accordance with the

laws and the Constitution of the Commonwealth."  The Legislature

intended thereby to maintain the protections afforded Article 97

to certain public lands.

     To date no information has been discovered which would sug-

gest that any parcels on either Deer Island or Long Island were

taken or acquired for Article 97 purposes.  Accordingly,  no fur-

ther discussion of these provisions is warranted.

     E.   Applicability of Chapter 742 of the Acts of 1970

     Section 8 of Chapter 742 of the Acts of 1970 provides that

     This act shall not be construed to limit the power or
     authority of any department,  board or commission of the
     commonwealth or of any political subdivision thereof or
     of any public authority except where expressly provided
     otherwise herein;  provided, however, that in, under or
     bordering Boston Harbor there shall be no acquisition




                                                           Legal  - 15

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           of land by any such public agency or instrumentality
           other than [the Department of Environmental  Management
           ("DEM")]  without the approval of the [DEM],  and no pub-
           lic land' on or bordering said area may be sold,  leased
           or used as a dump or refuse disposal area,  and no sand,
           gravel or soil may be removed therefrom or deposited
           thereon,  and no structure may be built thereon,  without
           the approval of the [DEM].

      On its face,  this statute would appear to give broad power to the

      DEM to regulate the acquisition and use of the Harbor Islands,

      and require OEM's approval to acquire land and construct and  op-

      erate a new facility on either Deer Island or Long Island.  There

      was no question regarding the applicability of this statute to

      actions of the MDC,  which formerly would be responsible for waste-

      water treatment facilities.   However,  there is some ambiguity

      regarding the applicability of Chapter 742 to the Authority.

           Although the Act makes specific reference to a number of

      special acts as well as general laws to which the Authority is

      subject or exempt,  the Act does not provide separate treatment of

      Chapter 742.   Certain provisions of the Act,  however,  have some

      bearing on the potential applicability of Chapter 742.   Sec-

      tion 3(a)  of the Act states:

           .  .  .  [The Authority shall not be]  subject to the sup-
           ervision or control of the executive office  of environ-
           mental affairs or of any other executive office,  depart-
           ment,  commission,  board,  bureau,  agency or political
           subdivision of the commonwealth except to the extent
           and in the manner provided in this act.

      Because the DEM is a department within the Executive Office of

      Environmental Affairs,  and because the Act does not specifically

      reference  Chapter 742 as applicable,  one might argue that the

      actions of the Authority may be beyond the control of DEM.
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     Further support for this interpretation may be found at Sec-

tion 25 of the Act, which provides:

     The provisions of this act shall be deemed to provide
     an additional, alternative and complete method for ac-
     complishing the purposes of this act, and shall be
     deemed and be construed to be supplemental and addi-
     tional to, and not in derrogation of, powers conferred
     upon the Authority and others by law; provided, how-
     ever, that insofar as the provisions of this act are
     inconsistent with the provisions of any general or
     special law, administrative order,  or regulation,  the
     provisions of this act shall be controlling.

By these terms, the Legislature may have intended that all other

state law which may impede the purposes of the Authority are sus-

pended with respect to the Authority.

     However,  it is possible to interpret the various provisions

of the Act to require the application of Chapter 742 to the Auth-

ority.  Because Chapter 742 grants to DEM authority over transac-

tions involving land in Boston Harbor,  the City of Boston, as

grantor of Long Island or Deer Island,  could be barred from

transferring lands without DEM approval.

     Further pursuasive support for applicability may be found in

Section 4(c) of the Act,  which requires that transactions involv-

ing the transfer of certain protected public lands be conducted

in accordance with the laws and the constitution of the Common-

wealth, which would include the provisions of Chapter 742.  Read

in this light,  Section 25 would not preclude the application of

Chapter 742, since the purposes of the Act include compliance

with the laws of the Commonwealth in public land transfers.

     F.   Power to Acquire Property by Eminent Domain

     To acquire the property on either Deer Island or Long Island

necessary to construct a new treatment facility, it will be nee-
                                                             Legal - 17

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      essary  to purchase or take by eminent domain  land now owned by




      the City of  Boston.  Section 9(a) of the Act  provides the Author-




      ity with the general power to take property by eminent domain in




      accordance with  the provisions of M.G.L. c. 79 and 80A,  subject




      to several limitations.   In general, the taking of property by




      eminent domain requires the prior approval of the Legislature and




      the Governor, without regard to whether the property taken is




      held privately or by a public body.  However, under Section 9(a),




      an exemption from the requirement of prior approval exists for



      takings related  to certain sewers, pumping stations and  combined



      sewer overflow works.  Further, this section  of the Act  prohibits




      the taking of property, including water rights, that are part of



      the MDC watershed system.  Section 9(a) reiterates the require-



      ment that both the Governor and the Legislature must approve tak-



      ings of property by the Prior Public Use doctrine.



          Any taking  by eminent domain under the Act requires prior



      certification by the Authority .that it reasonably believes all



      regulatory approvals required for the proposed project and listed



      in Section 8(i)  will be obtained in the ordinary course.  How-



      ever, there  are  no provisions in the Act which would prevent the



      Authority from taking any portions of city-owned land on either



      island  by eminent domain.



          G.   Power  to Acquire Land by Other Than Eminent Domain



          Under Section 9(d) of the Act, after July 1, 1985,  the Auth-



      ority may acquire real and personal property  or interests or



      rights  therein,  "if deemed essential for operation, improvement
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or enlargement of its sewer and water works systems."  This sec-

tion would allow the Authority to purchase or otherwise acquire

property necessary for the proposed wastewater treatment facili-

ties by means other than eminent domain.  Section 26(b) provides

that except with respect to real property acquired or held for

purposes protected by Article 97, state and local agencies and

other governmental entities are "authorized and empowered to

lease,  lend,  give or convey to the Authority" any interest in

real or personal property which may be necessary or convenient to

effect the purposes of the Authority.   That section further pro-

vides that any such conveyance would be "upon such terms and con-

ditions as the conveying entity may deem appropriate and without

the necessity of any action or formality other than the regular

and formal action of said public bodies .  .  . ."

     Under the provisions Sections 9(d) and 26(b),  the Authority

may purchase private property or property interests without the

necessity of prior legislative or gubernatorial approval.

     H.   Power to Remove or Relocate Property

     Under Section 9(b)  of the Act,  the Authority has the power

to order the removal or relocation of certain property:

     The Authority may order the removal of any conduits,
     pipes,  wires, poles or other property located in public
     ways or places or in or upon private land . .  .  subject
     to the ability of the proper authorities lawfully to
     grant or otherwise make provisions for new locations
     for any such structure so removed or relocated.   Such
     orders,  to the extent specified therein, shall be
     deemed a revocation of the right or license to maintain
     such conduits,  pipes, wires, poles or other property in
     such public ways or places, and the private owner of
     any such structures in public ways or places shall com-
     ply with such orders.
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           It would appear  that  the  intent  of  this  provision is  to  en-




      able  the authority to remove and relocate  all utility easements




      from  its project areas,  including both public utility and  private




      easements.   Read broadly,  this vaguely worded section of the  Act




      could be construed to allow the Authority  to  order removal or




      relocation  of structures,  including buildings ("property") loca-




      ted in a public  place,  subject to the ability of the  proper auth-




      orities to  provide for a new location of such property or  struc-




      ture.   However,  because Section 9(b)  apparently limits the Auth-



      ority to issue relocation  orders to "private  owners," the  Author-



      ity may not use  this  provision to effectuate  removal  of public



      facilities  such  as the Long Island Hospital.



           I.   Relocation  of Long Island Hospital




           At present,  the  hospital  on Long Island  provides chronic and



      long-term care to approximately 150 patients  and provides  shelter



      for the homeless of the City of Boston.  Depending upon the spe-



      cific means used to appropriate hospital property and terminate



      hospital use,  removal or relocation of the hospital may be sub-



      ject  to the provisions of  M.G.L.  c. Ill, §§25B-G,  the'Common-



      wealth's "Determination of Need" law.  The law requires that



      notice of a proposed  change or termination of services be  given



      to the Department of  Public Health ("DPH") which must determine,



      in advance,  that a need for such a change  in  services exists



      (M.G.L.  c.  Ill,  §25G;  105  CMR  100.001 et.  seq.)



           Pursuant to M.G.L.  c.  Ill,  §25(c),  no person or  government



      agency may  make  a substantial  capital expenditure for construc-



      tion  of a health care facility or a substantial  change in  the
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services of any such facility unless the DPH has determined that




there is need for such change.  A substantial capital expenditure




is defined in the Determination of Need ("DON") regulations to



mean an expenditure of $600,000 or more which "under generally



accepted accounting principles is not properly chargeable as a




cost of operation ..."  The term "construction" is defined in



the regulations to mean the construction of a new health care




facility or the alteration of, expansion of,  making of major re-



pairs to,  remodelling of,  renovation of, or replacement of an



existing health care facility.  The term "substantial change in



services"  means,  among other things,  "any decrease in the level



of service of a long-term care facility which involves a substan-



tial capital expenditure;  or any termination of a service when a



capital expenditure is associated with such termination .  .  .;  or



any decrease by more than four beds of the bed capacity of a fa-



cility or of a service or unit thereof when a capital expenditure



is associated with such decrease .  .  ."



     The question of whether and how the Determination of Need



law applies to the Long Island Hospital closing depends on how



that closing is structured.  If Health and Hospitals undertakes



to raze the facility,  arguably the project is subject to DON re-



view as "construction" of a health care facility (i.e., "altera-



tion" of such a facility at a cost of at least $600,000) or a



substantial change of services (i.e., the termination or reduc-



tion of a service or beds which entails a capital expenditure).



Moreover,  the mere change of ownership of a health care facility
                                                           Legal - 21

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     is subject to DON review, although a change in ownership can be




     processed as a delegated or expedited review if the change does




     not involve a substantial change in services and if none of the




     statutory parties to the determination of need process objects to




     the application.  (105 CMR 100.505(A)(f).)  If DON review is re-




     quired (particularly if it is not delegated review), the project




     can be the subject of a delay of eight months and perhaps much




     longer.




          It is possible that, with proper structuring, a DON review



     may be avoided.  If Health and Hospitals were to notify the DPH



     that Long Island Hospital plans to terminate its patient care



     services, and if the patients could be transferred out of the



     facility without a capital expenditure being incurred by the hos-




     pital, DON review would arguably be avoided, at least with respect



     to Long Island Hospital.  Absent a capital expenditure in regard



     to the diminution of services offered by the Hospital, the diminu-



     tion of services is not a "substantial change in service" subject



     to review.  Moreover, once the hospital is no longer a health



     care facility, its alteration or destruction can no longer be



     termed "construction" of a health care facility.  The subsequent



     acquisition of the building and the land upon which it sits by



     the Authority would no longer constitute a change in ownership of



     a "health care facility".




          Avoidance of DON review for the transaction between Health



     and Hospitals and the Authority will, as noted above,  depend,  at




     least in part, on a finding that the transfer of the hospital's
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patients will not result in any capital costs.  Since the hospi-

tal must inform DPH of the proposed closure for licensure reasons,

the Department is likely to carefully scrutinize all closure and

transfer of patient costs to ascertain the applicability of the

DON provisions to the transfer.  One additional caveat should be

noted:  any hospital that takes patients transferred out of the

Long Island Hospital should assess its own exposure.  If such

hospitals already have chronic care services,  and if they can

accommodate the transferred patients without an increase in pa-

tient bed capacity,  it would seem that there will be no DON im-

plications for those hospitals unless the transfer itself in-

volves a capital cost.

     J.   Massachusetts Department of Capital  Planning and
          Operations Jurisdiction

     The Deputy Commissioner of the Massachusetts State Division

of Capital Planning and Operations (DCPO) has  the discretionary

power to approve or disapprove of acquisition  of real property by

state agencies.  The Act, however, .provides a  partial exemption

of the Authority from the jurisdiction of DCPO. ' Section 8(b) of

the Act requires the Authority to file copies  of any capital fa-

cilities programs with the DCPO pursuant to M.G.L. c. 7, §39c

and, under Section 9(c) of the Act, the Authority must notify the

DCPO of any sale, lease or disposition of interest which it has

acquired in real property.  The Act appears to exclude the DCPO

from the process of approving the acquisition  of land by the

Authority, a control which the DCPO exerted with respect to the

MDC.




                                                             Legal  - 23

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           K.    Other  Statutory  and Regulatory  Impediments to
                Facility Construction and Operation

           The  original memoranda discussed certain  statutory  and  reg-

     ulatory programs requiring state  and federal permits and approvals

     to  construct  and operate a new facility.  These  laws included the

     Massachusetts Historic Preservation Act,  Chapter 9, Sections 26

     through 27D;  the National  Historic Preservation  Act; the federal

     Coastal Zone  Management Act and state coastal  zone management

     program;  and  federal Executive Orders 11988 and  11990, concerning

     flood plain management and the protection of wetlands.   All  of

     these programs will apply  with equal effect to the Authority,

     since the Act does not provide exemptions to these state stat-

     utes, nor could  it provide exemption from federal law.   The

     Authority staff  has recently provided a more site-specific analy-

     sis of those  permits and licenses required to  construct  and  oper-

     ate a facility on either island.  These permits  and licenses are

     required  by programs from  which the Authority  is not exempt.

     These approvals  include:

           o     state  air pollution permits under 310  CMR 7.00 et
                seq.

           o     federal air pollution permits under  40 CFR parts 52
                and 329

           o     state  and federal NPDES permits

           o     federal dredge and fill permit  (Section 404 permit)

           o     ocean  dumping permit

           o     state  and federal channel dredging and navigable
                waterways permits
Legal -  24

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     o    approval of activities within the coastal zone




     o    reconstruction of bridges and causeways




Without a detailed facilities plan, it is not possible at this




time to identify very localized environmental conditions which



may present obstacles to the issuance of these permits,  or sug-



gest the applicability of other state or federal permitting re-



quirements.



     One regulatory program which was not identified or discussed



in the earlier memoranda is the federal Coastal Barrier Resources



Act ("CBRA"),  16 U.S.C.  3501 et seq.   Under this federal law,  no



new expenditures or federal assistance may be made available for



any purpose within the Coastal Barrier Resources System as de-



fined by the U.S. Department of Interior.   Currently,  there is



one barrier beach on Long Island included in the Coastal Barrier



Resources System, designated as C01C on the Interior Department's



inventory,  which is located at the southwesterly end of the island



on land near West Head adjacent to the causeway from Moon Island.



The Interior Department published a notice in the Federal Register



on March 4,  1985 discussing proposed amendments to the CBRA and



also proposing new additions to the inventory of designated bar-



rier beaches.   One of these proposed barrier beach areas, desig-



nated as MA-08,  is located to the west of the causeway between



Winthrop and Point Shirley just north of Deer Island.   Another,



designated as MA-11, is located to the east of West Head at the



southeasterly end of Long Island and extends to the east to in-



clude Peddocks and Rainsford Islands.  Any new additions to the
                                                             Legal - 25

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     barrier beach  system  as  recommended by  the  Interior Department




     will  require an Act of Congress.   Precisely when  any  such  legis-




     lation could be enacted  is unclear, because at present  the pro-




     posals are  still  in the  public  comment  period, and have not  yet




     been  finalized for transmittal  to  Congress.   In any event, neither




     the proposed barrier  beach area on Deer Island nor the  existing




     or proposed areas on  Long Island appears  to pose  an impediment to




     construction of a new or expanded  wastewater  treatment  facility




     on these  islands.  The CBRA may, however, influence the selection




     or location of the inter-island conveyance  system.



     IV.   CONCLUSION



           The  foregoing discussion has  identified  several  provisions



     of the Act, the Massachusetts Constitution  and other  general  laws



     which must  be  satisfied  by the  Authority  to acquire land on  either



     Long  Island or Deer Island for  a new  wastewater treatment  facil-



     ity.  While the Authority may be exempt from  some provisions  of




     state law,  it  must still obtain legislative and gubernatorial



     approval  for the  taking  of public  lands protected by  the Prior



     Public Use  doctrine and  land protected  by M.G.L.  c. 114, §17.  It



     is clear  that  a special  act of  the Legislature will be  needed to



     implement a plan  to construct a secondary treatment facility  on



     Long  Island on the Long  Island  Hospital site.  The need for  a



     special act is less apparent with  respect to  Deer Island because



     of uncertainties  associated with the  application  of the Prior



     Public Use  Doctrine to land outside the prison grounds, and with



     the location of unmarked graves on the  island.  A final determi-



     nation regarding  the  land ownership and use,  and  presence of  an
Legal - 26

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unmarked cemetery on the Island will establish whether  legisla-



tive and gubernatorial approval is required.
                                                            Legal - 27

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  II-6
air toxics

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II-6.   Air Toxics/Volatile  Organic  Compounds
A.  Background

    The comments on the SDEIS  on Air Toxics and Volatile Organic Compounds
    which required additional  evaluations by EPA centered on the following
    areas:

    1.  Will the proposed  500  MGD  secondary wastewater treatment plant be a
        major source of air  toxics?

    2.  If it is a major source will it impact the decision to site the
        wastewater treatment facility?

    3.  Will the proposed  secondary treatment plant be a major source of
        volatile organic compounds (VOCs)?

    4.  What does the literature say about air toxics and VOCs from waste-
        water treatment facilities?

    5.  What type of control technologies exist that could reduce or elimi-
        nate air toxics and  VOCs from a treatment plant should it be a
        problem?

    In order to respond to these issues the EPA Region I Air Management
    Division and EPA's consultant, Thibault/Bubly Associates (T/B), conducted
    an evaluation resulting  in the attached report.  EPA's consultant has
    prepared a separate report on  Documentation of Methods Used in Estimating
    Ground Level Concentrations of Volatile Organic Compounds (VOC).  This
    report is part of the  FEIS and is available from EPA under separate cover.
B.  Executive Summary and Conclusions

    Air Toxics

    The air toxics issue is  not  a  site determining issue, because it is
    predicted that the virtual safe dose will not be exceeded at any of the
    receptor populations (i.e.,  the prison, Point Shirley, Hull High School,
    etc.) if the secondary treatment plant is built on either Deer Island or
    Long Island.

    Ozone

    The secondary wastewater treatment plant will be a major source (over 100
    tons per year) of volatile organic compounds  (VOCs) and will have to be
    controlled to ensure reasonable further progress towards the attainment
    of the ozone standard.  (VOCs, in the presence of sunlight, are pre-
    cursors to the formation of  ozone.)  It is estimated, using the water
    concentrations found by  the  lab analysis of the May 1985 water samples,
                                                                       Air  Toxics - 1

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        and assuming 85% volatilization at those concentrations,  that  without
        additional controls, such as pretreatment of covering  of  the plant,  the
        emissions from the secondary wastewater treatment  plant could  be  as  much
        as 810 tons per year.  EPA is presently requiring  the  State of Massa-
        chusetts to control emissions from all sources which emit greater than
        100 tons per year of VOCs.

        Methodology

        Twenty-nine days of data were used to determine an average concentration
        for each volatile organic compound (VOC) found in  the  wastewater.  The 29
        data points are from the following sources:

        1.  Effluent data for the years, 1978, 79,  82, and 84  were taken  from the
            301 (h) waiver application and scaled back to  influent concentrations
            by dividing the effluent concentration by the  volatization rate  for
            each compound.

        2.  Influent data for the year 1978 were taken from the 301  (h) waiver.

        3.  Water samples were taken at the inlet to the sedimentation chamber by
            T/B on May 20 and 22, 1985.  EPA's lab analyzed the samples to
            identify compounds and their concentrations.

        4.  Water samples were taken at the inlet to the sedimentation chamber by
            EPA on June 11, 1985 and analyzed as described above.

        Thirteen compounds were found in the influent and  effluent and are
        represented in ug/m^ concentrations (see Table III).   These concentra-
        tions were converted to mass emission rates  (gin/sec) for  input into  the
        Industrial Source Complex (ISC) area source  model, and EPA approved
        model.  Each compound's emission rate was derived  by multiplying  the
        percentage of the compound that could be expected  to volatilize off  a
        secondary wastewater treatment plant (taken  from the literature)  times
        the concentration found in the influent or the effluent.

        Modeling for Predicted Concentrations

        The ISC area source model was then used to predict annual concentrations
        at receptor points where there are residential populations, from  400 to
        6000 meters away from the Deer Island and Long Island  siting locations.
        The model predicted ground level air concentrations of VOCs, in ug/m3,
        that were based on the estimated concentrations of the compounds  that
        would volatilize off a secondary wastewater  treatment  plant and four
        years of meteorological data from the Logan  International Airport.

        Analysis

        The predicted ambient air concentrations were compared to chemical
        specific "virtual safe doses' determined by  an independent toxicologist.
        A virtual safe does (VSD) is defined as "the level of  an  agent which
Air Toxics - 2

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   would be considered too small  to  be  of  concern and that would produce  a
   risk relatively insignificant  when compared  to normal background occur-
   rence of the toxic response (i.e., carcinogenicity) in the exposed
   population."1»2

   The virtual  safe doses for  carcinogens  used  in this analysis were
   compared to  predicted annually averaged concentrations which account for
   chronic exposure (70 years)  to emissions  from the facility.  The level of
   risk used to determine VSDs for the  carcinogens in this analysis was one
   additional cancer incident  in  100,000.  In other words, if a population
   of 100,000 is exposed to an ambient  air concentration of a carcinogen
   equivalent to its VSD for 70 years,  we  would expect to see one or less
   than one additional cancer  incident  within the population due to that
   exposure. When analyzing the  exposure  of the inmates at the Deer Island
   House of Correction to the  carcinogens, we considered a partial lifetime
   exposure since each inmate  is  exposed for less than 70 years.

   The level of risk used in this analysis is conservative and it is used
   for comparative purposes only. EPA  has not published an acceptable
   ambient air  concentration nor  an  acceptable cancer incidence risk for any
   of the thirteen compounds in this analysis.

   For the noncarcinogenic compounds, the  VSDs were based upon Threshold
   Limit Values (TLVs) established by American Conference of Governmental
   Industrial Hygienists (ACGIH). Since TLVs are based upon different
   endpoints of concern (i.e,  short  term and/or long term health impacts),
   we compared  the VSDs to modeled concentrations predicted for both annual
   and 24-hour  time periods.  (See Table III and Table IV.)

   Conclusion

   We compared  all of the predicted  concentrations to the appropriate
   virtual safe dose.   The virtual safe doses are not exceeded at any of the
   receptors for any pollutant.   Therefore,  air toxics do not rule out any
   of the sites currently under consideration in the EIS study.
^Stong,  D.   "Risk Assessment  for  Several Common Pollutants:  Acceptable
 Ambient Concentrations,"  provided  for T/B.

^Numerical  values used as  virtual safe doses are based upon information
 found in the following documents:

 a.  Health Assessment Document for Chlorinated Benzenes, EPA 600/8-84/015f,
     January, 1985.

 b.  TLVs — Threshold Limit  Values for Chemical Substances in the Work
     Environment, adopted  by  ACGIH  for 1984-1985.
                                                                      Air  Toxics  -  3

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      C.  Suggestions for Future Assessment

          This study is based on an estimate of 810 tons/yr.  of VOC  emissions.
          This estimate is based on samples taken and the use of existing effluent
          and influent data and represents the best estimate  available.   It  should
          be noted that this estimate is much less than the 3,428 tons/yr. approxi-
          mated using all the concentrations and other assumptions of the Indiana-
          polis plant (scaled up to 500 MGD), that was studied by U.S. EPA Region
          V.  (August 17, 1984 memo from Tim Henry and Pauline LeBlanc,  EPA  Region
          V, "Volatile Organic Carbon Emissions from an Indianapolis Wastewater
          Treatment Plant.")  It is hypothesized that in the  Boston  case a signi-
          ficant amount of VOCs are being emitted in the collection  system and at
          the headworks.  Therefore, a monitoring and sampling program should be
          designed to determine the validity of this hypothesis and  to identify and
          confirm or deny the existence of the potential sources.

          The findings in this report are based on a limited  number  of data
          points.  We are, therefore, recommending that the following three  tasks
          be initiated as soon as possible.

          First, samples should be taken at the influent to the existing Deer
          Island wastewater treatment plant to verify the emission rate  used for
          this assessment and to identify the type of control equipment  needed.
          The sampling study should be designed to identify peak influent and
          annual variations in influent concentrations.

          Second, influent and effluent water sampling data should be collected at
          the existing headworks to determine the compounds and their concentra-
          tions and to evaluate the headworks as sources of VOC.

          Third, air monitoring should be conducted at the headworks to  determine
          the actual emissions of each VOC.

          The Air Management and Environmental Services Divisions will provide
          guidance to properly design a sampling and monitoring program.   We
          recommend that this sampling begin as soon as possible so  that proper
          controls, if needed, can be designed for the plant.

      D.  Raw Data
          The raw data for this study came from two sources:

          1.  The 301 (h) waiver application,  and

          2.  Actual sampling at the inlet to  the sedimentation  tanks.

          Thibault/Bubly Associates reviewed the 301 (h)  waiver  application  and
          found four years of data which included 25 days of  effluent  sampling.   In
          1978 there were four dates of sampling data in  July; 1979, four days in
          June and July; 1982, ten days in April; 1984,  seven days  in  January.
          Additionally, Dorothy Allen of EPA found five days  of  influent sampling
Air Toxics - 4

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    data from 1978 that were averaged  into  the  1978 effluent data.  A total
    of 29 days of existing data were used.

    Wastewater samples were taken from the  inlet  to the primary sedimentation
    tanks, the first place in the wastewater  collections system, after the
    headworks, where the wastewater  stream  is exposed to the air and where
    there is turbulence and thus aeration.  Eight samples were taken on May
    20 and 22 and one additional sample was taken on June 11, 1985  (during
    the photovac air sampling).  The volatilization rate of each compound was
    taken from a literature search to  determine the amount of the compound
    that would be emitted from a new secondary  aeration tank.

    A more detailed description of the methodology is being provided by T/B
    as part of their contract report.

E.  Air Monitoring

    Air monitoring was conducted by  Frank Lilley  of EPA's Environmental
    Services Division (BSD)  on June  11,  1985  at the Deer Island wastewater
    treatment plant.  Frank calibrated a Photovac gas chromatograph for six
    compounds found in the water samples taken  in May:  1,2 dichloroethane,
    benzene, trichloroethylene, toluene, tetrachloroethylene, M-xylene.  He
    sampled over the inlet to the sedimentation chamber to determine the
    concentrations at a maximum concentration area and 50 yards downwind of
    the treatment plant to detect any  dilution  of the compounds.  The
    photovac was calibrated for a 1-2  ppb detection limit in order  to detect
    source and ambient concentrations.   The meteorological conditions were
    good for measuring these compounds,  hot ambient temperature and a slight
    wind.

    A peak concentration of hydrocarbons was  found over the inlet,  (probably
    caused by a high concentration of  acetone).   The presence of unidenti-
    fiable organic compounds prevented the  identification of any of the six
    compounds previously identified  in waste  samples.  The concentrations for
    the six compounds were,  therefore,  estimated  according to the percentage
    of each that would be expected to  be found  in the wastewater and 50 yards
    downwind of inlet to sedimentation chamber.
                                                                    Air  Toxics  -  5

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                                       Table I
                            Air Monitored Concentrations
                                                                  Air Monitored
                                       Air Monitored             Concentrations
                                      Concentrations            50 Yards Downwind
          Compound                       (in ppb)                	(in ppb)	

     1,2 Dichloroethane                       <1*                       <1*
     Benzene                                 <32                        <6.5
     Trichloroethylene                       <13                        <9.6
     Toluene                                 <79                       <35
     Tetrachloroethylene                     <41                        <7.5*
     M-Xylene                                <15*                      <15*

     *Lower detection limit.
        Note/ these values cannot be compared to the water concentrations used in
        the Industrial Source Complex (ISC) model because the air concentrations
        in Table I above are reported in ppb, a volume/volume ration and the
        water concentrations used in the ISC model are in ug/L»  a weight/weight
        ratio.
     F.  Virtual Safe Doses

        For the five carcinogens studied (benzene, carbon tetrachloride,  chloro-
        form, tetrachloroethylene and trichloroethylene), Dr.  David Stong,  an
        independent toxicologist hired by T/B, used the linearized multi-stage
        model developed by Crump and Watson to describe a linear non-threshold
        dose-response relationship.  This non-threshold model  has been adopted by
        EPA's Carcinogenic Assessment Group (CAG) and is recommended in most
        cases for risk extrapolation of the dose-response relationship to low
        doses.  The risk estimates made with such a model represent the most
        plausible, in this case, the 95% confidence limit, upper bound limit for
        the risk.  That is, the true risk is 95% likely to be  lower than  the
        estimated risk, and therefore, may be regarded as a conservative  estimate.

        Chemical carcinogenic dose-response relationships are  based primarily on
        animal oral toxicity studies although a few have been  calculated  using
        data from animal inhalation studies, human occupational exposure, or
        human drinking water exposure.  The most accurate data set which  esti-
        mates the highest lifetime cancer incidence is used to establish  the
        dose-response relationship.  This usually correlates with the most
        sensitive test species.  For the six carcinogens as categorized by EPA
        (see Table III and Appendix A for EPA's classification),  all but  one
        contaminant's risk estimate, that for benzene, was calculated using data
        from animal oral studies.  For benzene, the risk was estimated using
        human occupational exposure data.
Air Toxics - 6

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    Dr. Stong used an individual lifetime  cancer  risk estimate of  1  x  10"^
    to determine virtual safe doses (VSDs)  for  the  five  carcinogens.   That
    is, one person within a population of  100,000 breathing an ambient
    concentration of a contaminant equivalent to  its VSD for  70 years  would
    develop cancer as the result of that exposure.  This value represents the
    excess, above the normal background, cancer rate and generally represents
    the number of cancer cases,  not deaths,  related to exposure to a specific
    pollutant.  The use of a cancer incidence of  1  x 10~5 is  consistent
    with past Center for Disease Control  (DCD)  and  EPA's Carcinogen  Assess-
    ment Group (CAG) risk assessment as to what may be considered  as an
    acceptable maximum individual lifetime risk due to exposure to environ-
    mental contaminants.
    The following calculation was used  to estimate  the VSDs.
    guidelines used by CAG.
                                           It follow
    qi* x d      Where:  P      =   Risk
                         qj*    =   Carcinogenic  potency  (slope  from the
                                   dose-response curve)
                         d      =   Dose,  assuming the volumetric breathing
                                   rate of  10m3/day for  a 70kg  person,
                                   breathing  x ub/lm3 of a chemical

    (Note:  This estimation is based  on the assumption that dose per  surface
    area is equivalent between humans and rats.)

    For example, Benzene:
Where:  P
1 x 10~5
5.2 x 10'2 (mg/kg/day)-1
(20m3 day) x (1/70  kg)  x  (Y ug/m3) x
                            [Virtual
                            Safe Dose
                                                             [Conversion
                                                              Factor]
Solving for Y:
                                      1x10
                                          -5
      (5.2xlO~2  (mg/kg/day)"1)  x  (20m3/day)  x  (l/70kg)  x  (10~3mg/ug)

Y = 0.67 ug/m3

    For noncarcinogens, or threshold toxicants,  Dr.  Stong  has  calculated a
    VSD equivalent to the American Conference of  Governmental  Industrial
    Hygienists (ACGIH) Threshold Limit  Value-Time Weighted Average  (TLV-TWA)
    for an eight-hour averaging  time period,  divided by  a  safety factor of
    100.  The safety factor of 100 considers  (1)  a safety  factor of  10 for
    extrapolation from a subchronic exposure  to  a  chronic exposure  and  (2) a
    safety factor of 10 for extrapolation from a healthy worker population to
    a sensitive population.
                                                                      Air Toxics - 7

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          Table II (page  9  )  shows a  comparison  between the virtual safe doses
          established by Dr.  Stong and ambient  air  levels set by two state air
          toxics programs.  The virtual safe doses, according to Dr. Stong, protect
          the general public from chronic  (i.e.,  long  term) effects associated with
          the contaminants and, thus,  should be compared to predicted annual
          average concentrations.  Please  note  any  differences  in averaging times
          associated with the Michigan and New  York values.

          The State of Michigan conducts a risk assessment for  known or suspected
          carcinogenic compounds.  They follow  the  same basic risk assessment
          concepts as EPA's Carcinogen Assessment Group  (CAG),  setting an accept-
          able cancer incidence of 1 x 10~*> (one in a million).  Michigan's
          ambient air concentrations associated with a cancer risk of 1 x 10"^
          would be used as an annual average.   Using an acceptable cancer incidence
          of 1 x 10~° is more conservative than the 1  x 10   cancer incidence
          Dr. Stong used when setting  VSDs. However,  EPA has not published
          acceptable risk levels for carcinogens, and  1 x
          1Q-5 is frequently used as an acceptable  risk to environmental contaminants.
          Of the six carcinogens classified  by  EPA,  Michigan currently considers
          four of them as carcinogens.   These compounds are appropriately marked in
          Table II.  For noncarcinogens,  Michigan  uses 1% of the TLV  (TLV/100) as
          an eight hour average.  This  is the same approach used by Dr. Stong to
          establish VSDs, however he recommends an annual averaging time.

          The New York Air Guide I sets annual  ambient air guidelines equal to the
          TLV/300 for high or moderate  toxicity air  contaminants and TLV/50 for low
          toxicity air contaminants. The following  definitions are used when
          classifying contaminants:

              High Toxicity:      Human carcinogens  and other substances posing a
                                  significant risk to humans.

              Moderate Toxicity:  Animal  carcinogens, mutagens, teratogens, and
                                  other substances posing a significant risk to
                                  humans.

              Low Toxicity        Those substances whose primary concern is an
                                  irritant.  No confirmed carcinogenicity in
                                  animals.

          Contaminant specific acceptable ambient  levels (AALs) have been set for
          selected contaminants by the  New York Department of Environmental
          Conservation (DEC) or the New York Department of Health.  For the
          thirteen chemicals which Dr.  Stong reviewed, the New York DEC's interim
          AALs were all derived from Threshold  Limit Value-Time Weighted Averages
          (TLV-TWAs) set by the ACGIH.   Dr.  Stong's  use of CAG's carcinogenic risk
          estimates to derive VSDs for  the carcinogens provides a much more
          conservative acceptable ambient air level  when compared to the New York
          approach.
Air Toxics - 8

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                                  Table II
       Comparison of Virtual Safe Doses to State Air Toxics Guidelines
                                   (ug/m3)
     Chemical
(Classification)3
  Virtual
 Safe  Dose
(Annual  Avg.)
  Michigan
 (8-hr,  or
(Annual  Avg.)
New York DEC
Air Guide I
(Annual Avg.)
Carcinogens

Benzene (Group A)                0.67b

Carbon Tetrachloride (Group B2)   0.270b

Chloroform (Group B2)            0.50b
Dichloromethane (Methylene
Chloride) (Group B2)
         56
Tetrachloroethylene (Group C)     1.0°

Trichloroethylene (Group B2)      1.80b
        0.14ce

        0.04ce

        0.02ce


         	c


      3.35  x 103d

      2.7 x 103d
                                            100f

                                            100f
  1.17 x 103<3

  1.12 x 103<3

      900
Noncarcinogens

Acetone

1,2-trans-Dichloroethylene

Ethyl Benzene

Monochlorobenzene

Toluene

1,1,1 Trichloroethane
(Methyl Chloroform)

Xylenes (m, p, o)
         1.8 x  104d

         7.9 x  103

         4.35 x  103

         3.5 x  103

         3.7 x  103


         1.9 x  104

         4.4 x  103
      1.8  x  104d




      4.35 x 103d




      3.8  x  103d


      1.9  x  104d

      4.35 x 103d
  3.56 x 10
           4h
  1.45 x 103<3

  1.17 x 1039

  7.5 x 103h
  3.8 x 10
          4h
  1.45 x 103<3
  (assigned to
  each isomer)
aSee classification of carcinogenic evidence in Appendix A.
bldentified as a carcinogen by Dr.  David Stong, cancer risk  = 1 x 10~5.
Identified as a carcinogen by Michigan, cancer risk = 1 x 10~6.
dEight hour average.
eAnnual average.
^High toxicity classification — NY DEC.
^Moderate toxicity classification — NY DEC.
nLow toxicity classification — NY DEC.
                                                                     Air Toxics - 9

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      G.  Limitations

          Wastewater Sampling

          Very little influent data existed in the  MDC  computer  system and time and
          resources did not permit extensive wastewater sampling.   Therefore, T/B
          felt it was necessary to use the 301 (h)  waiver  application for effluent
          data in order to get the broadest view possible  of  the types of volatile
          organic compounds and their concentrations  in the wastewater.  In order
          to estimate the wastewater concentrations of  the influent from the
          effluent data, T/B used data available in the literature  to estimate the
          percent removal of each compound in a primary wastewater  treatment plant
          and back calculated for the influent concentration.  We believe this gave
          the best estimate possible for the influent concentrations for the ten
          compounds* studied except for chloroform2.

          However, since the concentrations of toxic  pollutants  in  the MDC waste-
          water fluctuate depending on the time of  day,  wet or dry  conditions,
          industrial dumps into the system, etc., we  recommend that an influent
          sampling system be set up to monitor the  toxic constituents so that
          appropriate controls can be designed if necessary.   (See  Suggestions for
          Future Assessments, page 4 .)

          Volatilization Rates

          For this analysis, volatilization was considered the only removal
          mechanism for VOC from the wastewater. All of the  volatilization rates
          for a secondary wastewater treatment plant  used  in  this analysis were
          estimated from the literature.  Removal by  biodegradation and adsorption
          to the solids were not considered because they have not been documented
          at the MDC system.  IF a percentage of VOCs in the  MDC system are removed
          from the wastewater by these mechanisms,  it would mean the volatilization
          rates were used are inflated and thus are conservative.   We used these
          conservative volatilization rates in order  to maximize the potential
          risks from the thirteen pollutants studied.

          Virtual Safe Dose

          Under Section 112 of the Clean Air Act, EPA has  the authority to estab-
          lish national emission standards for hazardous air  pollutants (NESHAPS).
          The term "hazardous air pollutant" refers to  a contaminant "which may
          reasonably be anticipated to result in an increase  in  mortality or an
          increase in serious irreversible, or incapacitating, reversible ill-
            compounds for which influent concentrations  were  calculated  from  the
        301 (h) waiver application are:   carbon  tetrachloride,  benzene,  chloroform,
        1,1,1 trichloroethane, 1,2 trans dichloroethylene,  ethyl  benzene,  tetra-
        chloroethylene, toluene,  trichloroethylene  and methylene  chloride.

       2Explained in the Projected Annual Average Ground Level  Concentrations
        Section.
Air Toxics - 10

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   ness."3  Under this authority, chemical emission standards are set for
   specific source categories  to control the emissions from both new and
   existing facilities.   The process of establishing a NESHAP is extremely
   lengthy and includes  a detailed review of all know toxicological and
   exposure data.  To date, six NESHAPS have been promulgated by EPA and
   none of these would apply to the proposed secondary wastewater treatment
   facility.  Additionally, EPA has not published an acceptable cancer
   incidence risk.  However, in the interest of protection of public health,
   VSDs, established by  an independent toxicologist, were used to assess the
   impacts of the thirteen compounds studied in this analysis.

   The data reviewed in  order  to establish the virtual safe doses (VSDs)
   included unit cancer  risk values established by the CAG as well as occu-
   pational threshold limit values (TLVs).  These values do not constitute a
   risk assessment as proposed by EPA4.  An EPA detailed risk assessment
   was beyond the scope  of this study and could not have been done in the
   time frame or within  the monies allocated.  The virtual safe dose method
   was considered a reasonable approach for this study.  However, there are
   limitations associated with this approach, and these are:

       The exposed individuals are usually represented by a "reference man"
       having a standard weight, breathing rate, height, etc.; so reference
       is made to health, age, race, sex, nutritional status, etc.

       The amount of information within specific toxicological databases
       varies from chemical to chemical.  Also, a large portion of available
       information may be based on animal or in vitro studies.  Extrapola-
       tion to human response  is difficult.  These are general limitations
       of toxicity reports.

       The VSDs for the  noncarcinogenic compounds are based upon varying
       toxicological studies and effects.  Therefore, when establishing the
       VSDs for these compounds, the division of all TLVs by the same safety
       factors is not scientifically justified.  Depending upon a specific
       chemical's effect, additional safety factors could be required.

       Cancer was assumed to be the end point of concern for the six chemi-
       cals identified as carcinogens.  These chemicals may also cause other
       adverse chronic health effects, as well as acute health effects.  For
       this analysis, however, it was assumed that an ambient air concentra-
       tion protecting the general public to a cancer incidence of 1 in
       100,000 would also protect against other toxicological effects.
3Section 112(a)(l)  of the  Clean Air Act as amended through July 1981.

4A detailed Carcinogen Risk  Assessment as proposed in guidelines published
 on November 23,  1984 by EPA includes the following components:  hazard
 identification,  dose-response assessment, exposure assessment and risk
 characterizations  (49 FR  46294).
                                                                   Air  Toxics  -  11

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              We estimated the prisoners exposures to the secondary sewage treat-
              ment plant assuming they would never be exposed to the same chemical
              concentrations again.  This may or may not be true depending upon
              where their post incarceration employment and living situations take
              them.

              The general population is exposed to chemical mixtures.   In general,
              a carcinogen when interacting with specific tissues may leave a
              •long-lasting imprint," however, the time from the initial tissue
              alteration to the production of a detectable tumor is usually
              measured in years and dependent on many factors (i.e., exposure
              regimen, nutritional status of exposed individual, etc.).   This
              latency period also makes it difficult to identify a cause-effect
              relationship between a specific chemical and cancer since  humans may
              be exposed to numerous chemicals during the interval between exposure
              and tumor production.  Data are not available to demonstrate or deny
              the existence of additive (a summation of the effects of two or more
              chemicals), synergistic, (a greater than additive effect of two or
              more chemicals) or antagonistic (a less than additive effect of two
              or more chemicals) health effects related to chemical mixtures.
              Likewise, only limited information is available on the promotion or
              cocarcinogenic potential of most chemicals.  A promoter is a chemical
              which enhances the effect of a carcinogen when exposure to the
              promoter occurs after exposure to a carcinogen.  A cocarcinogen is a
              chemical which enhances the effect of a carcinogen when exposure
              occurs at the same time.
       H.   Projected Annual Average Ground Level Concentrations

           Table  III identifies the 13 volatile organic compounds found in the
           wastewater and classifies them as known, probable,  or possible human
           carcinogens and noncarcinogens using EPA's Proposed Guidelines for
           Carcinogen Risk Assessment (see November 23, 1984 Federal  Register, 49 FR
           46294).  The virtual safe dose (VSD); the VSD multiplied by 35 for
           carcinogens; the modeled, annual average, ground level concentrations in
           ug/m^  for each of the 13 compounds at the closest receptors for Deer
           Island  (400 to 4000 meters) and Long Island (300 to 4000 meters)  are also
           listed.

           A comparison of the modeled concentrations at the Deer Island receptors,
           except  the prison receptor, show that all the modeled concentrations are
           below  the virtual safe doses.  For the prison population comparison, we
           took the virtual safe dose for each known, probable, or possible  human
           carcinogen, and multiplied by 35 since the average  incarceration  at Deer
           Island  is two years (nine months average stay with  40% repeat rate was
           estimated to be an average two year stay).  Therefore, the multiplication
           factor  of 35, (70 years divided by two)  was used to calculate the partial
           life time exposure.  In no case was the VSD, multiplied by 35,  exceeded
           at the  prison for any of the known, probable, or possible  human carci-
           nogens.  This strategy was recommended by Steven Bayard, a statistician
Air Toxics - 12

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with the CAG.  The partial  life  time  exposure calculation for the prison
population is not necessary for  the noncarcinogens.  The VSDs for the
noncarcinogens are based on TLVs that are set for acute or noncarcino-
genic chronic effects seen  during an  eight-hour averaging time exposure,
not a 70 year life span. Therefore,  Table III for noncarcinogens does
not include any VSDs multiplied  by 35.

A comparison of the modeled concentrations at the Long Island receptors,
show that the modeled concentrations  are below the VSD at each receptor.
Due to the limitations of the  data, the conservatism in the volatiliza-
tion rates used in the model and the  safety factors1 and conservatism
built into the virtual safe does,  we  considered values below or within
the same order of magnitude of the virtual safe does to be an acceptable
level of risk.

It should be kept in mind that the data presented in Table III represents
the amount of each compound that will be emitted from the new primary and
secondary aeration tanks at the  plant under consideration.
Thibault/Bubly Associates estimate that a portion of the measured
concentrations are currently being emitted from the existing primary
aeration tanks.  These existing  emissions were not subtracted from the
concentrations used for the ISC  model.  Therefore, the concentrations
presented are considered the potential maximum increase in emissions.

The chloroform concentrations  in the  effluent samples taken in 1978, 79,
82 and 84 were higher than  the concentrations measured in the influent
samples taken in 1985.  This may be expected because the effluent samples
were taken after chlorination, and chloroform is a product of chlorina-
tion.  Therefore the average chloroform concentration used in this
analysis is potentially skewed to a higher concentration than would
actually be found in an influent sample and the predicted concentrations
in Table III are also higher than will actually occur.
  the Discussion in Virtual  Safe  Dose  Section.
                                                                Air Toxics - 13

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                                      Table  III
            Predicted Annual Average Ground  Level Concentrations  in ug/m-3
                                   at Receptor Sites
    Receptor/
    Distance

    Annual Virtual
    Safe  Dose
     (70 yr. exposure)
     (2 yr. exposure)

    Deer  Island
    Closest
    Receptors

    DI Prison  E      400m
    DI Prison  W      400m
    Pt. Shirley  S   1000m
    Pt. Shirley  N   1500m
    Cottage Hill    2000m
    LI Hospital     3000m
    Winthrop
      Wash. Ave.    4000m
    Winthrop
      Main St.      4000m

    Long  Island
    Closest
    Receptors

    Thompson Is.    3000m
    Pt. Shirley S   4000m
    Hull  HS         4000m
    DI Prison       4000m
    Pt. Shirley N   4500m
    Cottage Hill    5000m
    Squantum
      NE  Shore     4000m
Carcinogens
Benzene
(Grp. A)1
0.67
23.5
1.12
0.94
0.23
0.12
0.06
0.06
0.04
0.02
0.04
0.03
0.05
0.03
0.02
0.02
0.02
Chloroform
(Grp. B2)
0.50
17.5
1.49
1.26
0.30
0.16
0.07
0.07
0.05
0.03
0.05
0.04
0.07
0.04
0.03
0.03
0.02
Carbon
Tetra-
chloride
(Grp. B2)
0.27
9.5
0.43
0.36
0.09
0.05
0.02
0.02
0.01
0.01
0.01
0.01
0.02
0.01
0.01
0.01
0.01
Methylene
Chloride
(Grp. B2)
56
1960
13.27
11.24
2.69
1.44
0.68
0.66
0.46
0.23
0.45
0.37
0.60
0.32
0.23
0.28
0.19
Triethylcne
(Grp. B2)
1.84
64.4
5.15
4.36
1.05
0.56
0.26
0.26
0.18
0.09
0.17
0.14
0.23
0.13
0.09
0.11
0.07
Tetra-
chloro-
ethylene
(Grp. C)
1.0
35
4.14
3.51
0.84
0.45
0.21
0.21
0.14
0.07
0. 14
o.i:
0.1'
0.10
o.o-
O.CH
O.Or
    These values represent the potential maximum increase in emissions.

         Appendix A for EPA's classification of carcinogens.
Air Toxics - 14

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                             Table III (Continued)
         Predicted Annual Average Ground Level Concentrations in ug/m3
                               at Receptor Sites
 Receptor/
 Distance

 Annual  Virtual
 Safe  Dose

 (ug/m3)
 Deer  Island
 Closest
 Receptors

 DI Prison E
 DI Prison W
 Pt. Shirley S
 Pt. Shirley N
 Cottage Hill
 LI  Hospital
Winthrop
  Wash.  Ave.   4000m
Winthrop
  Main St.     4000m
1,1,1
Tr i-
chloro-
ethane


Ethyl
Benzene Toluene Acetone
	
1.2

Trans
Dichloro- Chloro
Xylene ethylene Benzene
1.9x10   4.35x10   3.7xl03
                             4.4xlQ
                                                  7.9xl0
0.25
0.13
0.18
                                    0.09
                    0.40
                    0.20
                    0.81
                                                        0.41
                                        0.07
                                        0.04
                                        0.05
                                                                            0.02
400m
400m
1000m
1500m
2000m
3000m
7.72
6.11
1.47
0.78
0.37
0.36
5.15
4.36
1.05
0.56
0.26
0.26
11.67
9.89
2.37
1.27
0.60
0.58
23.72
20.10
4.62
2.57
1.22
1.18
2.18
1.84
0.44
0.24 '
0.11
0.11
1.43
1.21
0.29
0.16
0.07
0.07
1.75
1.48
0.36
0.19
0.09
0.09
                                                             0.06
                                                            0.03
Long Island
Closest
Receptors
Thompson Is.
Pt. Shirley S
Hull
High St.
DI Prison
Pt. Shirley N
Cottage Hill
Squantum
NE Shore


3000m
4000
4000m
4000m
4500m
5000m
4000m


0.24
0.20
0.33
0.18
0.13
0.15
0.10


0.17
0.14
0.23
0.13
0.09
0.11
0.07


0.39
0.32
0.52
0.28
0.21
0.25
n i f,


0.80
0.66
1.08
0.58
0.42
0.51
n TJ


0.07
0.06
0.10
0.05
0.04
0.05
f\ r\ i


0.05
0.04
0.07
0.03
0.03
0.04



0.06
0. 05
0.08
0. 04
0.03
0. 04

                                                                  0.03
                                                  0.02
                                                                                      o.o:
                                                                          15
                                                                     Air Toxics - 15

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       I.  Assessment of the Annual Average Ground Level Concentrations

          Thirteen compounds were found in the wastewater and put into an Indus-
          trial Source Complex (ISC) model.  Of the 13 compounds, six are EPA
          listed carcinogens (see classification below and in Appendix A), and
          seven are noncarcinogens.

          All modeled, annually averaged compound concentrations at the receptor
          points, (14 receptors for Deer Island, 15 for Long Island)  were compared
          to a virtual safe dose (VSD), established by an independent toxicolo-
          gist.  Each VSD represents the annual average concentration of a compound
          that would be expected to cause one additional cancer incidence in
          100,000 if exposed to that concentration for 70 years.

          The following is an analysis of the EPA listed carcinogenic compounds
          studied.  The projected annual concentrations represent the potential
          maximum increase in emissions.

              Benzene — Group A*

              If located at Deer Island

                                       Distance   Concentration     VSD in
                   Receptor            in Meters     in ug/m         ug/m

                  Prison E                400          1.06          23.5**
                  Prison W  .              400          0.87          23.5**
                  Pt. Shirley S          1000          0.21           0.67

              The VSD is for a 70 year life span, but those incarcerated at the
              Deer Island House of Correction serve an average of nine months and
              with an estimated 40% repeat rate, therefore, we used two years for
              the average exposure for the inmates.  Therefore, we divided the 70
              year life span by two and used 35 as a multiplication factor.  Using
              35 times the VSD, as an adjusted VSD, the predicted concentrations at
              the prison are below the adjusted VSD for benzene and the 12 other
              compounds.  None of the Long Island receptor concentrations exceed
              the VSD.
       *See classification of carcinogenic evidence, Appendix A.

      **Adjusted for partial lifetime exposure.
Air Toxics - 16

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        Chloroform — Group  B2*

        If located at Deer  Island

                                Distance   Concentration     VSD in

             Receptor           in Meters     in ug/m         ug/m

            Prison E               400          2.39          17.5**
            Prison W               400          1.98          17.5**
            Pt.  Shirley S          1000          0.48           0.5
            Pt.  Shirley N          1500          0.25           0.5

        The prison concentrations do not exceed the adjusted VSD for the
        prisoners  nor does the Pt. Shirley receptor concentrations exceed the
        VSD.  None of the Long Island  receptor concentrations exceed the VSD.

        Carbon Tetrachloride — Group  B2*

        If located at Deer  Island

                                Distance   Concentration     VSD in
             Receptor           in Meters     in ug/m         ug/m

            Prison E               400          0.23           9.5**
            Prison W               400          0.19           9.5**
            Pt.  Shirley S          1000          0.05           0.27

        The Prison concentrations do not exceed the adjusted VSD for the
        prisoners  and none of the other Deer Island nor Long Island receptors
        exceed the VSD.

        Methylene  Chloride — Group B2*

        If located at Deer  Island
             Receptor

            Prison E
            Prison W
            Pt.  Shirley S

        The prison concentrations do not exceed the adjusted VSD for the
        prisoners and  none of  the other Deer  Island nor Long Island receptors
        are close to or exceed the  VSD.
Distance
in Meters
400
400
1000
Concentration
in ug/m
14.54
12.01
2.94
VSD in
ug/m
I960**
I960**
56
 *See classification of carcinogenic  evidence, Appendix A.

**Adjusted for partial  lifetime  exposure.
                                                                    Air  Toxics  -  17

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              Trichloroethylene — Group B2*

              If located at Deer Island

                                       Distance   Concentration      VSD  in

                   Receptor            in Meters      in  ug/m          ug/m

                  Prison E                400         4.60           64.4**
                  Prison W                400         3.80           64.4**
                  Pt. Shirley S          1000         0.93            1.80

              The prison concentrations do not exceed the  adjusted  VSD for the
              prisoners and none of the other Deer Island  nor  Long  Island  receptors
              exceed the VSD.

              Tetrachloroethylene — Group C*

              If located at Deer Island

                                       Distance   Concentration      VSD  in

                   Receptor            in Meters      in  ug/m          ug/m

                  Prison E                400         3.31           35.0**
                  Prison W                400         2.74           35.0**
                  Pt. Shirley S          1000         0.67            1.0

              The prison concentrations do not exceed the  adjusted  VSD for the
              prisoners and neither the Deer Island nor  Long  Island receptor
              concentrations exceed the VSD.

              The receptor concentrations for the remaining seven noncarcinogens
              are all below 1 ug/m^ and all of the VSDs  for those compounds are
              three to four orders of magnitude above 1  ug/m  .   Therefore, none
              of these seven compounds exceed the VSDs at  any  receptor.
       *See classification of carcinogenic evidence,  Appendix  A.

      **Adjusted for partial lifetime exposure.
Air Toxics - 18

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J.  Risk Evaluation

    The virtual safe doses  (VSDs)  for  the thirteen organic contaminants are
    recommended by Dr.  Stong  to be used as acceptable levels to protect
    against chronic effects.   Background concentrations of air pollutants
    were not considered.  This evaluation addresses the increased risk, above
    background, to the  general public  from exposure to emissions from a
    secondary wastewater  treatment facility only, not including the emissions
    from the existing primary treatment plant.

    Additionally,  we assumed  a 100% absorption rate.  That is, each indivi-
    dual absorbs 100% of  the  chemical  that is within the inhaled air.  This
    is a conservative estimate which does not consider a portion of the
    chemical that  may be  removed from  the body prior to being absorbed (e.g.,
    via exhaled air).

    The VSDs for noncarcinogens are based upon acceptable occupational levels
    established by ACGIH.   The scientific basis for each chemical's workplace
    standard varies. That  is, some occupational standards are based upon
    chronic (i.e., long-term)  effects  while others may be based upon acute
    (i.e.,  short-term)  effects.  To account for the different endpoints used
    in ACGIH1s analysis of  the noncarcinogens, we compared the VSDs to the
    highest modeled ambient air concentrations within the annual (appropriate
    for long-term  effects —  see Table III, page 14 ) and 24-hour (appropriate
    for most short-term effects — see Table IV, page  21) averaging time
    periods.  The  VSDs  do not  take into consideration the difference between
    worker  exposure (eight  hours per day, five days per week) and environ-
    mental  exposure (24 hours  per  day, seven days per week), that is,

                    VSD x  8  hours x  5 days/week  =  0.24.
                           24  hours    7 days/week

    Therefore, as  a conservative measure the VSD's annual averages were also
    calculated with a time  adjustment  factor to account for this difference
    (see Table IV, page 20).   In all cases, with and without the time
    adjustment factor,  the  modeled values were two to three orders of
    magnitude below the VSDs.

    The VSDs recommended  for  the carcinogens or non-threshold toxicants, were
    closer  to the  modeled annual average values.  Therefore, we looked at the
    potential chronic effects (i.e., cancer incidence) that might be associ-
    ated with the  modeled concentrations of these six contaminants at the
    nearest receptor points.

    To consider the maximum individual lifetime risk, that is, the risk
    associated with an  individual  living nearest the source, exposed to the
    highest concentrations; the modeled ambient air concentrations were
    compared to the cancer  incidence dose-response relationship.  For each of
    the six individual  carcinogens, the maximum lifetime risk is within a
    cancer  incidence range  of 10~6 to  10~7.  This is below the acceptable
    cancer  incidence rate of  1 x 10~5  used in this analysis.
                                                                    Air  Toxics  -  19

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          Methods to estimate the additive cancer incidence  risk  associated  with
          the predicted ambient concentrations of the six carcinogens  were dis-
          cussed with Richard Hertzberg,  EPA,  Environmental  Criteria and  Assessment
          Office.  Mr. Hertzberg has been involved with the  development of EPA's
          risk assessment guidelines for  assessing the risk  from  exposure to
          mixtures of pollutants.  Little information is available  on  the additive,
          synergistic, or antagonistic properties of  chemicals.   Likewise, infor-
          mation on the cocarcinogenic or promotion potential  of  chemicals are
          limited.

          Therefore, as a conservative estimate of the potential  cancer incidence
          we assumed the tumor actions of each identified carcinogen to be indepen-
          dent and added the individual risks  associated with  their predicted
          ambient concentrations.  Statistically this represents  a  96-97% upper
          confidence limit.  That is, the true risk would likely  be 96-97% lower
          than the estimated risk.  Estimates  of the  additive  increase in the
          cancer incidence among the populations at the six  closest receptor points
          exposed to the six modeled ambient air concentrations for the carcinogens
          are below or within the same order of magnitude as the  VSD's.

          In analyzing the exposure to the inmates at the Deer Island  House  of
          Correction, we considered a partial  lifetime exposure to  the carcinogens
          because each inmate is exposed  for less than 70 years.  The  average term
          served by inmates is nine months with a 40% rate of  repeat incarcera-
          tion.  Therefore, we estimated  the average  amount  of time served to be as
          two years.  Determining the virtual  safe dose of each carcinogen for two
          years we divided the 70 year lifespan by two for a multiplication  factor
          of 35.  Therefore, modeled concentrations of the carcinogens at the
          prison were compared to 35 times the virtual safe  dose.   The adjusted
          VSDs were not exceeded at the prison for the six carcinogens.
Air Toxics - 20

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                                  Table IV
          Predicted Highest 24-Hour Ground Level Concentrations in
                           ug/rn^ at  Receptor  Sites

                                                              Highest  24  Hour
                                  VSD      VSD X  0.24a
Acetone

Chlorobenzene

1, 2-trans Dichloroethylene

Ethylbenzene

Toluene

1,1,1 Trichloroethane

Xylene
 aTime adjustment factor for environmental  vs.  worker  exposure.   Environ-
  mental exposure being 24-hours per  day and  worker  exposure  8-hours per day.
VSD
18,00
3,500
7,900
4,350
3,700
19,000
4,400
VSD x 0.24a
4,320
840
1,900
1,044
888
4,560
1,056
DIb
303.03
22.37
1.43
65.76
149.14
92.19
27.81
Lie
90.51
6.68
0.05
19.64
44.55
27.54
8.31
       Island Prison,  East;  closest receptor  if  the secondary  treatment
  plant is located at  Deer Island.

 GLong Island Head; closest  receptor if  the secondary  treatment  plant  is
  located at Long Island.
                                                                    Air Toxics - 21

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      K.  Ozone
          A rough estimate was made of the expected total  volatile organic  com-
          pounds (VOCs) that will be emitted from a secondary wastewater  treatment
          plant.  The following assumptions were used:

          Assumptions:

          1.  The 13 compounds found in the analysis of the wastewater  sample  are
              the only VOCs in the wastewater.

          2.  Of the 13, one, 1,1,1 trichloroethane is  considered  photochemically
              nonreactive, so only 12 compounds will be added for  total VOCs.

          3.  The concentrations in the water are those that would volatize into
              the air (i.e., assume 100% volatilization).   A calculation  is
              included below to correct this to the estimated average volatiliza-
              tion rate of 85%.

          4.  The flow rate at Deer Island is constant  at  500 MGD  every day.
                                                      Highest Measured
                         VOC                       Concentrations  in  ug/1

                  Methylene chloride                          86
                  1,2 Dichloroethylene                         6
                  Chloroform                                  12
                  Benzene                                      6
                  Tetrachloroethylene                         40
                  Toluene                                    260
                  Ethyl Benzene                               13
                  Acetone                                    710
                  Xylenes                                    100
                  Trichloroethylene                            9
                  Chlorobenzenes                          	9

                  Total                                   1,251
          500 MGD at Deer Island = x I/day
          500,000,000 gal/day x 10 1/2.64 gal = 1.8939 x  109 I/day

          (1251 ug/1) (1.8939 x 109 I/day) = 2.3693 x  1012 ug/day
                                           = 2369.3 kg/day

          2369.3 kg/day x 365 days/year = 8.6479 x  105 kg/year

          8.6479 x 105 kg/year x 2.2046 Ibs/kg = 1.9065 x 106 Ibs/year
          1.9065 x 106 Ibs/year x 1 ton/2,000 Ibs = 953.3 tons/year

          953.3 tons/year x 0.85 = 810 tons/year
Air Toxics - 22

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    Any VOC source that  emits over 100 tons per year is considered a major
    source of VOC and must  be controlled to ensure the attainment of the
    national Ambient Air Quality Standard for ozone.  Since this will be a
    new source of VOC, the  State would require control under their Regulation
    310 CMR 7.02, New Source Review  (NSR).  The wastewater treatment plant
    would have to be controlled for  attainment of the ozone standard regard-
    less of its final siting location.
L.  Controls

    1.   Under NSR the  State  could offset the increase of VOC emissions at the
        wastewater treatment plant by reducing emissions from another
        source.   For  instance,  the State could require a more stringent cut
        point for the  hydrocarbon standard in the automobile inspection and
        maintenance program  to  obtain the required offset.  If the State does
        not use  the offset rule, technological controls are available to
        reduce the emissions of VOSs.

    2.   The secondary  aeration  tanks could be covered and the emissions could
        be vented to  a carbon adsorber, chemical scrubber or other add-on
        control  device to control VOCs.

    3.   The industrial sources  could be required to pretreat their VOC
        emissions or  not allow  them into the wastewater treatment collection
        system at all  and dispose of them in another manor.  This would also
        control  possible emissions at the headworks and through the collec-
        tion system.

    An  analysis  of the existing controls available must be included in the
    design phase of this project.
                                                                    Air  Toxics  -  23

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                     AppendJx AT- I :   ( ,.t i-^oriz.it ion  .!  0\eraJl Evidence
      Group A:  Human Carcinogen

      This category is used only when there is sufficient evidence  from epidemi-
      ologic studies to support a causal association between  exposure to the
      agent(s) and cancer.
      Group B:  Probable Human Carcinogen

      This category includes agents for which the evidence of  human  carcinogenicity
      from epidemiologic studies ranges fro almost "sufficient*  to  "inadequate."
      To reflect this range, the category is divided into higher (Group Bl)  and
      lower (Group B2) degrees of evidence.  Usually,  category Bl is reserved  for
      agents for which there is at least limited evidence of carcinogenicity to
      humans from epidemiologic studies.  In the absence of adequate data  in
      humans, it is reasonable, for practical purposes,  to regard agents for which
      there is sufficient evidence of carcinogenicity  in animals as  if  they
      presented a carcinogenic risk to humans.   Therefore, agents for which  there
      is inadequate evidence from human studies and sufficient evidence from animal
      studies would usually result in a classification of B2.

      In some cases, the known chemical or physical properties of an agent and the
      results from short-term test allow its transfer  from Group B2  to  Bl.
      Group C:  Possible Human Carcinogen

      This category is used for agents with limited evidence  of  carcinogenicity  in
      animals in the absence of human data.  It  includes  a  wide  variety  of  evidence:

      a.  Definitive malignant tumor response in a  single well-conducted experiment.

      b.  Marginal tumor response in studies having inadequate design  or reporting.

      c.  Benign but not malignant tumors with an agent showing  no  response in a
          variety of short-term tests for mutagenicity; and

      d.  Marginal responses in a tissue known to have a  high and variable  back-
          ground rate.

      In some cases, the known physical or chemical properties of an agent  and
      results from short-term tests allow a transfer from Group  C to B2  or  from
      Group D to C.
Air Toxics - 24

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Group D:  Not Classified

This category is used for agent(s)  with inadequate  animal  evidence  of
carcinogenicity.
Group E;  No Evidence of Carcinogenicity  for  Humans

This category is used for agent(s)  that show  no  evidence  for  carcinogenicity
in at least two adequate animal  test  in different species or  in both epidemi-
ologic and animal studies.
Source:  Proposed Guidelines for  Carcinogen Risk Assessment  49  PR  46294,
November 23,  1984.
                                                                    Air Toxics - 25

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	II-7
water quality outfall evaluation

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II-7.  WATER QUALITY OUTFALL EVALUATION

A.  Background

    EPA received comments on the water quality  evaluations contained in Volume
    II of the SDEIS, Section 11.3.   The comments centered on the following
    areas:

    1.  Was the SDEIS accurate  in predicting the water quality impacts at the
        President Roads  location?

    2.  What were the limitations of the MERGE  modeling analysis?

    3.  Would ambient water  quality conditions  in the Harbor preclude any
        outfall from meeting water quality standards?

    4.  Were other outfall locations available  that might be environmentally
        acceptable?

    In order to respond  to these questions EPA  evaluated four potential
    outfall locations, two within Boston Harbor and two outside the Harbor.
    An EPA model DKHPLM  as used  to predict initial dilutions at these
    locations.   The modeling results indicated  that the potential for initial
    dilution of secondary effluent to meet EPA's saltwater aquatic life
    criteria exists at all discharge locations.  The results also indicate
    that the President Roads and South Channel  locations, both within the
    Harbor, have the potential for greater initial dilutions.  The.limiting
    factor for the acceptability of these two locations is the ambient water
    quality.  Detailed monitoring at these potential locations is recommended
    in order to establish a  comprehensive ambient water quality data base.
    Additional experimental  and/or numerical modeling is also necessary for
    the two channel locations to assess the significance of the shadowing
    effect, the initial  dilution reduction due  to the orientation of diffusers
    in a direction parallel  to the ambient current.

    The construction and cost implications of the various discharge locations
    are also discussed.

    Water quality issues were addressed in SDEIS through comparison of
    expected pollutant concentrations after initial mixing at the discharge
    location with established and proposed saltwater aquatic life criteria.
    The material presented in the SDEIS (Tables 11.3-10 through 11.3-12)
    suggests that the past and existing primary effluent concentrations of
    copper, cyanide, PCBs and heptachlor may result in the violations of
    saltwater aquatic life criteria.  These violations were projected for
    periods of minimum current velocity, maximum ambient density stratifi-
    cation and above average pollutant loadings for a discharge in President
    Roads.  All of these assumptions are environmentally conservative and in a
    modeling effort yield minimum initial dilutions.
                                                                 Water Quality  -  1

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           Violation  estimates were based on initial dilution modeling performed with
           the model  MERGE.   Modeling  results should be interpreted with an appreci-
           ation  for  the  limits of modeling methodology and scarcity of the existing
           input  data.  The model MERGE estimates dilutions of sewage plumes
           discharged through a multiport diffuser into a saltwatar ambient environ-
           ment.   The model accounts for effects of uniform ambient current, ambient
           density stratification, discharge depth and certain diffuser specifi-
           cations.   Besides  being limited by the simplifying assumptions intrinsic
           to  the model development, the modeling effort is dependent on the
           reliability of the input data.  At the present time, ambient current and
           density data for the inner  and outer harbor is not extensive and reliable
           enough to  support  sophisticated modeling efforts.  Similarly, precise
           diffuser specifications and expected secondary effluent quality have not
           been established.

           Although precise evaluation of water quality impacts is not possible at
           this time, a preliminary evaluation of alternative outfall locations was
           performed  by EPA as part of the final EIS.  This evaluation was performed
           to  address the issue of water quality advantages and disadvantages of
           various outfall locations.  The relationship of these outfall locations to
           siting of  a secondary wastewater treatment plant at either Deer Island or
           Long Island was subsequently investigated.  The evaluation was also
           performed  in preparation for an assessment of future NPDES discharge
           permit requirements and compliance.

           The SDEIS  evaluated the discharge of secondary effluent at a location
           called the President Roads.  Other possible discharge locations were
           studied by MDC as  part of the Draft Deer Island Facilities Plan (Havens
           and Emerson for MDC, 1984).  These locations were President Roads, South
           Channel, Broad Sound and Seven-Mile presented in Figure 1.

           A comparative  assessment of initial dilutions was performed by EPA with
           the use of model DKHPLM at  the four locations.  The DKHPLM model evaluates
           effluent discharge from a multiport diffuser and accounts for the effects
           of  discharge depth, uniform current velocities, and linear salinity and
           temperature profiles.  It does not assess the effects of shadowing, the
           reduction  of actual initial dilution of downstream diffuser plumes cause
           by  re-entrainment  of effluent discharged from upstream diffuser plumes.
           This effect is minor when the current is perpendicular to the diffuser,
           but can be significant when current is parallel to a long diffuser, as
           would  be the case  in locations such as President Roads and South Channel.
           Although this  model is different from the MERGE model employed in the
           SDEIS,  it  relies on similar input data.  Therefore, the precision of the
           initial dilution values is  subject to the limitations similar to those of
           the previous modeling effort.  The results, however, may be used for the
           purpose of preliminary comparison of initial dilutions at different
           outfall locations.

           The DKHPLM model input parameters include:  diffuser specifications, such
           as,  port spacing,  port diameter, port velocity, port discharge angle, and
           the angle  of ambient current with respect to horizontal discharge.  The
Water Quality - 2

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                   ALTERNATIVE OUTFALL SITES
Figure 1
                                               Water Quality - 3

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           input also includes ambient saltwater parameters,  such  as:   ambient
           uniform current, ambient temperature stratification,  ambient salinity
           stratification, and the discharge depth.   The  effluent  characteristics  of
           concern are salinity and temperature.  The comprehensive  summary of  input
           data to the DKHPLM model is presented in  Table 1.   Each location was
           modeled with a single reasonable diffuser specification presented in Table
           2 and developed in the SDEIS.

           The results, summarized in Table 3,  indicate that  average initial
           dilutions, those that reflect  approximately 50% current frequency, are
           comparable for the President Roads and South Channel  discharge  locations
           and are high for discharges which are in  proximity to land.   These high
           dilutions are due to high velocity tidal  currents  present in these harbor
           channels.  The average initial dilutions  for the Broad  Sound and
           Seven-Mile locations, although modeled at greater  depth,  are lower and
           reflect the slower currents present  in these locations.   The effects of
           slower current velocities, those that represent approximately 10%
           frequency, at President Roads  and South Channel were  also investigated.
           The results indicate that these initial dilutions  achieved  at President
           Roads and South Channel are also higher than the average  initial dilutions
           possible at the Broad Sound and the  Seven-Mile locations.

           Modeling results indicate that the potential for initial  dilution of
           secondary effluent to meet saltwater aquatic life  criteria  exists at all
           discharge locations.  The results also indicate that  the  locations with
           greater current velocities, President Roads and South Channel,  have  the
           potential for greater initial  dilutions.   These conclusions, however, are
           based on the assumption that sufficient supply of  unpolluted ambient
           dilution water is available and comparable at  the  four  locations, and that
           shadowing does not significantly reduce the initial dilutions at the
           President Roads and South Channel locations.

           Presently, the harbor represents an  ecologically stressed environment.
           Existing water quality surveys of the harbor indicate that  water quality
           criteria are being exceeded for certain metals at  various harbor locations
           (Metcalf & Eddy, Inc., MDC 301(h) Application,  1984,  pp.  II  -
           B5.169-.178).  Also, the studies of  sediment contamination  in the harbor
           (Metcalf & Eddy, Inc., MDC 301(h) Application,  pp  II  -  5B.179-.295;
           Battelle, Organic Pollutant Biogeochemistry Studies Northeast U.S. Marine
           Environment, Part I and II, 1984) document the existing high levels  of
           pollutants.

           Due to the degraded condition  of Boston Harbor,  initial dilution calcu-
           lation can only be used as guidelines for determining compliance with
           water quality standards.  The  draft  National Pollutant  Discharge Elimi-
           nation System (NPDES) Permit includes chronic  and  acute effluent toxicity
           limitations, toxicity reduction evaluation requirements and  bioaccumula'
           tion assessment requirements.   The draft  permit also  indicates  that  EPA
           will evaluate the results of the toxicity tests in conjunction  with  the
           chemical analyses required by  the permit  to develop site-specific
           numerical effluent limitations for specific pollutants.   EPA believes the
Water Quality - 4

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                                    TABLE 2
                     EFFLUENT AND DIFFUSER SPECIFICATIONS
                   Specification

               Diffuser lengthen

               Jet velocity1 m/sec

               Port diameter1 m

               Port spacing1 m

               Discharge angle

               Current angle w/respect
                 to horizontal discharge

               Jet temperature2 °C

               Jet salinity2 '/•>•>
                                        Value

                                          1,829

                                          2.134

                                          0.152

                                          3.048

                                         vertical
                                         17.2

                                          1.0
1Source:

^Source:
C.E. Maguire,  SDEIS,  1985.

EPA Discharge  Monitoring  Reports, June  1985.
                                   TABLE  3
             INITIAL  DILUTION AND HEIGHT OF RISE OF EFFLUENT PLUME
  Outfall Location
      Current	

President Roads
approximately 50%
current

President Roads
approximately 10%
current

South Channel
approximately 50%
current

South Channel
approximately 10%
current

Broad Sound
approximately 50%
current

Seven-Mile
approximately 50%
current
                 Initial Dilution
                      214
                     153
                     194
                     153
                     115
                                   73
                                       Plume Height of Rise
                                                m
                                               5.83
                                               7.50
                                               5.93
                                               7.49
                                               7.95
                                                           8.59
                                                                           Water  Quality  -  5

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                                          TABLE  1
                        AMBIENT WATER  PARAMETER INPUT TO DKHPLM MODEL
      Ambient
     Parameter

Discharge depth m

Approximately 50%
  current2 m/sec

Approximately 10%
  current2 m/sec

Bottom salinity1
  °/00

Salinity gradient1
  VOO/M
       Bottom temperature
         °C

       Temperature gradient
         °C/m
                                President
                                  Roads

                                  20.15
 0.31


 0.15


31.85


 0.017


12.51


 0.251
 South
Channel

 15.12
 0.27


 0.15


31.85


 0.017


13.o3


 0.253
                              Broad
                              Sound

                              23.35
                                                                 0.10
                31.85


                 0.017


                11.03


                 0.363
                            Seven-
                             Mile

                             31.6
                               0.05
                                                                              31.85
                                                                               0.017
                                                                        0.461
        LSource:    Metcalf & Eddy, Inc., MDC 301(h)  Application,  1979.

        ^Source:    NOAA, Boston Harbor Tidal Current Tables,  1985.

        ^Source:    EG&G, prepared for Havens & Emerson,  Data  Summary and  Documenta-
                   tion for Field Studies in Boston  Harbor, 1984.
Water Quality - 6

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above mentioned approach and procedures  in  conjunction with other cleanup
efforts (residuals management,  CSO treatment)  will  eventually  result  in
Boston Harbor achieving its designated water quality  classification and
use.

The environmental concerns, other than compliance with water quality
criteria,  should also be considered in evaluating various discharge
locations.  The Draft Deer Island Facilities Plan summarizes the results
of a broad environmental assessment of the  four  sites.   The assessment
included the evaluations of:  the potential of the  effluent to  be carried
into the harbor, onto depositional areas, and  toward  beaches; the
potential  for exceeding water quality criteria for  conventional as well as
priority pollutants;  the potential for affecting levels  of metals and
organics in sediment  and biota;  the potential  of effects on lobster,
winter flounder and fishing activities;  and the  potential for aesthetic
impacts, and conflicts with other uses of harbor.   The draft report
concludes  that Broad  Sound and  Seven-Mile locations are  the most environ-
mentally acceptable for a combination of Deer  Island  and Nut Island flows.

MWRA will  be continuing outfall  evaluations in the  Facilities Plan for the
proposed secondary treatment plant. The ultimate choice of outfall
location will entail  further study by MWRA  in  close coordination with
EPA.  Future studies  should address the  following issues to allow for an
informed choice with  respect to an outfall  location.  More comprehensive
oceanographic data must be acquired to allow for accurate modeling of
water quality impacts, such as;  initial  and far-field dilution  of
secondary  effluent as well as sedimentation and  transport of the secondary
effluent particles.  An experimental and/or numerical modeling  effort
should also be used to assess the significance of the shadowing effect,
the reduction of initial dilution due to orientation  of  diffuser in a
direction  parallel to the ambient currents  in  President  Roads and South
Channel locations. Factors, such as, effects  on recreational and fishing
resources  as well as  aesthetic  values of the estuary  should also be
incorporated into an  evaluation of the secondary effluent discharge
location.   In addition, comprehensive ambient  water and  sediment quality
data are necessary for the assessment of the future improvements and  the
recovery of the presently stressed environment.

Outfall construction  feasibility for the four  discharge  locations were
judged to be similar  for Deer Island and the Long Island secondary
treatment  sites.  EPA review of existing reports, including the Draft Deer
Island Facilities Plan, determined that  an  outfall  originating  from either
Deer Island or Long Island to any of the proposed locations is  possible.
No major difference in outfall  construction or impact is expected for
either island.  Some  of the discharge locations  require  crossing the  main
shipping channel for  Deer Island and all may for Long Island.   Both
trenching  and tunneling are open for consideration  at this point in time
and may be possible from either Deer Island or Long Island treatment  plant
sites.
                                                              Water Quality - 7

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           Since more detailed  work  will  be  required of MWRA on location and cost of
           outfalls during facilities  planning,  EPA at this time did not do any
           further cost analyses.  Preliminary construction and costs of outfall to
           the President Roads  location are  given  in the SDEIS  (Vol. II, Section
           12-4) and for the Deer  Island  and Long  Island options are $47.72 and
           $91.86 million, respectively  (1984 dollars, ENR 4200).  The SDEIS
           concluded that because  Deer Island and  Long Island are close to one
           another, there is relatively  little difference in the cost of constructing
           an outfall from either  island  to  the  President Roads (4%-6% difference of
           total plant cost).

           An additional outfall cost  analysis for the Deer Island option, cited in
           the Draft Deer Island Facilities  Plan (Havens & Emerson for MDC, 1984), is
           presented in Table 4, for the  three other outfall locations.  It should be
           noted that these costs  are  preliminary  and are given in 1983 dollars.
           They are included to give the  reader  initial comparative cost infor-
           mation.  Further detailed costing of  alternative outfall sites will be
           prepared in the upcoming  MWRA's Facilities Plan for  the project.
                                          TABLE 4
                   CONSTRUCTION  COST COMPARISON FOR THE DEER ISLAND OPTION
                                                         Construction  Costs
                                                       1983  Dollars  (Millions)
                       Distance to Outfall          Trench                   Tunnel
           Site        	(Feet)	       Construction            Construction

       Broad Sound          28,000                  280                      325

       South Channel        10,500                  105                      142

       Seven-Mile           35,000                  410**                   430**
       **Does not include power costs.   (Includes pump stations,  diffusers  and  shafts
         for tunnels.)  Seven-Mile site costs were developed  in MDC  Site Options
         Study and updated by 10% to October  1983.
    ''•' Source: Havens & Emerson / Parsons Brinkerhoff, Draft Deer Island Facilities Plan,
      1984.  Prepared for the MDC.
Water Quality - 8

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II-8
 costs

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II.8 Cost Estimates

     A.    Background

          Comments on  the construction  cost estimates  in  the SDEIS included:

          1.    Whether the estimates  significantly  underestimated the  probable
               costs of construction.

          2.    Whether the differences  in  estimated costs amongst the
               alternatives were significant.

          These questions led  to a  series  of meetings  among  the engineers  who
          had at one time or another  proffered  cost estimates for the  project,
          including Metcalf &  Eddy, the original  authors  of  the Nut  Island
          Site Options Study;  CE Maguire,  the principal authors of the SDEIS;
          and Camp,  Dresser &  McKee,  consultants  to the MWRA.   These meetings
          led to the conclusion  that  a  broad range  of  costs  for any  given
          facility was possible, depending on the assumptions made by  the  cost
          estimator, including the  size of the  facility,  the specific
          processes to be included, the "furnishings"  to  be  included as
          "initial construction," the kind of construction,  the assumed
          difficulty of the work, etc.

     B.    New Estimates
          Since  it  was  not  clear  just  what  differences  did  exist  in
          assumptions for the  various  alternatives,  and since  new data  on  the
          site  and  on the proposed  facility were  being  developed  in  the review
          of  the proposed action  by the  MWRA subsequent to  publication  of  the
          SDEIS, the MWRA asked  its consultants to  prepare  new, up-to-date
          estimates.  The major  changes  in  assumptions  made by Camp,  Dresser  &
          McKee  included:

          1.    Increase in  the unit costs of primary sedimentation tanks from
               $78/square foot to $151;  of  secondary sedimentation tanks from
               $112/square  foot  to  $204; and of aeration  basins from
               $164/square  foot  to  $266.

          2.    Increase in  sludge processing costs  to reflect  the
               modifications to  the solids  management including adding  costs
               of $21 million  for dissolved air flotation of secondary
               sludges, and $24  million  for dewatering  of all  sludges.

          3.    Adjustments  in  the costs  for removal  of  unsuitables —
               essentially  an  estimate of costs associated  with disposal of
               surplus  excavated  material.   At Deer  Island, the cost  was
               estimated at $15  million  to  reflect  the  cost of removal  of  the
               drumlin. At Long Island, the cost was estimated at $45
               million, which  reflects the  greater  amount of excavation
               necessary to produce a  suitable site  at  this location.
                                                                         Costs  -  1

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                 4.    Adjustment  of  the  estimated  costs  of  pumping  in  two  manners.
                      The estimates  of  influent  and  effluent  pumping at  Deer  Island
                      were increased by  $15  million  and  $60 million respectively,  to
                      reflect  more recent  costs, and,  the estimates for  pumping  at
                      Long Island were  revised to  reflect both  the  more  recent costs
                      and the  need for  an  intermediate pump station in those
                      alternative layouts  in which both  the treatment  facility and
                      the hospital would remain  on the Island.

                 5.    Inclusion of allowances for  yard piping,  site work,  on-site
                      electrical  distribution and  instrumentation  (which includes  the
                      $30 million computer).  These  items added approximately $140
                      million  to  each alternative.

                 6.    Inclusion of allowances for  miscellaneous site conditions  which
                      are unique  to  each island.   The  costs for piers  and  erosion
                      control  at  Long Island were  estimated to  be higher than at Deer
                      while the cost for dikes to  prevent wave  run-up  are  expected  to
                      be greater  at  Deer Island.

                 7.    Inclusion of allowances for  additional  costs  if  the  facility  is
                      constructed on an  island which is  also  occupied  by an
                      institution.  An  increment of  about $40 million  was  made to
                      account  for the more complicated layouts  which would be
                      expected and for  additional  problems  in scheduling and
                      executing construction.

                 In  addition,  allowances were made for the  mitigation  of
                 environmental impacts  and for ancillary construction  -  particularly
                 bridge repairs - which  would be needed  to  allow construction to take
                 place.  Special  cost allowances were  also  made for bussing and
                 barging of personnel and  materials  to the  construction  site, control
                 of  construction  noise,  provisions for local  recreational  facilities,
                 special treatment for  visual enhancement,  bridge
                 rehabilitation/replacement  and  archaeological  preservation.  Table
                 C-l shows the costs of  these items, by  site  option and  the
                 assumption of the presence  or absence of the existing institutions
                 on  each island.

                 The differences  in  such costs amongst the  alternatives  were  in  the
                 areas of bridge  rehabilitation, visual  enhancement, local recreation
                 and the need  for control  of construction noise.  The  differences  in
                 the bridge costs reflect  the estimated  cost  for replacement  of  the
                 two smaller bridges on  the  approach to  Deer  Island, versus the  cost
                 for replacement  of  the  large span bridge from  Moon Island to Long
                 Island.  Costs allowances for visual  enhancement on the Long Island
                 site were higher because  the island has more shoreline, and  because
                 it  was expected  that the  plant  construction  would  result  in  greater
                 change to the landform.   Local  recreational  opportunities were
                 judged to be  possible at  Deer Island, but  not  at Long Island.   And
                 finally,  allowances for some form of  construction  noise control were
                 provided for  both Islands with  the  institutions in place, but only
                 at  Deer Island if the  institutions  were removed.
Costs - 2

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                                   TABLE  C-l
                       POTENTIAL MITIGATION EXPENDITURES
                                  ($ MILLION)
                                 With Institutions
                                               Without Institutions
Barging/Busing
Local Recreation
Visual Enhancement
Bridge Repair
Construction Noise Control
Archaeological
Odor/Air Emissions
Deer
45
5
5
4
3
2
23
Long
45
0
10
15
3
2
23
TOTALS

Source:
                         87
             98
Deer
45
5
5
4
3
2
11
87
issociat
Long
45
0
10
15
0
2
11
95
es , 1985.
Camp, Dresser and McKee, Inc.; Thibault/Bubly Associates

 Changing the assumptions as to the status of the institutions also
 changes costs.  Removing the prison from Deer Island would lower
 construction costs by about $20 million, as a result of $40 million
 in savings attributable to construction in an uncongested site and
 an offset of $20 million resulting from the loss of the existing
 clarifiers.  Keeping the hospital on Long Island would raise costs
 by about $100 million, reflecting the changed pumping configuration,
 and an adjustment for construction in a confined site.

 In addition, table C-2 summarizes the estimated cost for all the
 alternatives, all made using the same underlying assumptions.  The
 primary treatment alternatives costs were based only upon primary
 treatment components, and an extended outfall with a total estimated
 cost of $479.5 million.

      COMPARATIVE CONSTRUCTION COSTS OF OPTIONS (1985)
PRIMARY
SECONDARY
       All Deer

       1,065-1,090
     1,11s1-!,1352
 All Long

  1,180-1,285
1,1803-1,2854
                                               Primary:        Primary
                                               Nut & Deer      Deer & Long
                                               Secondary: Deer Secondary: Long
1,210-1,230
1,275-1,295
1,345-1,365
1,355-1,375
 prison removed

 prison to remain

 hospital removed

^hospital to remain

Source:  Camp, Dresser -.nd McKee, Inc.,  FEIR On Siting of Wastewater Treatment
Facilities for Boston Harbor, 1985
                                                                         Costs - 3

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         II-9
facilities layouts

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I1-9  FACILITIES LAYOUT SCENARIOS
    A.  Background

        Questions on the  specific physical site layout characteristics of
        wastewater treatment  facilities that might be designed at the alter-
        native treatment  facility siting options included:

        1.   What  areas  of land might be required for wastewater treatment at
            each  alternative  siting location?

        2.   What  effects  might such facilities designs have on the appearance,
            recreational  potential, and documented archeological and cultural
            resources at  the  alternative sites?

        To  explore these  questions, two teams of site planners were assembled
        and asked to explore  the issues.  One team was organized by EPA
        consultants and the other by the applicant, the Massachusetts Water
        Resources Authority.  Each team included sanitary and civil engineers
        and landscape architects.  Each team worked independently, with
        somewhat  different assumptions as to the variables to be included.
        Both worked at  a  scale of 1"=200' and both considered profile views of
        the sites as well as  topographic plans.
    B.   EPA Facilities  Layout Studies

        The EPA consulting  team explored the following alternative assumptions:

        1.   For all  facilities for primary and secondary treatment on Deer
            Island:
            a.   removal of  the prison off the island.
            b.   relocation  of the prison on the island.
            c.   a  treatment technology that would require less land than
                "activated  sludge."
        2.   For all  facilities on Long Island:
            a.   removal of  the hospital off the island and use of all uplands
                without documented archeological resources
            b.   treatment technology that would require less land than
                •activated  sludge."
        3.   For facilities  to be divided between Deer Island and Long Island:
            a.   division of facilities as proposed in SDEIS (primary for
                northern system on Deer Island, everything else on Long
                Island).
            b.   alternative facilities, 40% on Deer Island, 60% on Long Island.

        The specific alternatives, and the consultant's evaluations, included:
                                                            Facilities  Layouts - 1

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             Alternative 1A:  All Deer Island Secondary

                 Assumptions:

                 1.  Existing prison to remain
                 2.  Activated sludge process as per SDEIS

                 Effects:

                 The environmental impacts of this alternative are those described
                 in the SDEIS and subsequent environmental reviews in the FEIS.

             Alternative IB:  All Deer Island Secondary

                 Assumptions:

                 1.  Existing prison to be relocated off-island
                 2.  Activated sludge process as per SDEIS

                 Design Modifications:

                 1.  Earth berm across northern end of island
                 2.  Playfield on low land between berm and Winthrop
                 3.  Parkway corridor along east shore
                 4.  Small park at south end of island
                 5.  Pedestrian/bicycle paths and promenades circling the shoreline
                     and ascending embankments.

                 Effects:

                 1.  Removal of existing prison buildings could improve view of
                     island from Winthrop and elsewhere in harbor
                 2.  Berm, if properly designed, could block view  of plant from
                     Winthrop and provide topographic variety from elsewhere in
                     harbor
                 3.  Harbor views from southern end of island, and access to them,
                     could be preserved with proper design.
                 4.  Facility emissions (whatever they might be) to prisoners would
                     be eliminated.

             Alternative 1C:  All Deer Island Secondary

                 Assumptions:

                 1.  Existing prison to be relocated over treatment plant
                 2.  Activated sludge process as per SDEIS

                 Design Modifications:

                 1.  Same as for alternative IB
                 2.  New prison on platform over treatment plant
Facilities Layouts - 2

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    Effects:

    1.  Similar to those of alternative IB except that views  of  Deer
        Island would depend on quality of architecture.

Alternative ID:  All Deer Island Secondary

    Assumptions:

    1.  Alternative treatment process (pure oxygen)
    2.  Relocate prison to southern end of island

    Design Modifications:

    1.  Substitute process alternatives
    2.  Relocate prison south of drumlin
    3.  Construct earth berm across northern end  of  island
    4.  Playfield on low land north of berm
    5.  Small park at south end beyond prison
    6.  Retain drumlin

    Effects:
    1.  Similar to those of alternative 1C
    2.  Smaller plant size makes air emission controls more practical
        and less costly.

Alternative IE:

    Assumptions:

    1.  Alternative treatment technologies
    2.  Prison to be removed from island

    Design Modifications:

    1.  Substitute process alternatives
    2.  Remove prison from island
    3.  Construct earth berm across northern end  of  island
    4.  Playfield on low land north of berm
    5.  Small park at south end beyond prison
    6.  Retain drumlin

    Effects:

    1.  Same as those for alternative ID with greater  Winthrop buffer
        and larger local and regional parks.
                                                       Facilities Layouts  -  3

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              Alternative  2A:  All Long  Island Secondary

                 Assumptions:

                 1.   Hospital to be relocated
                 2.   Activated sludge process
                 3.   Plant to be fitted into upland plateau

                 Effects:

                 1.   Wetlands, pine plantation and documented archeological
                      resources at southwestern end of island, escarpments, and Long
                      Island  Head could  be preserved.
                 2.   Roadway would be forced close to edge of escarpment.
                 3.   Parade  Ground would be required for treatment plant.
                 4.   Cemeteries to be relocated.

              Alternative  2B:  All Long  Island Secondary

                 Assumptions:

                 1.   Hospital to be relocated.
                 2.   Alternative treatment process, less space demanding.
                 3.   Plant to be fitted to upland plateau, etc.

                 Effects:

                 1.   Wetlands, pines, parade ground, Long Island Head, cemeteries,
                      archeological sites, etc. could be preserved.
                 2.   Depending on size  reduction attained, plant could be well set
                      back from escarpments allowing ample room for bicycle paths,
                      roadway, walkways  and landscape planting.
                 3.   Smaller plant size makes emissions control less costly.

              Alternative  3A:  Split Deer Island/Long Island Secondary

                 Assumption:

                 1.   Treatment plant to be divided between Deer Island and Long
                      Islands as proposed in the SDEIS
                 2.   Activated sludge process

                 Effects:

                 1.   On Long Island, impacts similar to those of alternative 2A,
                      somewhat less severe, cemeteries probably need not be re-
                      located.
                 2.   On Deer Island, impacts similar to those of alternatives
                      employing less space demanding technologies.
                 3.   Deer Island effects limited to primary effects only.
Facilities Layouts - 4

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C.  MWRA Facilities Layout  Studies

    The MWRA site planning  team  explored the following alternatives:

    1.   On Deer Island
        a.  prison to remain
        b.  prison to be  removed
    2.   On Long Island
        a.  hospital to remain
        b.  hospital to be  removed

    For all these alternatives it was assumed that the total plant area
    would aggregate 140 acres, a "reasonable, conservative assumption"
    based on "technology  that requires the maximum land area of reasonable
    alternative technologies," the alternative that "requires the most
    land of all the reasonable alternatives."  It is a somewhat larger
    area than any plans shown in the SDEIS.

    The MWRA consultant said of  this exploration, "conceptual site layouts
    were developed that focus on the factors of noise, odor, visual
    impact, and operational reliability.  The approach used to mitigate
    each of these factors is discussed separately in the following
    subsections.   The purpose of this breakdown was to separately portray
    potential approaches  to design that could be initiated as a form of
    mitigation.  During both the facilities planning stages, and in final
    design these concepts will undergo further scrutinizing and revision."

    "The suggestion has been brought forth that covering of the facilities
    would be beneficial.  There  is a perception that this plant could be
    buried, and that this would  afford substantial benefits by way of odor
    and noise control, enhanced  recreational opportunities, and visual
    relief.  Commentors have pointed out that other wastewater facilities
    are covered,  at least in part."

    "An examination of other reported facilities found that the covering
    of  facilities was commonly done for primary facilities only.  These
    facilities were typically covered for odor control.  Many of the
    covered plants have experienced high levels of maintenance and
    degradation of the structural integrity of the plant due to high
    moisture and hydrogen sulfide levels within the covered areas.  While
    the covering of primary basins for odor control may be necessary such
    covers should — based  on experiences at other facilities — be
    designed for protection against corrosion and should be easily
    removable for access  to conduct maintenance."

    "Other facilities cover aeration basins at installations with pure
    oxygen systems in order to capture and reuse (thereby decreasing
    operational costs) the  available oxygen.  At some locations, secondary
    clarifiers have been  covered (typically domed structures on circular
    clarifiers).   These plants are located in northern climates where
    adverse weather conditions may cause freezing."
                                                         Facilities  Layouts  -  5

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               "In summary,  the covering of unit operations at a facility is done
               based upon the need  to  increase the operational reliability of the
               plant.   However, the coverings are, however, an additional item that
               must be maintained and  at times have caused maintenance problems in
               other areas.   Such covers cannot be expected to result in either
               making the plant 'disappear' or in providing additional area for
               recreational  purposes.   The alternative to covering the unit processes
               is to attempt,  if possible, to locate facilities away from affected
               receptors.  Both Island sites are sufficiently large, each with an
               axis of at least 6,000  feet in length, to allow for relocation of
               components on site to a more mitigated location.*

               "For each site, two  layouts are presented, one with the institution
               and one without the  institution.  The existing conditions at the two
               sites have been defined in detail in the SDEIS.  Some generalization
               about the topographical land forms should be noted."

               "Deer Island  and Long Island are both dominated by drumlin land forms
               that rise approximately 100 feet off the water.  The drumlin at Deer
               Island occupies the  central third of the island and is flanked to
               either  side by rolling  terrain.  The drumlin at Long Island forms a
               broad high spine that runs the length of the island up to the neck of
               land that connects the  main portion of the island to Long Island
               Head.  The area occupied by the Deer Island drumlin is much less than
               the Long Island drumlin.  Consequently, plant layouts at Long Island
               are envisioned as being at a higher overall elevation than at Deer
               where it is presumed that the drumlin would be substantially altered.
               Aside from elevation differences, the shape of Deer Island is boxier
               than Long Island which  is longer and thinner.  This results in the
               Long Island layouts  being more linear, with appurtenant facilities
               located at either end of the Island.  The facilities at Deer Island
               are more compact, with  less distance between the outside edges of the
               plants."

               "At each of the two  Islands the drumlins present a contrast against
               the flat background  of  the ocean horizon.  Removal of the drumlins
               will be a decrease in aesthetic quality."

               "The need to  remove, lower or alter the drumlins is governed by the
               hydraulic profiles of the proposed plants.  At Deer Island the plant
               will be most  likely  constructed at or near the elevation of the
               existing primary basins which are located approximately 20 feet above
               sea level.  Each of  the next two unit processes will be constructed at
               a slightly lower elevation than the preceding unit process.  This will
               allow the plant to flow by gravity, except for storm tide situations
               at which time the outfall pump station would be utilized.  This
               results in a  flat, sea  level plant at the Deer Island site.  With the
               prison this means that  the drumlin material will have to be disposed
               of off  site as there is insufficient land available to save the
               material on site.  Also, the layout without the prison requires that
               the drumlin be cut down.  However, a buffer strip can be maintained
Facilities Layouts - 6

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around the plant with a minimum width  of  200  feet.   It would be
possible to move major portions of  the drumlin  material  into this
buffer area to create an esker-like mound varying in height from 40 to
60 feet to provide both visual  screening  and  landscape qualities."

"At Long Island the fact that the bulk of the Island is  a drumlin
rising out of the Harbor makes  it impractical,  from  an engineering
cost perspective, to reduce the drumlin in its  entirely  in order to
provide a sea level site.  This means  that the  primary will require a
greater amount of influent  pumping  than that  required at Deer because
they will be located at an  elevated position  above sea level.  This is
offset by the availability  of sufficient  hydraulic head  to eliminate
the need for an effluent pumping station  under  the secondary plant
options.  The drumlin at Long Island will have  to be lowered or
terraced to provide both a  level site  on  which  to construct the plant
and to avoid the operational costs  of  pumping above  the  elevation
necessary to ensure gravity flow through  the  outfall under all
conditions.  The amount of  drumlin  lowering will be  between 20 to 50
feet.  With the hospital on Long Island,  the  amount  of drumlin
lowering would require that a retaining wall  be constructed to hold up
the hospital grounds.  Without  the  hospital,  the drumlin lowering
would likely be accompanied by  a filling  in and raising  of the parade
ground area.  This would eliminate  the need for off  island disposal of
surplus material.  Because  of the long thin shape of the island it is
not possible to buffer and  hide the facility.  Visual mitigation would
require the application of  architectural  detailing to the basins.  One
possibility would be to utilize the sloping characteristic in either
direction to create a terrace effect.   For the  layout without the
hospital, the plant components  have been  divided in  half with the
primaries located in the middle to  create this  terraced  effect."

"At each site the height and scale  of  the buildings  will require
masking for visual acceptability.   The routine  practice  of relying
upon plantings will need to be  supplemented by  architectural consider-
ations in the building facades  themselves."

"If the institutions remain at  either  site, the possibility of
providing meaningful recreational resources at  either site will be
minimal.  At most, a limited shore  line buffer  zone  would be preserved
and even then portions of the shore line  would  require alteration with
a breakwater or dike type structure to protect  low lying portions of
the facilities from storm damages.'

"The possibility of limited recreational  development exists without
the institutions.  At Deer  Island without the prison, a  walking path
may be possible along the buffer mound.  The  vicinity of Shirley Gut
area would be available to  provide  an  extension to Yirrell Beach,
offering enhanced local recreational opportunities.  At  Long Island
without the hospital, the head  end  with its forts could  be preserved
intact.  At the opposite end of the island the  upland area between the
barrier beaches and marshland could be preserved."
                                                   Facilities Layouts - 7

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             "The more land available the greater the flexibility in constructing a
             facility which responds to mitigation (i.e. of esthetic, recreational
             and cultural resource impacts).  The constraints imposed upon either
             site by the inclusion of institutional facilities does not preclude
             the siting of a plant.  However, the elimination of the institutional
             facilities from either site is preferable."
Facilities Layouts - 8

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	II-1O
hist oric/archcological

-------
11-10  HISTORICAL AND ARCHAEOLOGICAL

    A.  Background

        The comments on the  SDEIS  on  historical and archeological issues which
        required further investigations center on the following question:

            Did the SDEIS overstate the historical and archeological value of
            Long Island and  underestimate the historic and archeological
            resources of Deer  Island?

        In order to respond  to this issue,  it was important to review previous
        studies and investigations of historic and archeological resources for
        both islands.  The scope of the SDEIS investigation was designed to
        build upon previous  studies to ensure that the areas proposed for
        construction of wastewater treatment facilities had been adequately
        evaluated.

        In June and June 1984,  EPA's  consultant Public Archeology Laboratory,
        Inc.,  conducted an intensive  level  archeological survey on sections of
        Deer and Long Islands.  Two project areas ranging from 60 acres on
        Deer Island to between 20  and 115 acres on Long Island were stratified
        into zones of expected archeological sensitivity on the basis of a
        literature search and  walkover survey.

        Survey efforts on Long Island were  coordinated with the University of
        Massachusetts,  Boston  field school  in archeology.  The University of
        Massachusetts field  school had surveyed the Southern end of Long
        Island in summer of  1984.  The combined efforts of the Phase I survey
        conducted by PAL,  Inc., and the UMass Boston field school concluded
        that Long Island is  considered to be a significant complex of
        prehistoric and historic period cultural resource much of which may be
        eligible for inclusion in  the National Register.

        On Deer Island, it was determined that the area covering the central
        drumlin had not been previously investigated.  Earlier surveys of Deer
        Island were conducted  by the  Institute of Conservation Archeology and
        covered a small area on the southern tip of Deer Island and the site
        of the existing treatment  plant.  Other areas of the island exclusive
        of the prison site were judged to have been previously disturbed from
        construction activity  and  therefore did not warrant further
        investigations.

        The conclusions of the Deer Island  survey were that no potential
        significant prehistoric or historic period cultural resources were
        identified on Deer Island. However, the consultants did recommend
        further examination  of the pump station/screening plant to determine
        its resent condition and structural integrity.  Since the pump house
        is associated with the earlie-r operation of sewerage handling and
        disposal.  For the Boston  Metropolitan area, it could meet the
        criteria for eligibility to the National Register of Historic places.
                                                                     Historical -  1

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               The SDEIS analyses on historic and archeological  inputs  presented on  a
               comparable level the information needed by the  grantee and  EPA  in
               order to state a preference and selection of  a  siting alternative for
               the FEIS, on July 10, 1985, the MWRA in their vote  to select  Deer
               Island as the preferred alternative also voted  to remove other
               institutions such as the prison or as a mitigation  proposal.  Earlier
               planning proposals assumed that adequate land area  existed  on Deer
               Island to construct a waste water treatment plant adjacent  to the Deer
               Island House of Correction.  As a result previous archeological
               investigation of Deer Island did not include  Prison Property.

               With the MWRA vote to relocate the prison off of  Deer Island  and
               utilize the site for the treatment plant, it  was  appropriate  for
               additional investigations of the prison site  and  the pump house to be
               undertaken.

               In September 1985, the MWRA commissioned Camp,  Dresser,  McKee,  Inc.,
               to conduct historical surveys and archaeological  investigations the
               areas of Deer Island in and around the Deer Island  House of
               Correction.  The research and walkover inspection uncovered a small
               cemetery plot on the north west edge of the project area considered to
               be archaeologically sensitive.  The exact horizontal limits of  the
               .cemetery are unknown and will require additional  Phase II
               archeological investigations.

               With regards to the Deer Island Hous.e of Correction and  Pump  Station
               building complex the survey concludes that both are probably  eligible
               for listing on the National Register of Historic  Places.  Excerpts
               from those surveys and investigations follow  this section.,  The full
               survey, report, including photos, appears as  part of the FEIR.

               The MWRA is continuing to collect additional  information at the
               request of Massachusetts Historical Commission  to determine support of
               the eligibility of the prison complex to the  National Register  of
               Historic Places.  The MWRA will, during the facility planning phase,
               include evaluations on the preservation or reuse  of the  eligible
               sites.  EPA will forward to the Keeper of the National Register
               nomination papers for these sites upon review and approval  of the
               Massachusetts Historical Commission.  A preliminary case report and
               memorandum of agreement will prepare for those  sites where  a
               determination of an adverse effect on a National  REgister property is
               proposed.

               The significance of a property being placed on  the  National Register
               of Historic Places is that it is offered protection by the  National
               Historic Preservation Act, Section 106 of Act outlines the  review
               process that federal agencies must adhere to  before taking  actions
               that might affect the property.
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                              MANAGEMENT SUMMARY
          An Archaeological Reconnaissance Survey of the Deer Island
               Corrections  Facilities, Deer  Island,  Massachusetts

                                Alan Leveilee
                                Marsha  K.  King
                                Duncan  Ritchie

                                Prepared  for:

                          Camp Dresser  & McKee,  Inc.
                               One Center  Plaza
                         Boston,  Massachusetts  02108

                                 Prepared  by:

                   The Public Archaeology Laboratory, Inc.
                              217 Angell  Street
                       Providence, Rhode  Island   02906

                              September  30,  1985

Introduction

As part of a program to upgrade  sewage  treatment facilities and reduce
pollution in Boston Harbor, the  Massachusetts  Water  Resources Agency (MWRA)  is
currently planning for the relocation and  construction of wastewater treatment
facilities on Deer Island,  in Boston  Harbor.

Previously, two archaeological investigations  had taken  place on the island.
In 1981, Harvard University's Institute  for  Conservation Archaeology tested
the existing treatment plant area  and the  island's southern tip (Randall
1581).  In 1984, the Public Archaeology  Laboratory,  Inc., conducted testing  in
the elevated central section which contained an  earlier  treatment  plant and
remnants of a former military installation.  Fort Dawes (Ritchie and Gallagher
1984).  While no prehistoric or  historic archaeological  deposits were
identified by these studies, the former  pump station and the screening plant
on the island's southern  shore were considered to be potentially significant
standing structures because of their  role  in the early development of Boston's
wastewater treatment facilities.

In September, 1985, the firm of  Camp  Dresser and McKee,  Inc., contracted with
the Public Archaeology Laboratory,  Inc., to  conduct  an archaeological
reconnaissance study in and around the  area  of the Deer  Island Correctional
Facility, in the island's northern sections.  No archaeological investigations
had been conducted in the northern island  area prior to  this study.
                                                                Historical" - 3

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       Research Goals and Strategies

       The goal of an archaeological reconnaissance study is to identify areas of
       actual or potential archaeological sensitivity;  that is to say to locate areas
       that may contain prehistoric or historic cultural deposits.  To operationalize
       the objectives of such a study several lines of  investigation are utilized,
       each with their own methodologies and results.   This memo will summarize the
       activities which took place during investigations of the Deer Island
       correctional Facilities area and will conclude with recommendations based upon
       the results of those activities.

       Walkover Reconnaissance

       A walkover of the correctional facilities area was conducted in order to
       assess the degree to which modifications to the  landscape had taken place.
       This aspect of the investigation included visual inspection of surfaces
       throughout the project area as well as subsurface probes to document soil
       profiles.

       Across the facility transects were walked to facilitate mapping.   Along these
       transects investigators paces a distance of approximately 20 meters to a
       •station."  Here notes on disturbances or surface modifications were made and
       when possible a soil core was taken and the profiles recorded.  Correctional
       officers Anthony Leggiero and Al Kane were interviewed.  They provided
       information on recent modifications to the correctional facilities buildings
       and grounds.

       Figure 1 represents the results of the walkover  survey.  Essentially, the
       project area can be subdivided into a three-layered hierarchy of
       archaeological potential.  Areas I and II would  include those areas that are
       comprised of fill and previously disturbed soils respectively.  These two area
       types constitute low sensitivity sections where  modifications would have
       severely impacted archaeological deposits.   Areas in the third category, with
       intact soil horizons, represent those sections within the facility where
       archaeological deposits would have been less impacted by recent landscape
       modifications.

       Within areas of intact soil horizons noted on Figure 1, no evidence of
       prehistoric or historic cultural deposits was encountered.   Across the
       correctional facility we found evidence of a range of modifications resulting
       from landscaping impacts including building construction,  water and utility
       line easements,  filling,  stripping,  and resurfacing.   Any cultural deposits
       which may have exited prior to these activities  would have suffered impacts
       when they occurred.

       The existence of a narrow,  rectangular cemetery  — similar in configuration to
       a  plot indicated on  topographic maps of the island — wf>s  verified during the
       walkover inspection.   This  cemetery  plot  has not been impacted by recent
       development and  it is presumed that  the burial area  itself  is intact.   The
       remains of a wooden  fence that originally defined this  plot  were  also found
       during the walkover  inspection.   The open hillside immediately to the
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  northwest of the cemetery has had the  loam  topsoil (A zone) removed, exposing
  the  underlying subsoil.  It is not clear  when  this soil stripping occurred,
  but  it  appears to have taken place within the  last ten years.  It is possible
  that this hillside could contain additional  unmarked graves since
  documentation of former cemetery areas  on Deer Island appears to be minimal.
  No obvious evidence of unmarked graves  or a  defined cemetery plot was  found
  during  the walkover inspection, however,  this  entire hillside should be
  considered to be an archaeologically sensitive area.  At the base of the  hill,
  approximately 50 meters south of the former  piggery (now the K-9 Training
  Facility), is a small stone mausoleum  inscribed with the date 1908.  This also
  suggests  that the open hillside it could  have  functioned as an unmarked
  cemetery  area for prison inmates and transients.   Limited soil auger probes
  taken  in  proximity to this cemetery area, illustrated in the northwest edge of
  the  project area on Figure 1, indicate  intact  profiles.
if! FiTi Arc" *ith '='"1 sail horizons
'Ml' that could be .rchacolugically sensitive
o.
(    /  Previously CislurbcJ ar^i
 'tr*. V Previously fillcJ
t     7
* v  >
 Figure 1
                                                                   Historical  -  5

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       Historical Background

       Deer Island was heavily forested with a large mobile deer population when the
       land was granted to Boston in 1634.  Two years later, the island's forests
       were opened for wood cutting to residents of Boston.  Within ten years, enough
       trees had been removed for the town council to restrict the cutting of wood to
       island residents in 1647 (Sweetser 1881:  194; Snow 1971:  199).  By 1655,
       "only enough for a farm remained"  (Drake 1856:  342).  Besides providing wood
       for Boston, Deer Island served as a pound for stray goats and swine.  John
       Ruggle built a pen to provide shelter for the strays in 1641 (Shurtleff 1871:
       466).

       From the mid 1640's, and for the next two hundred years, the Boston town
       fathers rented Deer Island lands to a series of individuals.  Proceeds from
       these leases went to support Boston schools.  During much of this period of
       the islands' history, Deer Island appears to have been used primarily as
       farmland, focussing on pasturage and grazing lands for cattle, sheep, and
       other livestock (Sweetser 1882:  1984; Snow 1971:  199-200).

       During King Philip's War, Deer Island served first as a concentration camp for
       Christian or Praying Town Indians.  The English settlers feared that these
       natives might take up arms along side Philip's hostiles, so they rounded them
       up from their towns and removed them to Deer Island.  Some five hundred men,
       women and children were left on the island without adequate shelter,
       provisions, or boats during the winter of 1675.  Many of them died.  At the
       close of the hostilities the survivors were allowed to leave the island, only
       to be replaced by native prisoners of war who were then interned there.  These
       captives were kept on the island until they could be sent away or sold into
       servitude (Sweetser 1881:  195).

       A native claim was made to Deer Island in 1685 by Wampatuck, also known as
       Charles Josias.  Citizens of Boston paid nineteen pounds to buy the island
       from Wampatuck (Snow 1971:  200-201).

       As early as 1677 Deer Island was suggested as a quarantine station for the
       crews and passengers of ships infected with small pox (Snow 1971:  201).  No
       more action was made on the idea until 1717 when the Boston town council voted
       to lease a small parcel on the island for the erection of a 'Hospital or Rest
       House for the reception and entertainment of sick persons coming from beyond
       the Sea."  This time the concept was carried out, but the pest house appears
       to have been built on Spectacle Island instead (Snow 1971:  202).

       Deer Island was the site of two Revolutionary War incidents.  In 1775 Major
       Greaton lead his Continental soldiers on a foray to the island where they took
       some 800 sheep and horses, and a barge to transport them off the island, from
       under the noses of the British (Sweetser 1881:  196).  The following year two
       Continental privateers, the Franklin and the Lady Washington, were sneaking
       out of Boston harbor through Shirley Gut with the Lady Washington became
       grounded.  The ships were attacked by the British, but were able to escape
       when the British retreated and the grounded vessel floated free with the tide
       (Sweetser 1881:  124).   During the war,  minor fortifications were constructed
       on Signal Hill overlooking the harbor and Shirley Gut.
Historical - 6

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A resort hotel was operated on Deer Island from the 1780's into the mid
1800's.  William Tewksbury, the proprietor of the hotel, was locally known for
his many rescues of seamen and passengers from sinking vessels in the harbor.
The resort, which provided accommodations, a dance hall, lawn bowling, swings,
and a beach was popular with families and outing groups  from Boston (Snow
1971:  203).

In 1821, Deer Island was again considered as a location  for a public
institution.  This time, the "Committee on the Subject of Pauperism and the
Expediency of Erecting a House of Industry in the Town of Boston" concluded
that the island "was not a proper site [sic] for the location of the proposed
establishment" (Boston, Comm. on Pauperism 1821:  13).

It was not until 1847 that the first city institution was actually moved to
the island.  In that year, the "Committee on Alien Passengers" constructed a
temporary Quarantine Station on Deer Island for the many Irish immigrants
arriving with ship fever.  More than 10,000 Irish landed in Boston between
•January and July of 1847, and by the end of the year hundreds had been buried
in unmarked graves on the island (Sweetser 1882:  197).  During the same year,
a Boston "Committee on Public Buildings" reported "that  the new House of
Industry should be erected on Deer Island" (Boston, Comm. on Public Buildings
1847:  19).

In 1848, the first inmates from the crowded South Boston House of Industry
were transferred to Deer Island.  The following year saw the quarantine
station made permanent.  Plans for a new Almshouse were  drawn up in 1848 and
the structure was completed by 1852.  That year the first of the city's
paupers were removed to Deer Island (Snow 1971:  207).

The Deer Island Almshouse became the House of Industry in 1854 with the poor
sent to Rainsford Island (Snow 1971:  207).  Four years  later Deer Island
became the location of the House of Reformation and Almshouse School Housing
some 160 boys under the management of the Boston Board of Directors for Public
Institutions (Shurtleff 1871:  470).  For the next forty one years the island
housed a changing combination of paupers, neglected children, and boys in the
reformatory.  The institutions formed a self-sufficient  community with some
1,200 to 1,500 men, women, and children working at the various trades
necessary to provide the food, clothing, and supplies needed for the support
of the institution (Sweetser 1882:  198).

The "House for the Employment and REformation of Juvenile Offenders" was
removed to Rainsford's Island in 1895 (Snow 1971:  156)  and the following year
the Suffolk County House of Correction moved into the Deer Island facilities
(Snow 1971:  208).  By 1905, it had become the largest prison in Massachusetts.

The first sewerage facilities were built on the island in 1894.  The Deer
Island Pumping Station consisted of a single-story brick station, housing two
Corliss-type steam engines and a third different engine, together with a house
for the Superintendent.  The facility was completely renovated and modernized
in 1968 when the present sewerage treatment plant was built (Ritchie and
Gallagher 1984:  40).
                                                                      Historical  -  7

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       Recommendations

       In summary,  the results of background research and a walkover inspection
       indicate that the Deer Island project area (+^00 acres)  consists mostly of
       modified land surfaces that have been the site of numerous construction and
       demolition episodes (ca. 1850 — present).  Some areas on the northern end of
       the prison complex remained open, but have been altered  by many sources of
       previous disturbance such as grading/landscaping, filling, and installation of
       utility lines and easements.  Cultural resources may have survived in the area
       as small remnants, however, due to the extent of previous disturbances, it is
       not likely that they would have retained sufficient integrity to meet normal
       standards of significance.

       The small cemetery plot on the northwest edge of the project area and the open
       hillside surrounding it are considered to be archaeologically sensitive.  From
       current plans of the proposed treatment plant, it is clear that the cemetery
       area will be impacted by this development.  The exact horizontal limits of the
       cemetery area are unknown at present and additional archaeological
       investigations will probably be necessary to verify the  actual extent of this
       sensitive cultural resource.
Historical - 8

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                                  REFERENCES

Boston, Committee on Pauperism
     1821 Report on the Committee on the Subject of Pauperism and the
          Expediency of Erecting a House of Industry in the Town of Boston.
          Boston.

Boston, Committee on Public Buildings
     1847 Report on the Removal of the House of Industry and Other Public
          Institutions at South Boston to Deer Island.   J.H. Eastburn, Boston.

Drake,  Samuel G.
     1856 The History and Antiquities of Boston, From Its Settlement in 1630,
          to the Year 1770.  Luther Stevens.  Boston.

Randall, Debra
     1981 Archaeological Survey of the Proposed MDC Sludge Management Plant.
          Deer Island.  Massachusetts.  The Institute for Conservation
          Archaeology, Harvard University.   Submitted to MDC and Havens and
          Emerson, Inc. Boston.

Ritchie, Duncan and Joan Gallagher
     1984 An Intensive Level Archaeological Survey on Deer and Long Islands,
          Boston Harbor, Massachusetts.   The Public Archaeology Laboratory,
          Inc., Report No. 51-01.   Submitted to CE Maguire, Inc., Providence.

Shurtleff, Nathaniel
     1871 A Topographical and Historical Description of Boston.  A Williams
          and Company, Boston.

Snow, Edgar R.
     1971 The Islands of Boston Harbor, 1631-1971.  Dodd, Mead and Company,
          New York.

Sweetser, M.F.
     1882 King's Handbook of Boston Harbor.  Moses King, Cambridge,
          Massachusetts.
                                                                     Historical - 9

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Historical - 10

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              MEMORANDUM
            Historic Survey
of the Deer Island House of  Correction
  and  the  Deer  Island Pumping Station
      Deer Island, Massachusetts
             Stanley Moss
             David Amorena
         Pauline Chase-Harrell
             Prepared By:

       Boston Affiliates,  Inc.
           102 south Street
      Boston, Massachusetts 02111
            October  1, 1985
       Revised October 23,  1985
                                                 Historical - 11

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                         MEMO ON DEER ISLAND HOUSE OF CORRECTION
                          AND PUMPING STATION BUILDING COMPLEXES
      Summary of Significance

      Based on the  results of this study, we believe that both the House of
      Corrections complex and the Pumping Station are probably eligible for listing
      on the National REgister of Historic Places; the former based on its archi-
      tectural and  institutional history and the strong evidence it presents of the
      history of institutionalization throughout Boston's history, and the latter
      based on its  architecture and relationship to the development of the Boston
      Metropolitan  District Commission, one of the nation's earliest and most
      influential instances of regional planning for environmental management.  We
      recommend that a Determination of Eligibility be sought in both instances.
Historical  - 12

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Boston Affiliates, Inc., has conducted a historic study and  analysis  of the
Deer Island House of Correction and Deer Island Pumping Station as part of
the environmental study of the impact of the proposed sewage treatment plant
on the island.  The purpose of the study is to identify and  document  struc-
tures of historic interest and significance, and analyze the impacts  of the
proposed project.

Our approach in this study was to inspect and photograph the structures,  and
engage in documentary research on their history.  We collected  information
from the following sources:

Boston Public Library
Winthrop Public Library
State Archives
State Library
Bostonian Society
Society for the Preservation of New England antiquities
Metropolitan District Commission
City of Boston Department of Public facilities
Northeastern University

This memo was prepared in a short span of time to meet a time line of the
larger EIR/EIS project.  All information sources have not been  exhausted.   A
full report is being prepared to serve as an appendix to the Final EIR.
Deer Island House of Correction

History

Owned by the City of Boston since 1634,  Deer  Island  in  boston  Harbor  has
proved a useful place for purposes that  needed  some  site,  but  had  to  be set
apart from a populated area.   Its use has included the  detention of Indians
and the quarantine of contagious immigrants.

In 1850, the City sited a municipal Almshouse there,  which became  the first
in a complex of institutions  serving the poor,  the criminal and the delin-
quent.  The Almshouse was known as the House  of Industry;  other buildings,
such as a reformatory, and schools for pauper boys and  girls were  added in
the next three decades.  In the 1890s the whole complex started being used
for the detention of prisoners, and was  called  the House of Correction, the
name still used today.

The Deer Island group of institutions for many  years was self-sufficient,
providing its own food from animals and  farming.  Dairy barns  were built as
late as the 1950s, but farming has now ceased.   The  Island was accessible by
boat, and the Penal Institutions Department maintained  its own steamboat to
transport inmates between islands and the mainland.   In 1940 the Island was
connected to Shirley Point in winthrop by causeway.
                                                                     Historical  -  13

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       Deer Island  has  not  previously been surveyed for historical significance.
       Consequently,  none of  the  buildings is listed in official inventories or has
       been identified  as eligible.

       The main points  of historic  interest are the following:

       1.   Administration Building  (ca. 1850, 1929, 1949).

           This building incorporates major sections of the Deer Island Almshouse
           (also known  as the House of  Industry), designed by Gridley J.F. Bryant
           (1816-1899)  with the assistance of Louis Dwight of the Prison Discipline
           Society.   The original building of brick, in Italianate and vernacular
           style,  is  depicted in  a  lithograph shown as Figure 3.

           Fire damage  in 1929 and  1949 led to the removal of the roof and portions
           of the building.  Modern sections were added at the back.  The building
           as it -appears in 1985  is shown in Figure  5.

           Interior hallways  and  offices on the first floor have woodwork, match-
           board paneling,  and cast-iron columns which are apparently original.
           (Figure  16)  The  cell-block appears to date from the late nineteenth
           century, and is  probably the addition designed by City Architect Edmund
           Wheelwright  in 1892.

           The building is  now used as administrative offices, reception and cells
           for new  prisoners,  training and schoolrooms, and workshops.  The building
           appears  structurally sound but worn and neglected.

       2.   Hill Prison  (1902-04)  (Figures 22-23)

           This building appears  to be substantially unaltered.  It was built as a
           women's  prison,  but is now the main prison in the complex, occupied
           solely by  men.

           The architect was  A. Warren Gould, active in the 1890s in Boston, where
           he designed  a number of  houses and buildings in Dorchester, including
           Whiton Hall  for  the Dorchester Women's Club.  He moved to the Pacific
           Northwest  and died in  Seattle in 1922.

           The building is  T-shaped.  The two wings contain cell-blocks, the rear
           wing dining  and  recreational facilities.

           The building is  of loadbearing brick, 24 ins. at first floor level; the
           foundations  and  entrance facade are granite.  The floor construction is
           reinforced concrete, and brick vaults span the cell-block open areas.
           Interior supports  are  cast-iron columns and masonry.  The pitched roofs
           are covered  with slate.

           The style  of the building is classical revival.  The central section has
           a granite  facade in the  lower half, brick in the upper half.  In the
           granite  section, two projecting bays flank an arched entrance in Pal-
Historical - 14

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Figure- 3:  View  of  the New Alms House for  the  City of Boston
           on  Deer  Island, 1849
            (Print Department, Boston Public  Library)
                 i . i! i i in Bn i M i nt: ,  I 'IS''
                                                          Historical - 1

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           tetatft*
Histot i

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    ladian style,  above which is  a  recessed balcony set in a semicircular
    arch.  Above are a series of  vertical  brick pilasters between windows,
    topped by an entablature  and  surmounted by a hipped roof with clipped
    dormers and a prominent cupola.

    The two wings contain a series  of wide brick pilasters alternating with
    narrower barred windows arched  at their tops.  Since these windows give
    onto the open space of the cell-blocks, there are no floors behind them,
    and the windows are virtually continuous strips. .Above is a broad
    entablature.  The roof is pitched,  and has ventilators at the ridge,
    which were once open roof viewing platforms.  The end walls of the wings
    have the same pilaster and arched window motif of the front and rear
    elevations;  the windows are bricked up.

    The rear wing, also roofed with  a pitched slate roof, has a series of
    brick semicircular arches,  with  windows at each floor level.  In the
    uppermost floor — the recreation hall — the upper section of the window
    is blocked with plywood.   The end wall of this wing is the stage wall,
    and is solid brickwork.  The  outer  skin of this wall collapsed recently,
    and has been replaced.

    Inside the building, most of  the spaces are utilitarian.  There is some
    architectural  interest in the front entrance hall and in the recreation
    hall, which still retains original  woodwork in the doorways, stage and
    proscenium arch,  and balcony.

    The building appears to be structurally sound.  Inside all surfaces show
    signs of much  wear,  poor  maintenance,  makeshift repairs and careless
    painting.

3.   Superintendant's Office (1910s?) (Figure 35)

    This two-storey brick building,  situated opposite the Administration
    Building, was  once the Superintendant's residence.

    The style is Georgian Revival with  a central entrance topped by a
    segmental pediment.   The  windows are arranged in three bays on either
    side of the entrance with a window  above it; those on the lower floor are
    nine over nine paned sash,  and  on the  upper floor six over nine.  The
    slate roof has five dormers and  a chimney.  The rear of the house,
    overlooking the harbor, has french  doors leading onto a terrace.  At the
    north of the house is a one-storey  flat-roofed section in similar but
    plainer style.  It may have been added later.

    The house appears in sound structural  condition though inadequately
    maintained.

    No documentation for this building  has been found.
                                                                    Historical - 17

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            Figure 35:  Superintendent.' s Office,  1985
      l-'i pin-  .':   S i I
Historical - 18

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4.  Ancillary Buildings

    a.  Garage — 20th century.

    b.  Commissary — 20th century.   This  building was previously three and a
        half stories, reduced  to  a one-storey building in 1946.

    c.  Dormitories (former Dairy Barns) —  1957 and 1958.  Architect, Joseph
        F.  Page.

    d.  Shower Block — date written  on building is 1945.

    e.  Chapel — 1950s (?)

    f.  Power Plant — 1958.   Engineers, J.M. McKusker Assoc.

    g.  Dormitory and Laundry  (opposite Hill Prison) — 1869.  This building
        is  a remnant of the Pauper Boys' School, roof and top floors removed.

    h.  K-9 Quarters — 1980s.  On site of former piggery.

    i.  Work Release House —  1900s  (?)

    j.  Sheet Metal Shop — 20th  century.  Abandoned.

    k.  Residences — 1900s (?).  Three houses, previously occupied by prison
        officials.  One is now the engineer's house, one the work release
        office, one vacant.

    1.  Gymnasium — 1960s (?)

    m.  Staff Dining Hall — 1941.

5.  Site Layout (ca.  1850 to present)  (Figure 2)

    The Deer Island House of Correction consists of a grouping of major and
    ancillary buildings informally sited in an institutional yet rural
    setting.

    The buildings form two clusters.   Near the water's edge, the predominant
    building is the Administration Building, sited parallel to the main
    road.  Opposite is the Superintendent's Office, Gymnasium and Staff
    Dining  Hall.   Nearby is the Work  Release House, and further along the
    shore are three Residences.   Behind the Administration Building and
    parallel to it are the Garage and Commissary.

    Up on the hill the predominant structure is the Hill Prison, sited on a
    street  sometimes referred  to  as Hill Prison Street.  Across from the Hill
    Prison  is the Dormitory and Laundry.   Next to the Hill Prison are two
    Dormitories,  a Chapel, the Shower Room, and the Power House.  Below and
    across  a road is the Sheet Metal  Shop.   Behind the Hill Prison are the
    K-9 Quarters.
                                                                    Historical  -  19

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           The buildings are informally  set  on the site which has a character that
           is institutional, industrial  and  rural.   There  is a loop road that gives
           vehicular access to all  buildings.  It is paved, but without curbs in
           most places.   The largest expanse of paved area is between the Adminis-
           tration Building and the Garage and Commissary.  Stone retaining walls
           and foundation walls of  demolished buildings occur on the site.  Cyclone
           fencing and wooden telephone  poles are in evidence.  Trees, bushes and
           overgrowth of grass contribute to the rural character of the site.

       Significance

       The complex is historically  significant because of  its long history as an
       institutional complex accommodating a succession of uses related to social
       control.  Various reform movements devoted to the treatment of the poor,
       delinquent, and criminal have found physical  expression in the buildings on
       this site.  The succession of buildings and alterations also speaks to the
       continual attempt to recategorize individuals (as poor, delinquent, unwed,
       truant, criminal, etc.) and  to separate men from women, children from adults,
       and poor from deviant.

       The site today, with its many support buildings clustered around the Hill
       Prison and the Administration Building, still reflects the self-sufficient
       character, with farming complementing the institutional use and officials
       living on the site, which was for more than a century an important part of
       its institutional philosophy.  More research  remains to be done on the
       relationship of this philosophy and its physical expression here to national
       trends, but Massachusetts was a nineteenth-century  leader in these areas.

       It would appear that the complex  is eligible  for listing on the National
       Register of Historic Places, under categories A and C, for its significance
       in social/humanitarian, political, legal and  community planning, as well as
       architectural history.

       The oldest building on the site,  the  Deer Island Almshouse (House of In-
       dustry) still contains large fragments of the original building and is on its
       original site.  Its diminished integrity and  altered interiors convey little
       of its original use, although the exterior clearly  conveys its early ori-
       gins.  The cell-block, believed to date from  the 1890s, is an intact interior
       eloquent of its past and current  use.

       The Hill Prison is virtually unchanged since  it was built and has complete
       integrity in its  exterior and interiors.  It  has been used continuously as a
       prison with minor alterations reflecting changes in penal practice.

       Impact of Proposed Project

       Although there are no firm designs for the proposed sewage treatment plant,
       Camp Dresser and  McKee have  developed alternative conceptual schemes.

       One scheme retains the House of Correction, and locates the plant on the
       remainder of the  island.  This concept would  subject the environment of the
       correctional site to noise and smell.
Historical - 20

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The second scheme gives the entire  island  to  the treatment plant.   In this
alternative, the prison would be demolished entirely,  and the  historical
evidence of institution practices on  Deer  Island lost.

Recommendations

If the House of Correction is altered or demolished, an  intensive effort
should be made to record and document the  complex through photographing it,
assembling original drawings and records,  and preparing  a thorough  history.
If the complex is retained, sections  of historic interest should be identi-
fied so that further alterations and  changes  are carried out sensitively.  If
the complex is demolished,  consideration should be given to saving artifacts,
such as appurtenances of the cells  and cell-block, for display.
                                                                    Historical - 21

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       Deer Island Pumping Station (Figures  54,  56)

       History

       In 1889, legislation, prompted by reports of  the Massachusetts State Board of
       Heath on pollution of Boston Harbor,  authorized the  formation of the Boston
       Metropolitan Sewerage Commission.  By 1900, the North  Metropolitan Sewerage
       System, serving the 14 cities and towns of the Commission's northern region,
       was fully operational.

       The North Metropolitan system's 74 miles  of sewer  lines  connected nearly
       1,000 miles of local lines and pumped to  an outlet in  Boston Harbor at Deer
       Island.  The Pumping Station at Deer  Island was the  largest of three stations
       constructed to pump sewage through the North  Metropolitan  system.  Con-
       structed in phases in the period from 1894 to 1900,  the  Deer Island Pumping
       Station's development reflected the growing needs  of the region's burgeoning
       population.

       Site Plan

       The Pumping Station at Deer Island lies on the southwesterly side of the
       island about midway down its length.   Actually a complex of five attached
       buildings, the development of the station reflects the development of the
       North metropolitan Sewage System which it served.  Completed in three phases
       between 1984 and 1899, the complex contains a Screen House, Coal House,
       Boiler Room and two Engine Rooms.  The buildings give  the  appearance of a
       single structure, designed in a compatible manner  by Arthur F. Gray, archi-
       tect for the Stations at Charlestown  and  East Boston.  Though operated in the
       periods between construction, it became fully operational  in May of 1900.
       The Station was in operation until 1968 when  the Deer  Island Sewage Treatment
       Plant was completed.  The building, still containing the old machinery, is
       now abandoned.  To the southeast of the pumping station  complex is a
       two-storey shingle structure of unknown origin or  use  but  which will be
       referred to as the Farmhouse.

       Facing the westerly elevation, the Pumping Station buildings are, from left
       to right:

           Screen House (ca 1895)

           A two-storey brick, granite and terra cotta structure  27' x 23'.  Built
           in a simple vernacular industrial style with Queen Anne — Romanesque
           elaborations and detailing, it has a  hipped roof of  slate with terra
           cotta tile coping and is surmounted by a  cupola, now only partially
           extant.

           The building covers the screen shaft  of the pumping  station system and
           contains machinery for hoisting and pressing.  Sewage  was screened with
           double rows of wrought iron bar cage  screens before  it was put through
           the pumping machinery.  The Screen House  and the adjacent Coal Pocket
           were constructed after the Boiler Room and the first Engine Room.
Historical  - 22

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       ,?—	  -•-•"
St.al \:>li.  i. H
                                                    Historical  - 23

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           Coal  Pocket  (ca 1895)

           A  one-storey brick, granite and terra cotta building 74' x 34' with a
           dynamo  room  attached.  Styled similarly to the Screen House, it also has
           a  slate pitched roof punctuated by dormer-type openings and terra cotta
           tile  coping.

           The engines  for the pumping station were powered by coal burned in the
           boiler  room  until the facility was converted to diesel fuel in the
           1950s.   The  Coal Pocket was designed to hold 600 tons of coal.

           Boiler  Room  and Chimney (September 1894)

           A  one-storey brick, granite and terra cotta structure, 63' x 35" with a
           height  of  17'  to the roof trusses and an accompanying masonry chimney
           125'  in height.  Styled in a vernacular Romanesque with Queen Anne
           details, slate pitched roof with terra cotta tile coping and topped with
           a  ventilation structure (Figure 59).  Converted from coal to diesel in
           the 1950s, the boilers still remain intact (Figure 60).  The boiler room
           and the first engine room were the initial structures built for the
           pumping station, which shares its pattern of boiler room-engine room with
           the stations at East Boston and Charlestown.

           Engine  Room  (first) (September 1894)

           A  one-storey brick, granite and terra cotta structure, 100' x 31 1/2',
           with  a  height of 15' to the roof trusses.  Styled in a vernacular
           Romanesque with Queen Anne detailing, it also has a pitched slate roof
           punctuated by dormer-type openings and with terra cotta tile coping.
           Similar to the stations at East Boston and Charlestown, it was originally
           equipped with two triple-expansion Corliss type steam engines.

           Engine  Room  (second) (ca. 1899)

           A  two-storey brick structure approximately 50' x 50' with a hipped slate
           roof.   Built in a more formal style with Romanesque details of
           round-headed arches, brick patterns to create circles, and horizontal
           lines denoting function.

           Because of a need for increased system capacity, an extra pump and engine
           were  added to the Deer Island Pumping Station and housed in this struc-
           ture.   The machinery is still extant.

           Farmhouse  (ca. 1900)

           Approximately 300 feet to the southeast of the Pumping Station stands a
           two-storey wood and shingle Queen Anne and Colonial Revival structure
           believed to  have been a farmhouse.  No information about its construction
           or  design  has been found to date.  Little is known about its structural
           integrity.
Historical - 24

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Significance

The Deer Island Pumping Station and related  structures  (Farmhouse and now
demolished Employee Dwelling)  were  constructed  during the great  institutional
expansion which occurred in Boston  at the turn  of  the century.   The struc-
tures together form a complex  which is expressive  of the "Picturesque"
movement in architecture.  This movement,  and the  design of  the  pumping
station complex, reveals "the  deep  new need  of  the time in an increasingly
industrial and ugly age to dream romantically of a picturesque past."  The
complex is an expression not only of an architectural ideal, but of the
perceived responsibility of a  regional authority,  the pride  in the accom-
plishment of that authority and as  a fine  example  of the contemporary
technology and the changes in  that  technology at the turn of the century.

The significance of the Pumping Station complex can be outline in three areas:

    Cultural/Historical

    The complex is the largest pumping station  of  the area's first regional
    system.   It was built in an era of strong individualism, and represents
    and important cooperation  among many communities to address  a problem
    which had been growing since the 1700s.  The accumulation of structures
    is representative of the rapid  suburban  growth which characterized this
    period,  and which the station served.  Further, it represents a continu-
    ation of the use by the Boston  region  of Deer  Island as  a "dumping
    ground"  for the region's various social  and physical ills.

    Architectural

    The Deer Island Pumping Station and its  related structures form a
    coherent grouping of institutional buildings representing the powerful
    influence of the picturesque on institutional  architecture of its time.
    Usually  found in the structures of contemporary park development, the
    complex  at Deer Island is  a sensitive  blend of structures with a natural
    setting.  This spirit contrasts with the trend to build monuments to the
    civic ego which soon followed.   The complex is an intriguing example of
    vernacular adaptations of  popular styles to express a certain whimsy in
    the design of a structure  built to house a  then particularly "offensive"
    operation.  The workings of the station  are directly represented in the
    differentiation of the parts of the structure. The careful  additions to
    the original boiler-engine room station  display the increasing demands
    placed upon the facility by the northern metropolitan region.  Even the
    more monumental styling o.f the  second  engine house reflects  the larger
    size of  the added engine and pump.  Additionally, the architecture of the
    station  shares stylistic similarities  with  the suburban  architecture in
    the communities directly served by the system.

    Technological/Industrial

    The Pumping Station is a nearly intact representation of the period
    technology, and one of the earliest and  best designed sewer  systems of
                                                                    Historical  -  25

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           its time.   Aside from its  quality as  an  industrial artifact, it expresses
           an incomplete attempt by contemporary technology to solve an increasingly
           dangerous  problem — the unsanitary handling of sewage in congested
           areas, closely linked to urban epidemics — only to create another which
           endures to this day:  the  pollution of Boston  Harbor.

       Based on the above evaluation,  it would appear that the Deer Island Pumping
       Station is eligible for listing on the National Register of Historic Places
       under category C, for its significance in community planning, engineering,
       politics/government and architecture.

       Impact of Proposed Project

       The development of a new sewage treatment plant on Deer Island will poten-
       tially affect  the Pumping Station complex either by altering the setting or
       altering the structure.  The largely natural setting of the pumping station
       is strongly related to the historical and architectural significance of the
       structures.  The design of the structures and the  use of the natural setting
       is heavily influenced by the "Picturesque" movement of the period.  This
       relationship,  a harmonious blend of site  and structure remains largely intact
       despite 85 years of use.  Changes to the  setting will have an impact on the
       architectural  and cultural/historical significance of a magnitude  related
       directly to the degree of alteration.  Alterations to the structures them-
       selves will have an impact on  significance corresponding to the extent of the
       alteration.  The Pumping Station and Farmhouse have been untouched since
       their abandonment and machinery, boilers, pumping  wells and pipes  remain in
       the pumping station.  The Farmhouse interior has not been examined. ..

       Recommendations for Reuse

       With any degree of alteration  or demolition, the Pumping Station and Farm-
       house should be thoroughly documented and photographed beforehand.

       Reuse adaptations should take  advantage of the characteristics of  the site.
       Proximity to the new sewage treatment plant  suggests the reuse of  the
       structures for administrative  of maintenance functions.  The possibility of
       reuse as a facility for sewage treatment  related functions will preserve much
       of their significance as industrial architecture.
Historical  - 26

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   11-11
disinfection

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11-11.  CHLORINE USE RISK EVALUATION

A.   Background

     Public comment on the SDEIS raised  two questions on the continued use of
     chlorine as a wastewater disinfectant:

     1.  Does the continued storage and  use of chlorine at Deer Island pose a
         risk to public health and safety, and if so, to what extent?

     2.  What are the implications of any risk from the use of chlorine for
         siting of the proposed  wastewater treatment facility at Long Island
         as opposed to Deer Island, i.e., is one site inherently "safer" than
         the other?

         This report addresses the first question through a brief safety
         evaluation of chlorine  use at sewage treatment plants, derived from a
         limited database on chemical spills, and through the results of a
         generalized hazard assessment based on a mathematical model of gas
         cloud dispersion.  The  second question is addressed through a
         comparison both of wind directions and of distances to residential
         areas at Deer Island and Long Island, and through a qualitative
         assessment of the implications  of wind frequencies and gas cloud
         dilution for public safety.

B.   Safety Evaluation

     Chlorine is widely used as  the wastewater disinfectant of choice at most
     sewage treatment plants. It is usually shipped and stored as a
     pressurized liquid, but if  spilled  it readily vaporizes at normal
     atmospheric pressures and temperatures.  The resulting chlorine gas is
     toxic; it can irritate mucous membranes, the respiratory system, and skin
     at concentrations in the range of 5-15 ppm by volume, and can be lethal
     if inhaled for 30 to 60 minutes at  concentrations as low as 40-60 ppm.
     Lethal concentrations for acute exposure (i.e., exposure times on the
     order of a minute or less)  are roughly an order of magnitude greater, in
     the range of 800-1,000 ppm. (Underhill, 1920; NRC, 1976; Sconce, 	
     ).  At particular risk are  individuals with a history of asthma, in whom
     chlorine gas has been observed to cause severe asthma attacks in
     concentrations of 4-6 ppm.  {NRC, 1976).

     Chlorine gas is more dense  than air (density 2.5 relative to air) and can
     thus be expected, in the event of an accidental release, to persist in
     hazardous concentrations at or near ground level, where the potential for
     human exposure is high, for periods up to an hour or more under a
     worst-case scenario.  The risk of an accidental spill during the
     transport of liquid chlorine by tank truck, or during its storage and
     handling at a sewage treatment plant, should therefore be considered a
     threat to the health and safety of  treatment plant staff and local
     residents.  Such accidents, while rare, have occurred.
                                                                     Chlorine - 1

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           EPA  is currently compiling data for a planned database on chemical
           spills.    This  database is rather limited, having been compiled from
           data from  only  four states (Ohio, Texas, New Jersey, and California),
           several  news  wire  services, and a national emergency hotline.  Of some
           3,100 events  in the database, approximately 300 involved releases of
           chlorine during the period from 1981 to 1985, making it one of the most
           frequently spilled of the chemicals for which data are available.  Of
           those 300  spills,  nine have been identified which, judging solely from
           company  names,  may have occurred at sewage treatment facilities.  Several
           of these were listed as resulting from "equipment failure," and one, a
           150-pound  chlorine gas release at the Monticello, Iowa, sewage treatment
           facility,  was specifically listed as the result of a leaking chlorine
           cylinder in a storage area.

           The  nine possible  sewage treatment plant releases ranged in size (where
           indicated)  from 25 pounds to 1,500 pounds; five resulted in injuries.  Of
           these five, the most harmful was a combined chlorine and methane release
           in Chippewa Township, Pennsylvania, in July of 1983, which resulted in
           nine injuries and  caused a fire and explosion which destroyed the plant,
           releasing  raw sewage to a nearby stream.  A chlorine gas release in
           Knoxville,  Tennessee, resulting from a chemical reaction between ferric
           chloride (a metal  plating waste) and sodium hypochlorite in April of
           1983, caused  four  injuries and necessitated the evacuation of 300
           students.

           Figures  provided by the Transportation Systems Center in Cambridge,
           Massachusetts,  also indicate a need for concern over the safety of
           chlorine in transportation.  During the period from January, 1983, to
           March, 1985,  the number of chlorine releases per month in the
           transportation  system (which includes intra-warehouse transfers as well
           as trucking)  ranged from four to sixteen and averaged eight or nine;
           i.e., over the  last two years there were an average of roughly 100
           chlorine releases  per year in the transportation system alone.  On-site
           storage  in tank trucks has also proven hazardous in at least one
           instance:   in December of 1981, 20,000 pounds of chlorine leaked from a
           truck parked  at a  chemical plant in Fraser, Michigan.  Although no one
           was  injured,  6,000 local residents had to be evacuated.

      C.    Modeling and  Analysis of Potential Chlorine Hazard

           In light of these  figures, and in light of questions raised by local
           public safety officials, it would be prudent to assess the severity of
           the  expected  hazard from a potential accidental chlorine release at
           either Deer Island or Long Island.  It should be noted here that the
           following  hazard assessment implicitly assumes a release of chlorine gas
           to the atmosphere.  Safety procedures currently in effect at most sewage
           treatment  plants,  including the existing Deer Island facility are
           designed to prevent such a release.  These safety procedures include
           off-loading and storage of chlorine in separate, fully enclosed buildings
           equipped with chlorine gas sensors.  However, as the preceding safety
           evaluation indicates, such procedures have proven less than foolproof in
Chlorine - 2

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the past.  Mathematical modeling of the atmospheric dispersion of
pollutants and gases is thus a useful tool  in assessing  the potential
hazard associated with the continued use of chlorine.  A search of  recent
scientific literature revealed that only a  small  fraction of  the work  in
mathematical modeling of pollutant  dispersal is applicable to the special
case of dense gases such as chlorine.  Furthermore, the  few dense gas
dispersion models which do exist represent  attempts to describe the
movement of specific clouds of known dimensions under carefully
controlled and thoroughly documented experimental conditions  (e.g.,
Picknett, 1981).  Consequently,  these models tend to be  of rather limited
applicability and require more detailed knowledge of site-specific
meteorological conditions and case-specific cloud characteristics than
are generally available for accidental hazardous gas releases.  A more
generalized model is needed to quickly and  efficiently estimate downwind
concentrations and assess public hazards at distances on the  order  of
kilometers from the release point for a wide range of cloud sizes and
meteorological conditions.  One  such model  was developed by William B.
Petersen at the EPA Environmental Sciences  Research Laboratory (Petersen,
1982).

Petersen1s model provides a set  of  equations for calculating  peak
concentrations and average concentrations up to 100 km.  downwind from  the
release point for any amount of  gas under various atmospheric stability
conditions (which are functions  of  wind speed and the amount  and
intensity of sunlight, or insolation).  The
model assumes a Gaussian concentration distribution, but is applicable to
negatively buoyant gases provided they are  well mixed with the ambient
air.  For small to moderate quantities of chlorine gas dispersed over  a
range of 1-5 km., such as are of primary concern here, this is a
reasonable assumption.  Furthermore,  for large gas clouds, the Gaussian
concentration distribution assumes  a degree of vertical  dispersion
characteristic of neutrally or positively buoyant gases  and will thus
tend to produce low estimates of the downwind ground-level concentration
of a negatively buoyant gas.

A copy of the section of Petersen1s model on which this  study is based is
appended to this report.  The approach taken in applying the  model  was to
calculate the size of chlorine releases which would result in a lethal
chlorine gas concentration at various distances downwind of the release
point for a range of"atmospheric stability  conditions.   This  approach
permits a hazard assessment which minimizes assumptions  on site
characteristics, release conditions,  and spill sizes.  It should be
noted, however, that the model implicitly assumes an instantaneous
release of material, regardless of  spill size; the validity of this
assumption is dependent on the actual case-specific mechanism of
release.  Furthermore, for the purposes of  this analysis it was assumed
that the hypothetical chlorine spill volatilizes completely,  i.e, that
all of the chlorine released evaporates before any of it is cleaned up.
The validity of this assumption is  dependent, in part, on case-specific
release mechanisms and spill sizes; nonetheless,  this can be  regarded  as
the functional equivalent of a worst-case assumption that the workers  at
                                                                  Chlorine  -  3

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           the release point are forced  to evacuate the site or are stricken by the
           gas cloud before initiating any emergency clean-up action.

           For the purposes of this report,  a peak chlorine concentration of 850
           ppm. by volume in the atmosphere  at ground  level was assumed to be
           lethal.  There is some disagreement within  the scientific community
           regarding the minimum peak concentration which should be considered
           lethal in the case of instantaneous or acute exposures, reflecting the
           paucity of experimental data  on human exposure to gaseous chlorine and
           the impracticality of obtaining such data.  However, concentrations in
           the range of 800-1000 ppm. are repeatedly cited in the literature as
           lethal to most animals in a very  short time; hence the assumption of 850
           ppm. as a lethal concentration.   To place this concentration level in
           perspective, it is worth noting that the Occupational Safety and Health
           Administration (OSHA) has set a workplace standard of 1 ppm. for exposure
           to chlorine gas.  Any exposure above this level, regardless of duration,
           is considered a violation of  OSHA safety regulations.

           The results of our calculations are presented in Tables 1 and 2.  Table 1
           gives figures on the projected sizes of chlorine releases which will
           produce gas concentrations of 850 ppm. at various distances downwind for
           a range of atmospheric stability  conditions at an ambient temperature of
           20°C (68°F), corresponding to a hypothetical summertime release.  Table 2
           gives analogous figures for a hypothetical  wintertime release at an
           ambient temperature of 3°C (37.4°F).  Calculations for both tables
           incorporate an assumed constant atmospheric pressure of 980 mb.  Included
           in the tables, for comparison, are figures  on the amount of chlorine gas
           which, when released to the atmosphere, can be expected to result in
           concentrations of 250 ppm. at a distance of 250 meters downwind of the
           release point.  These figures are intended  merely to provide a rough
           estimate of the amount of chlorine gas that might reasonably be expected
           to pose a significant hazard  to those in the immediate area who have a
           history of asthma or other chronic respiratory illnesses and are thus
           more susceptible to the toxic effects of chlorine gas.

           A careful examination of Tables 1 and 2 shows:

               1.  that the amount of chlorine gas which will result in a lethal
                   concentration at a given  distance downwind is strongly dependent
                   on atmospheric stability, decreasing markedly (by an order of
                   magnitude) with a slight  increase in stability.

               2.  that the projected hazard from a chlorine spill is only weakly
                   dependent on temperature, with a seasonal decrease in temperature
                   producing only a minor increase in  the amount of chlorine
                   resulting in lethal concentrations  at a given distance downwind.

               3.  that under unfavorable meteorologic conditions (e.g., a
                   moderately stable atmosphere), a very small chlorine spill (1.78
                   pounds) would produce lethal gas concentrations of 850 ppm. at a
                   distance of 250 meters downwind, and a spill of approximately 67
Chlorine - 4

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             pounds would be sufficient  to produce lethal concentrations at a
             distance of 1 km.  (the distance  from the existing Deer Island
             treatment plant to the southern  end of  Point Shirley).  To place
             these spill sizes  in perspective,  it should be noted that
             chlorine is presently stored at  Deer Island in 16-ton
             (32,000-pound)  tanks.

         4.  that even under comparatively favorable meteorologic conditions
             (a slightly to  moderately unstable atmosphere), a spill of a few
             hundred pounds  would result in lethal concentrations at a
             distance of 250 meters from the  release point (the approximate
             distance from the  existing  Deer  Island  treatment plant to the
             Deer Island prison).

     Table 3 presents a breakdown of the ranges of wind speeds and insolation
     conditions giving rise  to  the various conditions of atmospheric
     stability.  As shown in the table,  each  atmospheric stability condition
     can result from two or  three distinct combinations of factors.  Note, in
     particular, that any given stability condition  can reasonably be expected
     to occur in both summer (strong insolation) and winter (slight
     insolation).  Thus the  entire range of atmospheric conditions will occur
     throughout the year, and it is not  possible to  restrict the consideration
     of chlorine spills under unfavorable conditions to a particular season.
     Table 3 does show, however,  that the most unfavorable atmospheric
     conditions are expected to occur on clear, calm nights.

     It is concluded from this  analysis  that,, even in the absence of figures
     on the probability of a  chlorine spill, the risk of such a spill under
     adverse atmospheric conditions represents a potential public safety
     hazard, and that alternatives to the continued  use of liquid chlorine as
     a wastewater disinfectant  should therefore be explored.

D.   Implications of Hazard  Analysis for Siting of the Proposed Treatment Plant

     Questions were raised on the implications, if any, of the possible
     continued use of chlorine  for siting of  the proposed treatment plant.
     Specifically, it was asked whether  siting the plant on Long Island would
     be 'safer" than placing it on Deer  Island, and  would pose less risk to
     public safety in the event of an accidental chlorine release.  To answer
     this question, it was necessary to  look  at wind directions and
     frequencies in Boston Harbor, and at the distances from both Deer Island
     and Long Island to the  nearest inhabited areas.

     The closest residential areas to Deer Island are Point Shirley, 1 km. to
     the northwest, and Cottage Hill, 2  km. to the north-northwest.  The
     closest inhabitants, however, are the inmates and staff of the Deer
     Island prison, some 250 meters north of  the existing treatment plant.
     These areas would be at risk from any chlorine  gas cloud blown on winds
     from the south, south-southeast, or southeast.  A wind rose for Boston
     Harbor prepared by Metcalf and Eddy (1982) indicates that such winds are
     most common during the  summer, when they occur  approximately 20% of the
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           time, and are fairly infrequent during the winter, when they occur
           approximately 8% of the time.  Clearly, the population most particularly
           at  risk from a possible chlorine spill at Deer Island are the inmates and
           staff of the Deer Island prison, who not only are exposed to a
           significant hazard in the event of even a small release under favorable
           atmospheric conditions, but are also constrained in their ability to
           evacuate the area if necessary.  Relocating the prison can be expected to
           significantly reduce the level of risk to local inhabitants by increasing
           the distance to the nearest residents, and hence the size of spill which
           would result in lethal concentrations in areas where human exposure is
           likely.  However, residents of Point Shirley will remain at risk from
           small- to moderate-sized spills under a range of atmospheric conditions
           which cannot be considered uncommon.

           The inhabited areas which lie closest to Long Island, and would thus be
           exposed to the greatest hazard from a chlorine gas release, are Georges
           Island, lying 3 km. to the east, and the Pemberton-Stony Beach-Telegraph
           Hill section of Hull, lying approximately 5 km. to the east-southeast.
           These areas would be at risk from a chlorine gas cloud blown on winds
           from the west or northwest.  The Boston Harbor wind rose prepared by
           Metcalf & Eddy indicates that such winds are prevalent during the winter,
           when they occur approximately 47% of the time, and are common during the
           summer, when they occur 23% of the time.  From a purely qualitative
           standpoint, this indicates that the inhabited areas threatened by a
           hypothesized release of chlorine gas at Long Island would be at risk
           nearly three times as often as areas similarly threatened by a comparable
           release at Deer Island.  This increased frequency of risk must be weighed
           against the fact that a gas cloud released at Long Island would, by
           virtue of traveling longer distances before reaching populated areas,
           undergo greater dilution prior to any public exposure than would a gas
           cloud released from Deer Island.  A rigorous quantitative assessment of
           just how this frequency/dilution tradeoff will influence the expected
           level of risk in Hull, relative to that in Point Shirley, is beyond the
           scope of this report.

           From this assessment, it is nonetheless concluded that siting the
           proposed plant at Long Island rather than at Deer Island would merely
           replace a comparatively high level of risk with a comparatively high
           frequency of risk, and would not substantially mitigate the existing
           public safety hazard from a possible accidental chlorine release.

       E.   Conclusions

           In  summary, it was found, from documentation of past accidental chlorine
           releases and from mathematical modeling of chlorine gas releases
           resulting in lethal concentrations downwind of the release point, that
           the continued use of liquid chlorine as a wastewater disinfectant in
           Boston Harbor constitutes a potential public safety hazard.  The
           implications of this conclusion for siting of the proposed treatment
           plant are not clear-cut, as they involve a tradeoff between the level of
           risk to which the public is exposed and the frequency with which the
Chlorine - 6

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public is exposed to that risk.   Siting  the plant at  Long  Island  rather
than Deer Island would place it  farther  from  inhabited areas,  insuring
greater dilution of a gas cloud  prior  to public exposure  (as well as more
time for any evacuation that might  be  required), but  would at  the same
time increase by roughly a factor of three the chances that the wind
would be blowing toward a residential  area in the event of an  accidental
(and.'hazardous)  chlorine gas release.  In short, moving the plant does
not eliminate the hazard from a  possible chlorine leak, and it is
recommended that alternatives to the continued use of chlorine be
examined.  Various alternative disinfectants  do exist (e.g., sodium
hypochlorite, ozone), and it would  be  prudent, once an in-depth
examination of the costs and feasibilities of these alternatives  has been
conducted, to discontinue the use of liquid chlorine  as a wastewater
disinfectant in Boston Harbor unless a clear  and convincing need  for its
continued use can be demonstrated.

It should be noted, however,  that in light of the figures on chlorine
releases in the transportation system  cited earlier in this report, and
given the special problems posed by the  difficulty of evacuating  Deer
Island and/or Point Shirley,  the continued trucking of chlorine would
appear to be a more important concern  for the short-term than  is  the
continued use of chlorine at the proposed plant.  A tank truck accident
involving a chlorine spill anywhere along the route to either  Deer Island
or Long Island would have the potential  for exposing  densely populated
areas to very high concentrations of chlorine gas.  It would therefore be
advisable to adopt an alternative means  of chlorine transport  at  the
earliest possible opportunity. •
                                                                 Chlorine - 7

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                                           NOTES

       1.    Mr.  Fred Talcott,  Office of Policy Planning,  EPA Headquarters,
            Washington,  DC;  personal communication,  October 23 and 25,  1985.

       2.    As cited by  Mr.  Fred Talcott in personal communication,  October 23,  1985.
Chlorine - 8

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                              SOURCES REFERENCED

1.   Metcalf and Eddy, 1982:  Typical Wind Patterns in Boston Harbor,  Summer
     and Winter; from "Climatology of the U.S.,  No. 82-19,"  U.S.  Dept.  of
     Commerce, National Climate Center.

2.   National Research Council, 1976:  Chlorine  and Hydrogen Chloride;  NTIS
     Publication PB-253196,  April 1976.

3.   Petersen, W.B., 1982:   "Estimating  Concentrations Downwind from an
     Instantaneous Puff Release"; Environmental  Sciences  Research Laboratory,
     USEPA, April, 1982.

4.   Picknett, R.G., 1981:   "Dispersion  of Dense Gas Puffs Released  in  the
     Atmosphere at Ground Level"; in Atmospheric Environment,  vol. 15,  pp.
     509-525.

5.   Sconce, J.S., date unknown:  "Chlorine:   Its Manufacture, Properties,  and
     Uses"; American Chemical Society Monograph  Series; Reinhold  Publishing
     Corp., New York.

6.   Underbill, P.P., 1920:   The Lethal  War Gases:  Physiology and
     Experimental Treatment; Yale Univ.  Press, 1920.
                                                                       Chlorine - 9

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                         ESI IMA1ING CONCENTRA1IONS DOWNWIND FROM
                             AN INSTANTANEOUS  PUFF RELEASE
                                            by
                                  William B. Petersen
                           Meteorology and Assessment Division
                         Environmental Sciences Research Laboratory
                        Research Triangle Park, North Carolina  27711
                        ENVIRONMENTAL SCIENCES RESEARCH LABORATORY
                           OFFICE OF RESEARCH AND DEVELOPMENT
                           U.S. ENVIRONMENTAL PROTECTION AGENCY
                        RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
Chlorine -  10

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                          CONCENTRATION ESTIMATES

INSTANTANEOUS PEAK CONCENTRATIONS

     The peak ground level concentration from an instantaneous surface
release is given by Equation 1.

                20
   Xp  =
                    Oxoyaz

Where:  Q   is the total emission (g),
        ox is the downwind dispersion parameter (m),
        Oy is the cross wind dispersion parameter (m),
        oz is the vertical dispersion parameter (m).

     Typically it is assumed that ox = oy for puff-type dispersion estimates.
Nickola (1971) showed that, for ground level releases, ox is greater than
Oy in the first few hundred meters of travel, but the puffs become more
symmetrical as travel distances approach 800 meters.  For the purposes of
this work ox and oy are assumed to be equal, and the dispersion in the
xy plane will be indicated by or.  Equation 1 can then be expressed as:

                2Q
              (2t)3/2
                                                                     Chlorine - 11

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           Figure  1  shows  peak  ground level  concentrations  normalized by emission
      strength, Xp/Q,  versus  downwind distance  for  three  stability regimes unstable,
      neutral, and very  stable.  The  stability  regimes  can  be  determined from cloud
      cover, ceiling height and wind  speed,  using Turner's  stability  classification
      scheme (1970).  In the  absence  of  meteorological  data at the site  of release
      or from a nearby weather  station,  the  stability regimes  can  be  approximated as
      follows.  On a clear, sunny day with light winds, use the unstable curves.
      During windy or  cloudy  conditions,  use the neutral  curves.   On  a clear  night
      with calm or light winds, use the  very stable curves. The dispersion coef-
      ficients for the three  stability classes  are  those  recommended  by  Blade (1968).
      Figure 1 was derived using Equation 2  with the dispersion coefficients  mentioned
      above.  Equation 2 is applicable only  for surface releases.   Solid lines on
      the curve represent  distances of observed data.  Dashed  lines are  extrapolations.

      Example Problem  2-1

      A 1000 kg instantaneous release of  chlorine occurs  during neutral  stability
      conditions with  a  mean  wind speed  of 3 m/sec.  What is the peak  concentration
      5 km downwind?

      Step 1.  Use Figure  1 to  determine  X /Q at 5  km downwind on  the
               neutral stability curve.
               X /Q  =  9.5x10-8   Note:  X  /Q  is  independent  of  u.
                P                        P

      Step 2.  Compute X  r x /Q x Q
               X   =  (9.5x10-8)  x (1.0x106) =  9.5x10-2 g/m3

      If the atmosphere  was actually  very stable rather than neutral,  to what
      downwind distance  would the peak concentration be greater than  that  computed
      in Step 2?
Chlorine -  12

-------
  10
1CT1
i\
                   :^
                                       \
                             -v
                                                A
                                     Ck-
                                     : *
                                                                V
                                                 ^
                                                                  10-'
                                                                 10"
   OjOl
                      0.1                1.0
                                            10.0
                                                               100
                              DOWNWIND DISTANCE (km)
          FIGURE 1.  XpA> VERSUS DOWNWIND DISTANCE. THE LEFT HAND SCALE

                   IS FOR Xp/O VALUES OF 10 5 TO 10. THE RIGHT HAND SCALE

                   IS FOR Xp/O VALUES OF 10'11 TO 10*.
                                                                      Chlorine  -  13

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      Step  1.  Find  x/Q  (9.5x10"B) on Figure  1, on the very  stable  curve.
      Step  2.  Read  down to the distance scale.
               x  s  32 km.
      CONVERSION OF CONDENSATION UNHS

           Ihe equation of state can be used for conversion of concentrations
      from wg/m' to ppm.
      X(ppm) s   x        x T(K) x R
                     M x P(mb)

      where:  T is the absolute temperature (K),
              M is the gram molecular weight (gm-mole),
              P is the atmospheric pressure (mb),
              R is the universal gas constant 8.31x10~2    - — ^—
                                 3                         gm-mole

      The equation to convert ppm to ug/m^ is given below.
                   UK) x 8.31x10-2

       In the example above the ambient temperature was 80°F and the atmospheric
       pressure was 980 mb.  Find the concentration in ppm.

                 U°C) = 5/9(l(°F)-32)
Chlorine  -  14

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The absolute temperature is 299.7 (K).  The molecular weight of chlorine
(CL2) is 70.91.


               95000(gg/m3) x 299.7(K) x 8.31x10-2
   x    .  -  	 - 34
    (ppm)                   70.91 x 980(mb)

The peak concentration 5 km downwind is 0.095 g/m3 or 34 ppm.
AVERAGE CONCENTRATIONS

     In the paragraphs that follow a methodology is described for computing
ground level concentrations from an instantaneous surface release for a
given stability class and sampling time.  The average concentration over
sampling time T can be expressed as some fraction of the peak concentration.

   XT = XP x F,                                                (3)

where:  XT   *s tne average concentration for a given sampling time T,
         T   is the sampling time, i.e. 5 min., 1-hour etc.,(expressed
             in seconds)
        Xp   is the instantaneous peak concentration,
         F   is the correction factor for sampling time, which always has
             a value less than or equal to one.
The correction factor F can be computed as follows:
       F -  (A-0.5)
            (N) 0.3989
                                                                     Chlorine - 15

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                 1000
                  100
                                                                        *l
                  10
                 0.1
                    0.01
0.1
1.0
10.0
                                                  DOWNWIND DISTANCE (km)





                                         FIGURE 2. o, VERSUS DOWNWIND DISTANCE
                                                                                                  100.0
Chlorine  - 16

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   4.0
O
UJ
O

O
cc
<
O
V)
u.
O
CC
UJ
to
5

Z
   3.0
   2.0
   1.0
     50  60  70
  90   95    98  99     99.899.9


AREA UNDER NORMAL CURVE
99.99
       Figure 3. Percent  area under  normal  curve  for  a given

                 number of  standard  deviations.
                                                              Chlorine - 17

-------
       where:   A   is the cumulative area under the normal curve (Figure 3),
               N   is the number of standard deviations out from the peak
                   of the Gaussian distribution.
                   N =
                       TU
                          f
               u   is the mean wind speed,
               or   is the horizontal dispersion coefficient (Figure 2).

            The concentration at a given receptor location ranges from zero to a peak
       value as the puff moves towards the receptor.  The peak instantaneoous concentra-
       tion  is  always assumed to occur at time t when the center of the puff is at
       the receptor location.  If the growth of the puff is small as the puff passes
       over  the receptor* then the peak average concentration for sampling time T at
       a  particular location occurs during the time period t - t/2 to t * T/2.

       Example  Problem 2-2

            For the conditions given in Example problem 2-1, find the peak 5 minute
       average  concentration and the peak 1-hour average concentration at 5 km
       downwind.

       Step  1.   Compute the instantaneous peak concentration x~.

                From problem 2-1, xp = 9.5x10"^  g/m^.

       Step  2.   Compute A.

          (a)   Determine the number of standard deviations.

                     TU      300(3)
                N  =  	 = 	 = 3.0
                     2or    (2X150)

                or is approximately 150 meters,  determined from Figure 2 at 5 km
                downwind.
Chlorine - 18

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  (b)  Given a value of N = 3.0 determine A from Figure 3.

         A = 0.998

Step 3.  Compute Xf

         Substitute A into Equation 4.

          p _   (0.998-0.5)      - o 42
                (3.0) 0.3989

         Substitute F into Equation 3 to determine  peak 5 minute average
         concentration.

          JT = 0.42 x 9.5x10-2 = 4.0x10-2 g/m3.

         In a manner analogous to the above, the  peak  1-hour  average
         concentration can be computed.

          N = 3600 (3)    ,,
             —o         -jo.
              2 or

          From Figure 3,  A = 1,
          F=        -'	   =0.035
                  (36)   0.3989
          Substitute F  into Equation  3  to  find  the  peak  1-hour  average
          concentration.

           JT  = 0.035 x 9.5x10-2 =  3.3x1Q-3 g/m3.
                                                                     Chlorine  -  19

-------
           The total dosage, D, at a given downwind distance, stability class,
      and wind speed can be approximated using the following equation.
         0 = X  x   2'    r  (matter-time/volume)
      or is determined  for the given stability class and downwind distance.
Chlorine - 20

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11-12
 sludge

-------
11-12  Sludge Management Facilities

     A.   Background

          In the Certificate of Adequacy on the Supplemental Draft
          Environmental Impact Statement/Report, issued by the Executive
          Office of Environmental Affairs of the Commonwealth of
          Massachusetts, the issue of sludge management was discussed at
          length.  The certificate indicates that segmentation of final sludge
          management is an appropriate course of action to take in the
          environ- mental review of the siting decision.  However, it was
          noted that the SDEIS/R was inconsistent in describing the sludge
          processing facilities that would be required.  The Certificate
          directed the Final EIS/EIR to use common  assumptions   concerning
          sludge processing for all siting options.

          Consultants for the MWRA reviewed the SDEIS/R and reassessed the
          sludge processing facilities that could be assumed to be necessary.
          The results of that assessment follow.
                          i
     B.   Information on Sludge Processing in the SDEIS/R

          Information concerning sludge processing appeared in the SDEIS/R in
          several places.  This information included conceptual site layouts,
          tables of numbers and sizes of sludge processing units, and tabular
          cost estimates.

          A comparison of the information contained  in the site layouts and
          the tables shows that there are inconsistencies between the data
          sources.  Table I summarizes the information on sludge processing
          units that was presented in the SDEIS/R.

          Table I shows that the SDEIS/R layouts and tables were consistent in
          their treatment of sludge processing at Nut Island.  For Deer
          Island, the tables assume existing facilities would be used, but the
          layouts assume they will be abandoned; no  compensatory sludge
          facilities are shown on the layouts to replace them.  In addition,
          flotation thickeners are indicated on the  Deer Island secondary
          layouts, but nowhere else in the document.  For Long Island, only
          the split primary option shows any sludge  processing at all.

          As a result of these discrepancies, some confusion was created
          concerning the sludge processing units that might be used at the
          facilities.  An inaccurate impression of the potential footprint of
          the plant also was conveyed.  Specifically, layouts at Long Island
          underestimated the size of the plant because no sludge processing
          was shown.
                                              Sludge Management Facilities - 1

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                    Table  I:  Comparison of  Numbers of  Sludge Processing
                      Onits Shown  in  Tables  and  Layouts of  the  SDEIS/R

                                  Gravity Thickening            Anaerobic  Digestion
       Secondary Options               Table  Layout                  Table Layout

       All  Deer                        10       6                   12         8

       Deer/Nut
       -  Deer                           95                    84
       -  Nut                           22                    44

       All  Long                         80                   12         0

       Deer/Long
       -  Deer                           85                    84
       -  Long                           40                    40

       Primary Options

       All  Deer                        10       6                   12         8

       Deer/Nut
       -  Deer                           85                    84
       -  Nut                           22                    44

       All  Long                         82                   12         4

       Deer/Long
       -  Deer                          10       5                   12         4
       -  Long                           22                    44
            C.    Sludge Processing  Units

                 The specific  processes for  sludge  management  that  will  be  used  at
                 the new wastewater treatment  plant will  not be  known  until the
                 MWRA's comprehensive study  on residuals  management is completed.
                 For the purposes of this  report, conservative assumptions  have  been
                 made concerning potential sludge processing unit operations,  and
                 used to develop layouts and cost estimates.   These operations
                 include:

                 1.    Thickening.   Thickening  of sludges  before  further  processing
                      reduces  their volume.  The unit  processes  assumed  here are
                      gravity  thickening for primary sludges and dissolved  air
                      flotation thickening for secondary  sludges.

                 2.    Anaerobic Digestion.   Anaerobic  digestion  of  sludges  reduces
                      the solids content and produces  methane, which can be used for
                      in-plant energy.
Sludge Management Facilities - 2

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           3.   Pewatering.   Dewatering of digested or undigested sludges
                reduces their water content, and thus, the volume of material.

           A diagram of the  process is shown in Figure I.  This group of
           operations represents  a conservative approach, and will result  in
           the maximum land  area  needed for sludge processing.  This ensures
           that plant area requirements and guidelines for developing
           mitigating actions will consider the 'worst case1  for sludge
           processing.  For  development of site layouts, allowances have been
           made for either on-site incineration, or sludge storage for
           off-island transport.

           For each sludge processing operation, numbers and sizes of tanks
           were estimated by taking data  from previous reports on solids
           production.  Figures of 265 dry tons per day of primary sludge  and
           150 dry tons per  day of secondary sludge are used for the planning
           purposes of this  final EIS/R.*

           A summary of the resulting units and sizes for each alternative
           appears in Table II.

                                    FIGURE I
                   Primary
                   Sluolge
                    Secondary
                      Sludge
                                     Thickening
                                  Digestion  8./or
                                      Storage
                                                            Dcean
                                                           Disposal
                                    Dewatering
               Incineration
Composting
Landf illing
Source:
*Camp,  Dresser  and  McKee
           Sludge Management Facilities - 3

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      Alternative Site

      Secondary Treatment

      1. All Secondary,
         Deer Island
         (Option la.2)
         Deer Island
         (New)
Table II:  Sludge Processing Unit Operations
          by Alternative and Sizes
               Flotation
   Gravity     Thickening Anaerobic   Belt Filter
   Thickening  No. -      Digestion   Presses
   No. -       Width      No.         No. -
   Diameter    X Length   Diameter    Width
   X Depth     X Depth    X Depth     (meters)
   8-80x12  28-20x75x12  24-110x30
      2. Split Secondary,
         Deer Island, Nut
         Island (Option lb.2)
         Deer Island
         (New)
         Nut Island
         (Existing)
         Nut Island
         (New)
           Total
      3. All Secondary
         Long Island
         (Option 2b.l)
         Long Island
         (New)

      4. Split Secondary
         Deer Island and
         Long Island
         (Option 2b.3)
         Deer Island
         (New)
         Long Island
         (New)
           Total
   £-80x12  _28_-20x75x12  _20-110x30

         0            0   ^-100x30

   2-80x12            0   1-110x30
   8-80x12  28-20x75x12  24-110x30
   _6-80xl2            0   1-110x30

   2-80x12  28-20x75x12  16-110x30
20-2.2
   0

   0
20-2.2
   0

20-2.2
          Net    Gross
          Area   Area
          Acres  Acres
15
14

 0

 1
15
15
12
16
18
17

 0

 1
18
18
14
19
Sludge Management Facilities - 4

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                 Table II:  Sludge Processing Unit Operations
                     by Alternative and Sizes (continued)
Alternative Site

Primary Treatment

1. All Primary,
   Deer Island
   (Option 4a.2)
   Deer Island
   (New)

2. Split Primary,
   Deer Island,
   Nut Island
   (Option 4b.2)
   Deer Island
   (New)
   Nut Island
   (Existing)
   Nut Island
   (New)
     Total
 Gravity
 Thickening
 No. -
 Diameter
 X Depth
 8-80x12
 6-80x12
2-280x12
     Flotation
     Thickening Anaerobic
     No. -      Digestion
     Width      No.
     X Length   Diameter
     X Depth    X Depth
            Belt Filter
            Presses
            No. -       Net    Gross
            Width       Area   Area
            (meters)    Acres  Acres
            0  11-110x30
              13-2.2
            0   2-110x30

            0   ^-100x30

            0   1-110x30
              _13_-2.2

                 0

                 0
             7

             0

             1
             8
                   11
3. Split Primary,
   Deer Island and
   Long Island
   (Option 5a.2)
   Deer Island
   (New)
   Long Island
   (New)
     Total
 .6-80x12

 2-80x12
4. All Primary, Long
   Island (Option 5b.2)
   Long Island (New) J|-80xl2
NOTES:

   (2)
   (3)

   (4)
        (1)
            0

            0
2-110x30

4-110x30
13-2.2

   0
                    0  11-110x30
                              13-2.2
2
9
 8

 3
11
                                 10
             Dimensions in feet except where
             otherwise indicated.
Net Acreage includes 2.5 acres for incineration.
Gross Acreage allows for piping space between
components
Costs do not include incineration.
                                              Sludge Management Facilities - 5

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	11-13
disposal of properties on Deer Island by GSA

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                           General Services Administration, Region 1
                           John W. McCormack Post Office and Courthouse
                           Boston, MA 02109
Date  iNovember 18,
Reply to
Attnof : 1PEP
1985
Subject: Disposal of Surplus Real Property
      Deer Island, Boston, Massachusetts

To   :Mr. Robert Mendoza
      Water Management Division
      Environmental Protection Agency
      JFK Federal Building, Room 2100
      Boston, Massachusetts 02203
      Please find enclosed a copy of the revised section pertaining to the subject
      disposal action for your Final Supplemental EIS on Siting of Wastewater
      Treatment Facilities for Boston Harbor.  This reflects discussion by our
      respective staffs on November 6, 1985.  If you have any questions please
      call Mr. Fred Ryan, Chief, Planning Staff at FTS 223-2707.
      L. M. PEARSON
      Assistant Regional Administrator
      Office of Public Buildings and Real Property

      Enclosure
                                                                              GSA  -  1

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GSA - 2

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11-13  DISPOSAL OF PROPERTIES ON DEER ISLAND  BY GSA
A.  Background

    This section describes the proposed  administrative  action by the General
    Services Administration (GSA)  pursuant  to the  Federal Property and
    Administrative Services Act of 1949  as  amended (FPAS) for the disposal of
    five parcels of land,  formerly comprising Fort Dawes on Deer Island,
    Boston, Massachusetts.

    Two parcels of 1.75 acres and  3.5  acres are currently under GSA control,
    pending disposal as surplus real property.  These parcels were acquired on
    March 8, 1985 from the Metropolitan  District Commission (MDC) by revest-
    ment of title.  Three  additional parcels of 32.74,  1.25 and 0.46 acres are
    controlled by the U.S. Navy which  now is in the process of declaring them
    excess and reporting them to GSA for disposal.  These parcels, totaling
    about 39.7 acres, are  located  at the southern  end of Deer Island and are
    bounded by property owned by the MDC and City  of Boston.  (See Figure I-A.)

    In May, 1985, GSA learned that these U.S. Government-controlled parcels
    may be required for construction of  a wastewater treatment facility on
    Deer Island, as proposed in several  alternatives described elsewhere in
    this document.  On July 26,  1985,  GSA met representatives of the Environ-
    mental Protection Agency (EPA) and Massachusetts Water Resources Authority
    (MWRA) to discuss GSA's disposal procedures and requirements.  GSA and EPA
    have had subsequent meetings to coordinate their actions.

    Since the siting decision and  disposal  action  would be directly related
    because of their functional interdependence and geographical proximity,
    GSA has been designated as a cooperating agency in  this environmental
    impact statement by the Environmental Protection Agency (EPA) which is the
    lead agency (4CCFR 1501.5 and  6).
B.  Need for Action

    GSA has statutory responsibility  for the disposal of real property
    reported as excess by  Federal  agencies.

    Council on Environmental  Quality  (CEQ)  regulations  require that all
    possible alternatives  be  identified and all  "reasonable* alternatives be
    objectively and thoroughly  evaluated.   Two types of alternatives are
    considered:  (1) the means  of  disposal  by GSA and (2) the uses of the
    property after disposal.
C.  Disposal Alternatives

    After a property has been reported  as  excess by a Federal agency, GSA has
    a number of disposal alternatives which are summarized below:
                                                                           GSA  -  3

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           1.   Transfer to Another Federal Agency

               GSA  screens excess property for use by other Federal agencies as a
               first  step.   Two of the Government parcels on Deer Island have been
               screened with negative results.  The remaining parcels are to be
               screened as soon as they are reported as excess.  Normally, a request
               from another  Federal agency would take precedence over other disposal
               options and GSA would transfer the property as requested.  However, it
               is expected that screening will identify no federal need for these
               sites.

           2.   Disposal by Specific Public Benefit Program Transfer or Sale to Public
               Bodies

               There  are  a number of programs by which surplus property may be
               conveyed to state or local governments or, in some cases, qualifying
               non-profit entities, at a discount of up to 100 percent.  Specified
               public uses under these programs include education, health, park and
               recreation, historic monuments, public airports, highways, wildlife
               conservation  and housing.  In most cases, the land must be used for
               the  specified use in perpetuity; otherwise title reverts to the
               Government.

               Transfer of the subject Deer Island parcels is possible under one or
               another of these public benefit programs depending on the interest of
               eligible applicants.

           3.   Disposal by Negotiated Sale to Public Bodies

               GSA  may dispose of surplus Government-owned property to states,
               territories,  possessions, and political subdivisions thereof, or
               tax-supported agencies therein by negotiated sale for unrestrictive
               use.   Surplus property may be sold through negotiations at not less
               than fair  market value obtaining such competition as is feasible for
               purposes that provide some public benefit.  Value is based upon the
               property's highest and best use which is considered the most suitable
               use  of the property from economic and environmental standpoints given
               the  characteristics of the property and improvements to it.

               Negotiated sale is a reasonable alternative for the subject Deer
               Island parcels.

           4.   Public Sale

               Surplus properties not disposed of to public agencies or other
               eligible bodies are offered for sale to the public by GSA on a
               competitive bid basis.  Scheduled sales are widely publicized through
               mailing lists, paid advertising and listing in the Commerce Business
               Daily.  The sale may be by sealed bid or public auction.  Considering
               the  limited feasibility of private development of the subject parcels
               (discussed below) and the great likelihood that there will be public
GSA - 4

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        agency interest in the subject parcels, the public sale means of
        disposal is not considered  a  reasonable alternative.

    5.  No Action

        The no action alternative would  be  inconsistent with GSA's legal
        mandate to ensure a timely  disposition of surplus property.  Hence, it
        is not considered to be a reasonable alternative.

    6.  Delay the Action

        If, in its disposal activities,  GSA finds that it cannot obtain fair
        market value, it may retain the  property until market conditions
        improve.

D.  Alternative Land Uses and Impacts

    1.  Wastewater Treatment Facility

        Under several of the final  alternatives for siting a Wastewater
        Treatment Facility for Boston harbor, the subject parcels on Deer
        Island will be required for construction and expansion.  The impacts
        of this proposed land use are thoroughly considered in this environ-
        mental impact statement including comparison of environmental impacts
        compared with alternative sites  in  Boston harbor.  This siting
        decision is the responsibility of EPA and the Massachusetts Water
        Resources Authority (MWRA).

    2.  Public Recreation

        Due to the security needs of  the Deer Island House of Correction,
        there has been no public access  to  Deer Island for many decades.  In
        1972, the Metropolitan Area Planning Council proposed to relocate the
        prison, expand the treatment  plant  in the northern portion of the
        island, and develop a park  in the southern portion of the island.
        These plans were never implemented.  In 1984, the Massachusetts
        Department of Environmental Management  (DEM) proposed a new draft
        master plan for the harbor  islands  which proposed no recreational
        facilities on Deer Island.  Though  that plan has not been finalized
        pending completion of this  siting decision, the Commissioner of DEM,
        who has authority to veto the placement of this treatment plant, has
        stated that as between Long Island  and Deer Island, it is of great
        significance that Long Island be developed as the Harbor's major park,
        not Deer Island.  A Deer Island  park would be precluded by expansion
        of the treatment facility.  However, alternative plans for the
        expansion of the treatment  facility feature the possibility of also
        developing small scale recreation uses  at Deer Island, such as public
        fishing piers or boat launching  ramps SDEIS (Section 4.3.1).  The
        subject parcels may be disposed  of  for  recreational use by public
        benefit conveyance through  the  National Park Service (NPS) of the
        Department of the Interior  or by GSA through negotiated sale.
                                                                            GSA - 5

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              The proposed plans  (mentioned above) foe recreational development of
              Deer Island indicate a  minor level  of  impacts, compared to the
              treatment facility  alternative.   The existing topography would be
              maintained.  The major  impact will  be  visitor traffic based on
              projected peak daily visits of 1500.

          3.   Commercial/Residential  Development

              Reuse of the subject parcels by  private developers in a manner
              consistent with local zoning might  be  feasible if the City of Boston
              and the State agreed to provide  public access over their land.
              However, this scenario  is  considered unlikely since it would neces-
              sitate the relocation of either,  and probably both, the prison and
              existing treatment  facility.  Proposals to relocate the Deer Island
              House of Correction would  substantially reduce public access con-
              straints resulting  from security concerns.  Nevertheless, accessi-
              bility and development  potential would remain constrained by the
              existing treatment  plant.  There are no known public plans for
              residential or commercial  reuse  of  Deer Island at this time.  Also,
              this alternative would  preclude  the above mentioned recreation plans.
              Hence, this alternative is deemed to be not reasonable.  Industrial
              land uses are likewise  deleted from further consideration for these
              reasons as well as  incompatibility  with local zoning.

          4.   Conservation

              Since no significant wildlife habitat  or endangered species are
              identified on Deer  Island, there are no reasons to consider reserva-
              tion of the subject Government-owned parcels for conservation use.
      E.  Preferred Alternatives

          In narrowing the range  of alternatives  for  the disposal of surplus
          Government land on Deer Island,  GSA  has considered constraints imposed by
          existing land uses and  site characteristics, as well as plans by other
          public agencies.  Existing land  uses (the prison and treatment plant),
          their associated operational restrictions on public access and negative
          impacts (security, noise, odors)  are significant deterrents to residential
          or commercial development.  There are no significant natural resources on
          the site which would warrant conservation use.

          There are major public  plans for the re-use of Deer Island for recrea-
          tional and wastewater treatment  facility use.  If the Deer Island site is
          selected by the EPA and MWRA for the new Boston Harbor Wastewater Treat-
          ment Facility, GSA will consider that Facility to be the highest and best
          use for the surplus Government parcels  because of the manifest public need
          for and benefits of such a project.   Otherwise, GSA will re-evaluate
          disposal alternatives in consultation with  other public agencies.

          Given the preferred land use alternative, disposal would be by negotiated
          sale to a public body (i.e., the Massachusetts Water Resources Authority).
GSA - 6

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                      MEMORANDUM OF AGREEMENT

                              Between

         THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              REGION I

                                and

                THE GENERAL SERVICES ADMINISTRATION
                              REGION I


I.   Introduction and Purpose

It is the purpose of this Memorandum of Agreement to formalize an

existing lead agency-cooperating agency relationship between the

Environmental Protection Agency, Region I (EPA) and the General

Services Administration, Region I (GSA) in the preparation of the

Final Environmental Impact Statement (FEIS) on the siting of second-

ary 'wastewater treatment facilities for Boston Harbor and the GSA

disposal of surplus real property on Deer Island, Massachusetts.


The FEIS, which is now nearly complete, is expected to recommend

as EPA's tentative preferred alternative the siting of the treat-

ment facilities on Deer Island.  In order to implement such a

preferred alternative, it would be necessary to utilize five par-

cels on Deer Island which are owned by the federal government for

construction of the facilities.  Two of the five parcels are now

available for disposal by GSA.  In January, 1986, the U.S. Navy

will be reporting three additional parcels for disposal by GSA.

As a prerequisite to disposal of these parcels, GSA must conduct

an environmental review pursuant to the National Environmental

Policy Act of 1969 (NEPA).  The FEIS which is being prepared by

EPA pursuant to NEPA is a prerequisite to the grant of federal

funds to the Massachusetts Water Resources Authority to construct

the treatment facilities on Deer Island.  Accordingly, applicable

                                                                GSA - 7

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                                  -2-



  applicable regulations require  EPA and GSA to cooperate,  to  the



  extent practicable, to avoid duplication  by adopting and  com-



  bining environmental review procedures.






  EPA and GSA have been observing a lead agency-cooperating agency



  relationship  since,  it became reasonably clear that  environmental



  analysis by GSA of  disposal of  the Deer Island  parcels  was appro-



  priate.  EPA  and GSA have met several times since May,  1985  to



  ensure the participation of GSA in the review process,  initiate



  the preparation of  appropriate  environmental analyses by  GSA for



  use by EPA, and make the results of  the EPA scoping process  avail-



  able  to GSA so that GSA would be aware of and address the signif-



  icant issues  to be  analyzed in  the FEIS.  GSA has heretofore pre-



  pared a draft environmental analysis and  has submitted  it to EPA.





  11.   General  Provisions



  In  furtherance of the lead agency-cooperating agency relationship,



  EPA and GSA agree as follows:



  1.  EPA shall ensure compliance with NEPA as to EPA's administrative



  action.  GSA  shall  ensure compliance with NEPA  as to disposal of



  the five federal parcels.  To the extent  feasible,  GSA  shall in-



  corporate  technical information developed by EPA as part  of  the



  FEIS  and earlier Supplemental Draft  Environmental Impact  Statement



  to  complete GSA's environmental review for the  disposal of surplus



  property.





  2.  EPA shall.ensure the procedural  and technical adequacy of the



  impact analysis of  the  FEIS on  siting of  the wastewater treatment
GSA - 8

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                                -3-

facility.  GSA shall be responsible for the procedural and techni-

cal adequacy of the impact analysis for the disposal of the federal

parcels.


3.  GSA shall attend all public meetings and public hearings on

the FEIS which are sponsored by EPA.  GSA shall be prepared to

respond to questions at these meetings concerning the GSA analyses

contained in the FEIS.  GSA shall respond in writing to comments

received by EPA concerning the portions of FEIS for which GSA is

responsible.


4.  GSA shall complete its environmental review in a timely fashion

to ensure availability of a camera-ready copy of the FEIS on or

before December 4, 1985.


5.  Robert E. Mendoza, EPA Water Management Division (223-0841)

is designated by EPA as the point of contact for all correspondence,

consultation and comments in connection with the FEIS and this

agreement.


6.  Richard Stewart, GSA Disposal Division (223-2651) is designated

by GSA as the point of contact for all correspondence, consultation

and comments in connection with the FEIS and this agreement.
Michael R. Deland             ^^~->  L.M. Pearson
Regional Administrator              Acting Regional Administrator
U.S. EPA, Region I                  GSA, Region I
Boston, Massachusetts               Boston, Massachusetts
/V /
Dated :  ' *.  V /~               Dated :
                                                                    GSA - 9

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	11-14
property values research evaluation

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11-14  PROPERTY VALUES
     A.   Background
          The SDEIS stated that property values in the vicinity of the
          proposed wastewater treatment facility could be expected to decline
          during construction,  then rebound once the new facility began
          operation.  Commentors,  specifically the Town of Winthrop,  disputed
          this view; town officials felt that a facility on Deer Island would
          have a permanent adverse effect on property values in Winthrop,  thus
          affecting the town's  tax base.

          EPA, EPA's consultants,  and the MWRA's consultants have investigated
          this issue in an effort  to determine what is known generally about
          the effects of sewage treatment plants on adjacent property values,
          and, if possible, to  determine the specific effects of a plant
          located on Deer or Long  Island on property values in Point  Shirley
          or Squantum, respectively.

          It was discovered, as noted in the appended report, that no
          literature exists which  specifically addresses the effect of
          proximity to sewage treatment plants on property values.
          Consequently, such information can only be inferred from existing
          data on the effects of other "negative" land uses.  Whether such
          inferences are valid  remains open to question.  Furthermore,
          discussions with William Wheaton, Professor of Economics and Urban
          Planning at Massachusetts Institute of Technology, indicate that
          there are methodological problems associated with a specific
          prediction of the impact of the proposed treatment plant on property
          values.  To make such a  prediction, it would be necessary to collect
          real estate sales data from a number of areas, with and without
          treatment plants, which  are otherwise similar in all respects to the
          area for which the prediction is to be made.  Unless data were
          collected for a significant number (about a dozen) of such  areas
          near treatment plants of the proposed type, it would be difficult to
          separate the effect of the proposed treatment plant from other
          influences such as airport noise or proximity to other negative  land
          uses (e.g., a prison).  The large number of variables affecting
          property values complicates statistical control of any systematic
          study to the extent that there would be only a 50 percent chance of
          producing a correct prediction.

          The specific impacts  (e.g., noise, odor, visual intrusion on the
          surrounding area) of  an  enlarged, operational treatment plant at
          Deer Island are unknown  and cannot be definitively determined in the
          plant's absence.  The problems of predicting the plant's effects on
          property values are compounded by the presence in Winthrop of
          waterfront and other  amenities, as well as negative influences such
          as the airport and the prison.  And finally, property values are
          strongly dependent on the subjective perceptions of neighborhood
          residents and of prospective buyers.  Such perceptions are  not
                                                           Property Values - 1

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                 quantifiable and are often as  much emotional  as  rational.
                 Consequently,  it is  impossible to  predict with any certainty the
                 effect of the  proposed plant on property values,  particularly in
                 light of the fact that siting  of the plant at Deer Island  may well
                 involve relocation of the prison.

                 Given these considerations,  i.e.,  the lack of data on the  specific
                 effects of sewage treatment  plants on property values,  the
                 methodological problems inherent in any effort to conduct  a
                 systematic study of  those effects, the difficulty of  separating the
                 influence of the treatment plant from that of other facilities, and
                 the ultimate dependence of property values on subjective
                 perceptions, it appears extremely  unlikely that  any effort to
                 monitor property values during construction would be  cost-effective
                 or would produce any meaningful result.  It should also be stressed
                 that information regarding property value trends  during construction
                 will have little or  no bearing on  the trends  to  be expected once
                 construction activities cease  and  the plant becomes operational.

                 A literature review  of the effects of sewage  treatment plants on
                 real estate values is appended.

                 The review was performed by Abt Associates, Inc.  of Cambridge,
                 Massachusetts, socio-economic  consultants under  the direction of
                 David Berry, Ph.D. in Regional Sciences.
Property Values - 2

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                   The Impact  of  Sewage  Treatment  Plants on
                 Local Property Values;  A Literature Review
I.   Overview
     Many essential public facilities  generate  "disamenities"  such as noise,
     visual intrusions,  smells,  barriers  to traffic,  or possibly even health
     or safety risks.   Among these are airports,  railroads,  electric power
     plants,  sewage treatment plants,  land  fills,  and prisons.   The
     disamenities generated by these  facilities are spatial  in  nature.  That
     is,  they spill over beyond  the immediate boundaries of  the facility into
     surrounding neighborhoods.   One  manifestation of the spatial extent of
     disamenities is a discounting of  residential  property values within the
     area of  influence of the facility.   Thus,  for example,  residential
     property values near an airport  may  be lower  than the values of similar
     properties located  away from the  noise of  the airport.

     The  capitalization  of amenities  and  disamenities into property values is
     a widely observed phenomenon.  It reflects people's willingness to  pay to
     be near  amenities and the market  discount  they must receive to be near
     disamenities.  The dollar value  of a property value discount attributable
     to a facility is  an economic measure of the value of the  disamenities
     generated by the  Facility.   (Likewise, the dollar value of property value
     increase attributable to amenities such as a  beautiful  view is an
     economic measure  of the value of  the amenity).

     This report describes the type of residential property  value impacts
     generated by noxious [The use of  the negative term noxious throughout
     this report is intended to  convey the  public  perception of a WWTF;
     however, properly designed  and supported facilities are not expected to
     be noxious.] public facilities and the magnitude of those  impacts.   These
     impacts  are taken from the  literature  on the  relationship  between
     disamenities generated by public  facilities and  the capitalization  of
     those impacts into  residential property values.

     The  general findings can be applied  to the sewage treatment plants
     proposed for Deer Island or Long  Island in Boston Harbor  as part of the
     Massachusetts Water Resources Authority's program to improve sewage
     treatment in the  Boston area. While it should be noted that the general
     relationships identified in the  literature are just that,  general,  they
     can  provide a broad view of what  could happen to residential property
     values in the vicinity of a proposed sewage treatment plant.

     The  literature review was confined to  empirical  studies of the effect of
     noxious  public facilities on residential property values.   This
     literature is fairly small  in comparison to the  whole literature on the
     factors  which contribute to urban residential property  values and on the
     effects  of environmental amenities (such as water access)  or disamenities
     (such as air pollution) on  property  values.   The principal source of
     literature was the set of journals devoted to urban and land economics
     issues.
                                                           Property Values - 3

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            In  addition  we  investigated  a  couple  of  sewage  treatment  plants  for  the
            availability of site-specific  reports.   The first plant was  in  the town
            of  Winthrop, Massachusetts that  encompasses the Deer  Island  Sewage
            Treatment Plant.  Unfortunately,  there were no  studies  conducted
            assessing the impact of  the  plant on  local  land values.   The second
            facility that was investigated was the Cedar Creek Sewage Treatment  Plant
            managed by the Nassau County Department  of  Public Works in New  York
            State.   This plant was built on  waterfront  land filled  marsh and
            integrated with a recreational park that includes facilities such  as
            tennis  courts and a golf course.   While  at  the  time of  completion  of
            construction of the Cedar Creek  Plant there were no housing  units  in the
            neighborhood, wince then, some housing units have been  built.   However,
            again there  have not been any  studies assessing the plant's  impact on
            property values.
       II.   Findings
            The literature reviewed considered  the impacts  of various  types  of
            noxious  public facilities  on residential  property values.   However,  no
            studies  of property value  impacts of sewage  treatment plants were
            discovered.   Nonetheless,  this review is  useful in that  the general  types
            and magnitudes of impacts  of the disamenities generated  by public
            facilities were identified:   power  plants, highways,  railways,  and
            airports.   These studies were conducted in a variety  of  urban and
            suburban locations throughout the United  States and Canada.  For the most
            part the studies were conducted with data on property values in  the
            1970s.   In general, the property value data  were sales prices of
            residential  property,  but  in some cases they were the average price  of a
            house in each city block or  census  tract  as  estimated by the owner of the
            house in the 1970 Census.

            Table 1  summarizes the property value impacts described  in the literature
            reviewed.   Several types of  facilities were  analyzed  by  the investigators:
Property Values - 4

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TABLE 1:  SUMMARY OF IMPACTS OF NOXIOUS FACILITIES ON RESIDENTIAL PROPERTY
          VALUES
Gamble and Downing
(1982)
Blomquist (1974)
Noxious
Facility

Nuclear
Power
Plants
Poon
Grether and
Mieszkowski (1980)
Coal
fired
power
plant
Railways


Highway
Locations

Plymouth, MA
Waterford, CT
Lacey TWP, NJ
Rochester, NY
Three Mile
Island, PA

Winneta, IL
London, Ont.
Hamden, CT
Years

1975-1977

1977-1979
For Three
Mile Island
1970
1967-1972
1955-1970
Data

Sales prices of
residential
property
1970 Census
block statis-
tics (average
house price
estimated by
owner)

Housing Sales
Prices

Sales prices of
single  family
homes
Nelson (1980 and
1982)
Mieszkowski and
Saper

Nelson (1979)
Airport
noise,
highway
noise
Airport
noise

Airport
noise
Emerson (1972)
Airport
noise
Review of
Literature on
Impacts on
Property
Values

Toronto, Ont.
Six cities:
San Francisco,
St. Louis,
Cleveland, New
Orleans, San
Diego, Buffalo

Minneapolis-
St. Paul
1960s&1970s
1969-1973
1970
1967
Housing sales
prices or census
tract or block
data on property
values.

Housing sales
prices

1970 Census data
for blocks
(average house
price estimated
by owner
Housing sales
prices
                                                           Property Values - 5

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       TABLE  1:  SUMMARY OF  IMPACTS OF  NOXIOUS  FACILITIES ON RESIDENTIAL  PROPERTY
                VALUES  (Continued)
       Gamble  and  Downing (1982)   1.
                                  2.
       Blomquist  (1974)
       Poon
       Grether  and  Mieszkowski
       (1980)
       Nelson  (1980  and  1982)
       Mieszkowski  and  Saper
       Nelson  (1979)
1.

2.
1.
                                  2.
1.
       Emerson  (1972)
1.
1.
                                  2.
1.
      Effect of Distance to Facility on
         Residential Property Values

No observed effect of proximity to facility on
property values.
Threa Mile Island accident affected only volume
of sales for a few weeks, but not property
values.

Power plant affects value of property within
11,500 feet of plant.
Within 11,500 feet of plant, a ten percent
increase in distance from the plant is
associated with a 0.9% increase in property
value for the average house.

Decline in housing values observed up to 800 to
900 feet from railway.
Sale price $2,161 higher 850 feet from railway
as compared to 50 feet from railway, ceteris
paribus (in 1972).

No statistically significant effect of proximity
to highway on property values.
Similar studies conducted for distance to
apartments, commercial zones, industrial zones,
and public housing but these are not noxious
public facilities.

For airports, noise discounts vary from 0.4% to
1.1% per decibel; thus a $40,000 house would
sell for $31,000 to $37,000 in a noisy zone (20
decibels noisier than a quiet neighborhood).

4% to 24% decline in housing values in noisy
areas, although due to samples sizes, authors
accept 15% decline as maximum impact.

For all six cities averaged housing prices  in
very noisy neighborhoods were valued about
$2,100 less than houses in neighborhoods
subject to only ambient noise levels.
House values decline between 0.29% and 0.74%
for each decibel increase in airport noise.

Decline in property value of 9.8% at maximum
noise level.
Property Values - 6

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The basic form of the investigations is a regression analysis with sales
price of residential property as the dependent variable and with
attributes of the property, distance to the noxious facility, and year of
sale as the independent or explanatory variables.  That is,

                    Y = a0 + a^X + 32D + 33! + u

where Y is the sales price of the residential property; X is a vector of
property attributes such as size, structural characteristics, access to
major roads, and the like;  D is a measure of distance to the noxious
facility of interest or a measure of the intensity of the facility's
spillovers at the property site (e.g., noise levels); T is a measure of
time or year of sale to reflect appreciation and inflation of property
values; and u is the error term.  The regression coefficients are
indicated by a^.  These models are often called "hedonic" models.

The form of the specification varies from case to case.  In some cases a
linear model is used, in others a logarithmic model is used.  The form of
D, distance to the noxious facility, is sometimes specified so that
property values increase with increasing distance from the facility, but
then level off, holding all other effects constant.

The major findings are:
- Not all noxious facilities have a detrimental effect on residential
  property values.

- When a noxious facility does have an effect on property values, that
  effect diminishes with distance and is no longer observed after a
  threshhold distance.  The threshhold distance could be a few hundred
  feet to a few miles.

- The effect of a noxious facility on property values can be very small
  (e.g., less than one percent diminution) to very large (e.g., 15%
  diminution).

- The impact of noxious facilities on residential property values varies
  greatly from case to case and appears to depend on housing market
  characteristics, the specific characteristics of the facility, and
  local likes and dislikes concerning disamenities.
                                                      Property Values - 7

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                                        BIBLIOGRAPHY
       Blomquist, Glenn, "The Effect of Electric Utility Power Plant Location on Area
       Property Value,":  Land Economics vol 50 (1974)  97-100.

       Emerson, Frank, "Valuation of Residential Amenities:  An Econometric
       Approach,":  Appraisal Journal, (April, 1972)  268-278.

       Gamble, Hays, and Roger Downing, "Effects of Nuclear Power Plants on
       Residential Property Values,":  Journal of Regional Science Vol. 22 (1982)
       457-478.

       Grether, David, and Peter Mieszkowski, "The Effects of Nonresidential Land
       Uses on the Prices of Adjacent Housing:  Some Estimates of Proximity Effects,"
       Journal of Urban Economics  Vol 8 (1980) 1-15.

       Mieszkowski, Peter and Arthur Saper, "An Estimate of the Effects of Airport
       Noise on Property Values," Journal of Urban Economics Vol 5 (1978) 425-440.

       Nelson, Jon, "Airport Noise, Location Rent, and  the Market for Residential
       Amenities,":  Journal of Environmental Economics and Management Vol 6 (1979)
       320-331.

       Nelson, Jon, "Airports and Property Values," Journal of Transport Economics
       and Policy, (Jan. 1980) 37-52.

       Nelson, Jon, "Highway Noise and Property Values," Journal of Transport
       Economics and Policy, (May, 1982) 117-138.

       Poon, Larry C.L., "Railway Externalities and REsidential Property Prices,"
       Land Economics Vol 54 (May, 1978) 218-227.
Property Values - 8

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	11-15
pathogen research evaluation

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11-15.  AIRBORNE TRANSPORT OF PATHOGENIC ORGANISMS
A.  Background

    EPA received comments on the SDEIS on the issue of impacts of airborne
    transport of pathogenic organisms.

    The comments center on the following areas:

    1.  Why didn't the SDEIS include an evaluation of the impacts and health
        effects of aerosols from the wastewater  treatment facility on nearby
        populations?

    2.  What does the literature say about pathogen transport and what is EPA
        official policy?

    3.  Does the issue of pathogen transport favor a site for the wastewater
        treatment facility?

    In order to properly evaluate the above mentioned issues, Region I
    requested assistance from the EPA Health Effects Research Laboratory,
    Office of Research and Development, Cincinnatti, Ohio.

    The Health Effects Research Laboratory has conducted a research literature
    review on the subject of potential health risk from wastewater aerosols.
    The PEIS contains a sampling of technical papers on this issue.  The
    conclusions drawn from these studies indicate that the potential for
    airborne transport of wastewater aerosols does exist and has been docu-
    mented to certain distances (up to 800 m.).   However, according to the EPA
    Health Effects Laboratory, less than half of the wastewater aerosols are
    respirable and very few, probably about one  percent are pathogenic.  The
    results of the EPA research do not support any suggested increase in
    illness of residents living near secondary activated sludge treatment
    plants.

    An examination of the research completed to  date concludes there is no
    expected adverse impact on public health from treatment plants located
    near residential areas similar to the proposed Deer Island facility and
    its proximity to residents of Point Shirley.
B.  Conclusions

    Comprehensive investigations conducted on aerosol transport leave little
    doubt that living near a wastewater treatment plant does not present a
    significant microbiological hazard to people.  There is presently no known
    information that would indicate a potential health problem at the plant or
    nearby residential neighborhood.
                                                                       Pathogens - 1

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           Although  research has been  completed at a number of plants around the
           country,  there are  few  treatment plants the  size proposed for  Deer
           Island.   In  order to respond  to the public concern regarding pathogens  and
           their  impact the MWRA might wish to conduct  a  pilot air monitoring program
           for  pathogenic organisms  at the perimeter of the wastewater treatment
           facility  to  verify  that no  potential problem exists.
Pathogens - 2

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The following references are attached for additional information which
supports EPA's position on this issue:


Aerosols from Activated Sludge Plants:  EPA TECHNIGRAM.  Herbert R. Pahren,
Walter Jakubowski, and Leland J. McCabe.

Study of Microbial Aerosols Emitted from a Water Reclamation Plant.  Project
Summary, EPA-600/81-83-013 by Kerby F. Fannin and Standley C. Vana.   Sept.
1983.

Effect of an Activated Sludge Wastewater Treatment Plant on Ambient Air
Densities of Aerosols Containing Bacteria and Virus.  Kerby F. Fannin,
Standley C. Vana and Walter Jakubowski.  Feb. 27, 1985.

Health Risks of Human Exposure to Wastewater.  Project Summary EPA
600-81-81-002.  Mar. 1981.

Wastewater Aerosols and Disease.  Proceedings of a Symposium.  September
19-21, 1979.  Edited by H. Pahren and W. Jakubowski:  EPA.  Office of Research
and Development.
                                                                       Pathogens - 3

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Pathogens - 4

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Office of Research and Development
                                 Aerosols from Activated  Sludge Plants

 Herbert R.Pahren. Walter Jakubowski. and Leland J. McCabe. Epidemiology Division, Health Effects Research Laboratory.
                                           USEPA. Cincinnati. OH 45268
  Many wastewater treatment plants
are constructed in urban areas in close
proximity to residential housing. These
systems  generally  contain  aeration
basins or trickling filters where there is
an 'opportunity for  small  droplets of
wastewater  to  be  emitted.  These
droplets could contain a bacterium or
virus and evaporate very rapidly to yield
droplet nuclei in the size range of 0.5 to
30 microns in diameter. Such panicles
are known as aerosols.
  Numerous persons have investigated
the types of organisms emitted and the
density in relation to distance from the
treatment plant. An overview of  the
subject was published by  Hickey  and
Reist.4 There had also been discussions
of the health significance of working at
a sewage treatment plant, but there
was a paucity of data upon  which to
base  definitive conclusions regarding
health effects.
  The  microorganisms  from   the
treatment plant  travel  passively  with
the wind and their  density decreases
with time and distance as a result of
atmospheric dispersion, loss of viability.
and deposition. The potential for plant
workers and nearby  residents to inhale
viable  organisms  certainly  exists.
However,  there  had  never  been  a
systematic  investigation to confirm or
negate the  existence of a health hazard
from these  viable wastewater aerosols.
    With this background, the Health
Effects Research Laboratory of the U.S.
Environmental   Protection  Agency
arranged for several studies  to gather
information  on  health   effects
associated   with  aerosols  from
uncovered  wastewater  treatment
plants. These studies  were conducted
by  personnel  from  universities  or
research  institutions  and  were
presented at a symposium along with
background information on exposure to
microorganisms in aerosols.2

Epidemiology Studies
  In one study, illness rates of students
at  an  elementary  school,  located
adjacant  to  a  new   advanced
wastewater  treatment  plant,  were
measured by  analyzing  recorded
absenteeism at this school before and
after  start-up  of  the   new  plant.
Attendance at eight nearby schools was
used for  control rates. Microorganism
densities from the plant were measured
and  a daily exposure  index  for the
children   was  calculated.  Detailed
examination  of  school   attendance
patterns for the two year period prior to
the operation of the sewage treatment
plant and the two year period following
operation revealed no differences for
the school next to the treatment plant.
Similar comparisons of attendance  at
this school and the eight other  nearby
schools  showed no differences. The
data provide no evidence of an adverse
health response from the treatment
plant.
  Another  study  involved  the
evaluation  of  residents living  near a
new activated sludge plant for one year
prior to start-up of the plant and one
year following operation.  Over 4.200
persons who lived between C.4 and 5.0
kilometers  from the plant answered
questions regarding their illnesses and
health   status.   Detailed  statistical
analyses  were  then  conducted  to
determine if results could  be related in
any way to the operation  of the plant.
Another  part  of  the  study included
taking clinical  specimens  from  282
persons  near the plant. Environmental
measurements were also  made.
  Although the plant was found to be a
source  of  several   microbiological
indicators, the levels of  the agents in
the air. soil, and water samples in the
neighboring residential areas were not
distinguishable  from  background
levels. Based on questionnaire results
aione, the responses showed a slight
increase in gastrointestinal symptoms
after operation of the plant for persons
living  the  nearest  distance.
Streptococci isolations in the  throat
swabs also increased. In contrast, tests
for  31 viral antibodies and attempted
isolations of many pathogenic bacteria.
parasites,   and  viruses  yielded  no
evidence of an adverse  health effect
from the wastewater treatment plant.
On  balance the overall conclusion was
that the plant did not present a health
hazard for nearby residents.
  Still another  evaluation was made
near a very large plant that had been in
operation  since  1929.  A  health
questionnaire  survey was  made  of
2.378 persons  over  an eight month
period. 318 persons gave paired blood
samples at the beginning and end of the
period, and stool and throat specimens
were collected from children under age
12.
  The plant was found to be a source of
total viable panicles  which were  still
above background  levels 800  meters
downwind.  Tctal  csliforrrs  were  at
background  levels at this  distance.
However,  there was no indication that •
the   microorganisms  resulted  in
increased  illness  rates,  pathogen
isolation rates or increased antibody to
enteroviruses measured.
  In an effon to check persons with the
highest  exposure  to  wastewater
aerosols, and with the best probability
of showing  a response,  studies were
                                                                                                   Pathogens  -  5

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 marie of  wastewater workers.  It is
 recognized that such exposure could be
 due to direct contact with sewage or
 handling equipment contaminated by
 sewage  =»s well  as exposure by means
 of the aerosol route.

  The primary study group consisted of
 about 100 newly employed  activated
 sludge plant-workers in three cities. In
 addition,  various control groups were
 compared and included utility workers.
 sewer maintenance workers, highway
 maintenance  workers,   and persons
 who  worked at  a primary  sewage
 treatment plant.

  Detailed medical  evaluations were
 made of  the  exposed  and  control
 workers as well as families of many
 participants.  The only  difference in
 illness rates among  worker  groups
 which was statistically significant was
 higher gastrointestinal illness between
 inexperienced   workers   and   other
 groups. These gastrointestinal illnesses
 were  mild  arid generally appeared
 within the  first  several  months of
 employment. There was no relationship
 between the occurrence  of illness and
 rise  of antibody liter  for any  of the
 numerous agents checked. An increase
 in infection was not demonstrated by
 culture techniques but serologic tests
• suggested a  slight increase with some
 viruses and bacteria in the wastewater
 exposed  workers.  In the  study  of
 families,  there  were  no  differences
 between the results of the two groups of
 families..
Assessment
  The  comprehensive  investigations
described leave little doubt that working
at or living near a wastewater treatment
plant  does not present a  significant
Microbiological hazard  to the people.
However, it should always  be kept in
mind that sewage contains  potentially
pathogenic agents  and  workers  at
sewage treatment plants should always
maintain good personal hygiene and
sanitation practices.
  Several reasons may  be offered why
the study participants generally did not
become infected  or  ill even though
exposed  to  microbial  aerosols.  1)
Densities of specific  pathogens were
low, and were reduced rapidly with time
and distance  from the source.  2) A
person would ordinarily  inhale very few
organisms  unless constantly e~.pcsed
for many hours. 3) The exposure levels
were  below  the  minimum infective
dose. 4) Microorganisms in wastewater
are  primarily enteric  organisms
whereas the  route of  exposure was
respiratory. 5) Phagocytic cells tended
to respond to the foreign  substance
before  antibody cells were  formed. 6)
Exposed persons were probably in good
health  and better  able to  combat
infection than  would sickly persons. 7)
Infectious  agents  other  than  those
checked   may  have  caused  an
undetected infection.
Cost  Impact
  The most effective and probably only
proven  method to contain microbial
aerosols would be to cover the aeration
basins at an activated sludge plant. This
would be  costly as well as result in
maintenance problems. As  a result of
local   pressure  and   litigation,  all
of the treatment plant units, including
six large retention basins, were covered
at  the  Clavey  Road  Wastewater
Treatment  Plant in  Highland Park,
Illinois. It cost over S8.5 million to cover
those units which was 24 percent of the
total  capital  costs for  expanding the
plant from 4.5 to 18 mgd.' A similar
proposal for  a plant at Des Plames.
Illinois could  have added  10  to  30
percent to  the cost.  If all sewage
treatment plants in the United States
would be  handled similarly, the cost
impact could be nearly S1  billion per
year  at recent rates  of construction
expenditure.  The $3 million research
erpenrtitu'e over s five year period for
the various health effects studies was a
modest  price to  show that aeration
basin covers  are not  necesary as a
national policy to protect public health.
References
1.   Hickey.  J.LS.  and  Reist,  P.C.
    "Health  Significance  of Airborne
    Microorganisms from Wastewater
    Treatment Processes. Pan I: Sum-
    mary  of  Investigations."  Jour.
    Water Poll. Control Fed. 47. 2741
    (1975).
2.   Pahren,  H.R. and Jakubowski. W.
    [Eds.], "Wastewater  Aerosols and
    Disease."  EPA-600/9-80-028.
    U.S. EPA, Cincinnati.  Ohio (1980).
                                                                                 HERL-Ci-303
   Pathogens -  6

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                    United Stales
                    Environmental Protection
                    Agency
Health Effects Research
Laboratory
Research Triangle Park. NC 27711
                    Research and Development
EPA-600/S1-83-013 Sept 1983
&EPA          Project  Summary

                    Study  of Microbial Aerosols
                    Emitted  from  a Water
                    Reclamation  Plant
                    Kerby F. Fannin and Stanley C Vana
                      The purpose of this investigation
                    was to determine the occurrence of
                    selected microorganisms in the air in
                    the vicinity of the O'Hare Water Recla-
                    mation Plant (OWRP), Des Plaines,
                    Illinois. The contribution of the OWRP
                    to ambient microbial aerosols was de-
                    termined by comparing baseline, or
                    preoperational, observations during fall
                    and spring/summer months to those
                    made after operation was initiated.
                    Three sampling sites were  positioned
                    < 150 m. 150 to 250 m. and > 250 m
                    downwind, while one location was up-
                    wind of the center of the two-stage
                    activated sludge aeration  tanks. De-
                    pending upon the wind direction, the
                    first  downwind site was  frequently
                    positioned at < 5 m from the edge of
                    the aeration  tanks, with  the  other
                    downwind sites proportionally nearer
                    to this tank boundary.
                      Air sampling volumes were based
                    upon predetermined sensitivity levels
                    for each group of microorganisms. At
                    each site, murtistaged impactor and
                    slit samplers were used to determine*
                    total aerobic bacteria-containing par-
                    ticle concentrations and particle size
                    distributions In addition, "large volume"
                    air samplers, that  included electro-
                    static precipitator and cyclone scrubber
                    samplers, were used to detect aerosols
                    of standard plate  count organisms.
                    total coliforms,  fecal coliforms. fecal
                    streptococci. Salmonella sp., other or-
                    ganisms within the total coliform group,
                    coliphages of Escherichia coli C3000,
                    and  animal  viruses detectable  with
                    Buffalo green monkey kidney (BGMK)
                    and WI-38 cell cultures.
  Low concentrations of several aero-
bic bacteria species and of certain coli-
phages were present in the air sur-
rounding the newly constructed acti-
vated  sludge plant before operation
was initiated. After plant operations
began at 21 to 67% of its design capac-
ity of approximately  270.00O mVd
[72 million gallons per day (MDG)]. the
frequency of detection of all micro-
organisms  studied increased at the
< 150 m downwind locations. The geo-
metric  mean total aerobic bacteria-
containing particle (TABCP)  concen-
trations, determined with slit samplers,
increased from 59 to 218 colony form-
ing units (cfu)/m3 during the night-
time and from 34 to 57 cfu/m3 during
the daytime. The TABCP concentra-
tions determined with Andersen sam-
plers increased from 125 to 281 cfu/m3
during the nighttime  and from 87 to
234 cfu/m3 during the daytime.
  Using large volume scrubber (LYS)
samplers at the first downwind loca-
tion, standard plate count (SPC) or-
ganism geometric mean concentra-
tions during the fall nighttime increased
from 55 to 1325 cfu/m3 and during
the fall daytime from 49 to 220 cfu/m3.
Increases from 0.30 to 5.03 cfu/m3 for
total coliforms. 0.12 to 1.02 cfu/m3 for
fecal coliforms. 0.14 to 0.66 cfu/m*for
fecal  streptococcus  organisms, and
0.004 to 0.095 most probable number
plaque-forming units (mpnpfu)/ m3 for
coliphages were also  observed at this
first downwind site after operations
started. At 150 to 250 m downwind from
the center of the aeration tanks aerosol
concentrations of total coliforms. fecal
                                                                              Pathogens -  7

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  coliforms, fecal streptococci, and coli-
  phages were significantly higher during
  plant operations than before such opera-
  tions started. When the aerosol concen-
  trations of these organisms at the >250
  m downwind site during  plant opera-
  tions were  compared to preoperation
  concentrations, however, no significant
  (p < 0.01} differences could be detected
  from any grou p except for the coliphages,
    Microbial aerosol  concentrations
  were generally higher during the night-
  time than during the daytime. The total
  coliform bacteria in  aerosols  during
  plant operations were predominantly
  Enterobacter sp., Escherichia sp.. and
  Klebsiella  sp.. respectively.  Animal
  viruses were  detected at <  150  m
  downwind from the center of the aera-
  tion tanks in BGMK but not in WI-38
  cells in two of twelve downwind air
  samples having total assay volumes of
  385 to  428  m3. Of the  three virus
  isolates, two were identified as cox-
  sackievirus B-1. The other virus was
  not identified by the antisera pools
  used.
    The low-level concentrations of mi-
  crobial aerosols observed  before plant
  operations  began did not  increase be-
  yond the perimeter of the  plant on the
  east,  south,  and west sides  during
  plant operations. Depending upon the
  meteorological and diurnal conditions,
  the concentration  of certain  micro-
  organisms could occasionally increase
  beyond the north plant boundary. These
  concentrations, however,  are very low
  {< 1 cfu or mpnpfu/m3)  and  require
  very sensitive methods for detection.
     This Project Summary was developed
  by EPA's Health Effects Research Lab-
  oratory. Research Triangle Park. NC, to
  announce key findings of the research
  project  that is fully documented in a
  separate report of the same title (see
  Project Report ordering information at
  back).

   Introduction
     Population growth  within large urban
   regions necessitates expansion of existing
  wastewater treatment systems  for pro-
  cessing increased volumes of sewage prior
  to utilization or discharge  Locating new
  wastewater treatment facilities in densely
   populated regions, however, requires con-
   sideration of the potential environmental
   and health  effects of their operation. Mi-
   crobial aerosols are  emitted  by waste-
   water treatment processes into  the sur-
   rounding air. Activated sludge treatment
   for example, generates small bubbles by
   diffused air aeration that adsorb and con-
centrate suspended bacteria and viruses
as they rise through the sewage depth in
the aeration tank to the surface boundary.
At this boundary, a surface film containing
microorganisms is disrupted as these rising
bubbles burst releasing tiny aerosol drop-
lets containing  the  bubble-adsorbed, as
well as the surface film-associated micro-
organisms.
  The nearly instantaneous  evaporation
which may occur  as these droplets be-
come suspended in air leaves dried rest-
dues referred to as droplet nuclei that are
subject to downwind dispersion. The sur-
vival and dispersion of the organisms that
may be  associated with these  droplet
nuclei are affected by organism character-
istics and environmental factors such as
relative humidity, temperature, irradiation,
wind velocity, atmospheric stability, and
atmospheric pollutants.

  While processes of wastewater treat-
ment have shown to generate microbial-
laden aerosols that can be carried down-
wind, the occurrence of potentially infec-
tious microbial aerosols per se does not
provide  evidence of associated health
risks. No conclusive evidence is yet avail-
able that demonstrates that persons resid-
ing in the vicinity of wastewater treatment
facilities are subjected to greater health
risks than those who do not dwell in such
areas. Placing such facilities in regions of
high population densities has,  however,
initiated  concerns  regarding the  hearth
implication of exposure to microorganism-
containing wastewater aerosols.
   One such facility, the O'Hare Water
Reclamation Plant (OWRP). located in the
City of  Des  Plaines. Illinois, was con-
structed to  be  operated  as  part of the
regional Metropolitan Sanitary District of
Greater  Chicago (MSDGQ  system  The
proximity of this plant to a residential area
has been the subject of concern over the
past several years because of the potential
for exposure to plant-emitted, microbial
aerosols. Because no data were available
to determine the potential for community
exposure to microbial aerosols that might
be emitted from this plant this study was
initiated to determine the probability of
such exposure over a wide range of envi-
ronmental and meteorological conditions.
   The probability of community exposure
was evaluated by comparing the preopera-
tional, or baseline, plant  site  microbial
aerosol  contribution to the  surrounding
environment to that observed after initia-
tion of  plant operations. This study was
intended to provide data on whether or not
significant increases in microbial aerosols
could be attributed to facility operations
during different seasons and atmospheric
conditions.

Conclusions
1.   When operating at 21  to 67% of its
    design capacity, the OWRP is a source
    of aerosols containing  bacteria  and
    viruses.
2.   Significant aerosol concentration in-
    creases over the baseline at < 150 m
    downwind from the center (or. depend-
    ing on the wind direction, to within 5 m
    from the edge) of the aeration tanks,
    were observed for total aerobic bacteria-
    containing particles,  standard plate
    count organisms, total coliforms. fecal
    coliforms. fecal streptococci, and coli-
    phages. The total coliform aerosols
    identified were predominantly Entero-
    bacter sp.. Escherichia sp., and Kleb-
    siella sp. Animal viruses from assay
    volumes ranging from 385 to428 m3
    in two cell culture lines were detected
    in two of twelve downwind air samples.
    Of three virus isolates, two were identi-
    fied as coxsackievirus B-1 and the third
    was not  identified with the antisera
    pool used.
3.   At 150 to 2 50m downwind from the
    center of the aeration tanks,  no sig-
    nificant increases in microbial aerosol
    concentrations were observed during
    the daytime after the plant began oper-
    ations. When considering both daytime
    and nighttime samples,  however, sig-
    nificant increases were observed for
    total coliforms, fecal coliforms. fecal
    streptococci, and coliphages The con-
    centrations of these organisms at  150
    to 250 m downwind sites decreased
    substantially from those observed at
    the <  150  m downwind locations
    during plant operations These concen-
    trations decreased by  85%  (5.0 to
    0.77 cfu/m3) for total  coliforms. by
    76% (1.02 to 0.24 cfu/m3) for fecal
    coliforms. by 33% (0.66 to 0.44
    cfu/m3) for fecal streptococci, and by
    68% (0.004 to 0.002 mpnpfu) for
    coliphages.
4.  Aerosol concentrations did not signifi-
    cantly increase after the plant began
    operations for any bacteria studied at
    sampling distances beyond 250 m
    downwind from the center of the aera-
    tion tanks The frequency of detection
    did. however, increase from 38 to 79%
    for total coliforms. from 0 to 63% for
    fecal coliforms and from 69 to 89% for
    fecal streptococci. Coliphage concen-
    trations were, however, significantly
    higher and their frequency of detection
    increased from 22 to 86% after the
    plant began operations.
Pathogens  -  8

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5.  Baciena aerosol concentrations were
    directly related to sewage flow rate
    within 1 50 m downwind of the center
    of the aeration tanks during the fall
    season of  plant operations, but, at
    downwind locations greater than 150
    m downwind, inverse correlations were
    observed at night
6.  During plant operations, bacteria aero-
    sol concentration was directly related
    to wind velocity during the  spring/
    summer season at locations <250m
    downwind of the center of the aeration
    tanks. Before operations, negative cor-
    relations were found at upwind and
    150 to 250 m downwind locations.
7.  Bacteria aerosol concentrations were
    directly related to temperature at loca-
    tions within 150 m downwind of the
    aeration tanks during plant operations
    At nighttime, however, negative corre-
    lations were observed at locations >
    250 m downwind and  upwind.
8.  Bacteria aerosol concentrations were
    generally inversely related to relative
    humidity.
9.  Fecal streptococci and coliphages ap-
    pear to be more stable in aerosols than
    the other indicator bacteria studied
10. Low-level concentrations  of bacteria
    and coliphages were present in the air
    in the vicinity of the OWRP before the
    plant  began operations. These con-
    centrations did not increase beyond
    the perimeter of the plant on the east
    south, and west sides during  plant
    operations. Depending upon the me-
    teorological and  diurnal conditions,
    the concentration of certain micro-
    organisms could occasionally increase
    beyond  the north plant  boundary.
    These concentrations,  however, are
    low (<  1  cfu  or mpnpfu/m3). and
    require  very sensitive  methods for
    detection.

Recommendations
1. Selected microbial aerosol parameters
   should be  monitored at the OWRP
   boundary during the nighttime when
   the plant begins operation at full capac-
   ity. These data  should then be com-
   pared  to the baseline  observations
   made in this study to determine wheth-
   er significant concentration increases
   occur at higher  sewage flow rates.
2. Coliphages and fecal streptococci ap-
   pear to be stable  as aerosols and are
   recommended as  indicators of poten-
   tial sewage-borne aerosol  contamina-
   tions.
  This report was submitted in fulfillment
of Grant No. R-806062 by IIT Research
Institute and The  Institute  of Gas  Tech-
nology under the sponsorship of the U.S.
Environmental Protection  Agency. This
report covers a period from July 24,1978
to June 30. 1981.  and work was com-
pleted as of October 31, 1981.
  Kerby F. Fannin is with the Institute of Gas Technology, Chicago. IL 606 J 6, and
    Stanley C. Vana is with the IIT Research Institute. Chicago. IL 60616.
  Walter Jakubowski is the EPA Project Officer (see below/.
  The complete report, entitled "Study of Microbial Aerosols Emitted from a Water
    Reclamation Plant." (Order No. PB 83-234  906; Cost: $14.50.  subject to
    change} will be available only from:
          National Technical Information Service
          5285 Port Royal Road
          Springfield. VA 22161
          Telephone: 703-487-4650
  The EPA Project Officer can be contacted at:
          Health Effects Research Laboratory
          U.S. Environmental Protection Agency
          Research Triangle Park. NC 27711
                                                   OOHRNMINI
                                                                    I983-6S9-OI?' JI9J
                                                                                                       Pathogens -  9

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Pathogens - 10

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        »ND ENVIRONMENTAL MICROBIOLOGY. Mav 19K5. p  1191-11%
             w-(*sn:.oo/n
             ^' American Society for Microbiology
                                          Vol. -W. No. 5
      Effect of an  Activated Sludge  Wastewater Treatment  Plant  on

  Ambient Air Densities of Aerosols Containing  Bacteria and Viruses

                  KERBY F. FANNIN.1' STANLEY C. VANA.: AND WALTER JAKUBOWSKl'
  Life's Resources, Inc., Addison. Michigan 492201; Life Sciences Department. I/T Research In.iiitnie. Chicago. Illinois
 60t>lt>~'. find Toxicology and Microbiology Division. Health Effects Research Laboratory. U.S. Environmental Protection
                                         Afency. Cincinnati. Ohio 45268*

                                 Received :6 December 1984/Accepted 27 February 1985

          Bacteria- and virus-containing aerosols were studied during the late summer and fall seasons in a midwestern
        suburb of the L'nited Slates before and during the start-up and operation of an unenclosed activated sludge
        wastewater treatment plant. The study showed that the air in this suburban area contained low-level densities
        of indicator microorganisms. After the plant began operating, the densities of total aerobic bacteria-containing
        particles, standard plate count bacteria, total coliforms, fecal coliforms,  fecal streptococci, and  coliphages
        increased significantly in the air within the perimeter of the plant. Before plant operations, bacteria were
        detected from  five  genera, Klebsietta, Enterobacter, Serratia, Salmonella, and Atromonas. During plant
        operations, the number of genera identified increased to 11. In addition to those genera found  before plant
        operations, Escherichia, Providencia, Citrobacter, Acinetobacter, Pasteurella, and Proteus, were also identified.
        Enteric viruses were detected in low densities from the air emissions of this plant. Only standard plate count
        bacteria remained at significantly higher than base-line densities beyond 250 m downwind from the center of
        the aeration tanks. Fecal streptococci and coliphages appeared to be more stable in aerosols than the other
        indicator microorganisms studied. In genera), the densities of microorganism-containing aerosols were higher
        at night than during the day. The techniques used in this study may be employed to establish  microorganism-
        containing aerosol exposure during epidemiological investigations.
  Aerosols that contain microorganisms are generated
through natural processes. Such microorganism-containing
aerosols occur widely in nature and are generated  in the
oceans by wave action (5. 6) and on the land when wind
suspends decaying vegetative debris through  soil erosion
(24). Microorganism-containing aerosols are reportedly ca-
pabie of very long-range transport (6). Some of these aero-
sols can contain microorganisms  pathogenic to humans as
well as to agricultural livestock and crops.
  Many other sources of microorganism-containing aerosols
are. however, generated through human activities in both
urban and rural  areas (8. 9). Population growth in urban
areas has increased  the  density of domestic wastes which
must be disposed of in a safe and environmentally sound
manner. Consequently, expansion of existing  waste treat-
ment or utilization facilities is necessary.  Some of these
facilities have, however, been shown to emit  microorgan-
ism-containing aerosols  under certain condiiions. Sewage
treatment  plants (1. 20),  sanitary landfills and resource
recovery systems (17).  and  compost operations (18). for
example, have all been considered as potential sources of
airborne infectious microorganisms. Because of economic.
environmental, or political constraints, some of these facil-
ities  are located in densely populated regions  of urban or
suburban communities. In these cases,  a determination of
the contribution of the facilities to the microorganism con-
tent  of the ambient air may allow an evaluation  of the
potential for adverse health or environmental effects.
  One  such facility, the O'Hare Water  Reclamation Plant.
located near the O'Hare International Airport in the City of
DesPlaines. III., a suburban area northwest of Chicago, was
constructed to be operated as pan of the regional Metropol-
itan Sanitary District of Greater Chicago system. The prox-
imity of this plant to a residential area was the subject of
concern for several  years because of the potential for
exposure of the surrounding population to  microbial aero-
sols emitted from the plant. The purpose of this study was to
determine the contribution of the newly constructed plant to
the base-line microbial aerosol densities that already existed
in the vicinity of that plant. The results reported here were
pan of a larger study of microorganism densities in air at the
wastewater treatment plant site
  * Corresponding author.
             MATERIALS AND METHODS

  Field sampling approach. (!) Study site and sampling loca-
tions. The O'Hare Water Reclamation Plant was designed as
a 272.000 m' (>2 x  10" gallons per day (MOD) capacity
two-stage municipal sewage  plant. The dimensions of the
two-stage aeration basins, including walkways, were ca. 160
by 200 m. The microbial aerosol densities reported in this
paper were  determined  during the late summer and  fall
season in the vicinity of this plam before it was operated and
again during a similar  season after it began operating. The
first sampling season was from 15 August to 7 November the
year before the plant was started, and the second was from
26 August to 12 November  during the first year of plant
operations.
  Aerosol sampling sites were located at various distances
downwind «150. 150 to 250. and >250 m) or upwind of the
center of the aeration tanks. As shown in Fig. 1. this center
was positioned ca. 80  m from the north and south aeration
tank boundaries and  ca.  100 m from the east  and west
boundaries of the first-  and second-stage  aeration tanks.
respectively.  This location was also ca. 120 m from the
northwest and southwest corners of the second-stage aera-
tion tanks and about the same distance from the northeast
and southeast comers  of the  first-stage aeration tanks.. The
sampling sites in closest proximity to the aeration tanks were
                                                         7*-
                                                                                                  Pathogens  -  11

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             FANNIN. VANA. AND JAKUBOWSKI
                              APPI . ENVIRON. MICROBIOI
     OAKTON STREET
                                              MARSHALL ROAD
                                         WILLE ROAD

       FIG. 1. O'Hare Water Reclamation Plant.  Sampling distances
     with respect to center of aeration tanks.
     located <150 m downwind  from the  center of the tanks.
     Since the exact location of  these sites was determined by
     physical accessibility, many samples were taken near or at
     the aeration tank boundary.
       (ii) Air sampling methods. Sampling instrumentation and
     procedures were selected with the goal of determining the
     density of microbial aerosols  of potential  public health
     significance.  The organisms  sampled, the sampling devices
     used, and the reporting units for the organisms studied are
     listed in Table 1. Air  samples were taken during the day
     (0800 to  1959 h)  and  night (2000 to 0759  h)  by using
     multistaged impactors (MSI) (3) and large-volume scrubbers
     (LVS) (12) at each of the four general locations with respect
     to the center of the  aeration tanks.
       Total aerobic bacteria-containing particle (TABCP) sam-
     ples were taken at an air sampling rate  of ca. 0.03 m'/min by
     using MSI samplers (Andersen. Inc.). These samplers were
     swabbed with 70% ethanol and loaded with six glass plates
     containing 27 ml of Trypticase soy agar (BBL Microbiology
     Systems) with 0.01 to 0.02% cycloheximide and coated with
     0.2% oxyethylene docosanol green), to reduce desiccation.
     Samples of  standard plate  count (SPC) organisms, total
     coliforms (TC). fecal coliforms (FC). fecal streptococci (FS).
     coliphages (CP). and enteric viruses (EV) were taken with
     LVS at air  sampling  rates of 0.6 to 0.9 mVmin.  These
     samplers were sterilized by conventional autoclaving before
     field use. The sampling fluids  used were Trypticase soy
     broth (25%) for SPC organisms. TC. FC.  and FS: dulcitol
     selenite broth (50%) for Salmonella sp.: phage assay broth
     (25%) for CP; and Hanks balanced salt solution with 2S9c
     nutrient broth  for  EV.  Particle-laden sampling  fluid  was
     aseptically collected in serum-stoppered bottles. The fluid
     was recirculated during sampling for EV. and evaporation
     losses were replaced with sterile distilled water. Collected
     samples were maintained on wet  ice  during sampling and
     transport.
       Assay and  enumeration. When available, standard meth-
     ods for assay and enumeration were  those previously de-
     scribed (2).  The standard membrane  filter procedure  was
     used for TC.  FC. and FS assays, and the SPC procedure was
     used for SPC organism determinations. Selected TC colonies
     were identified by using API  20E strips (Analytab. Inc.) with
     the oxidase test.
       Assays for Salmonella sp. and CP were performed in
     enrichment tubes and were  enumerated by using the most-
probahle-numher (MPN) method for estimating the density
of Sfruill  numbers  of microorganisms in fluids.  CP  were
assayed on ExHicrirhia cnli C3000 cells as previously de-
scribed  (11).  Salmonella cells  were enriched in  dulcitol
selenite broth at 40°C for 24 h and then streaked onto xylose
lysine  desoxycholate  acar  as previously described  (16).
Black colonies observed  after 24 h of incubation  at  37°C
were identified with the API system.
  Samples for EV assay were sonicated (model W-375: Heat
Systems-Ultrasonics. Inc.).  filtered through 0.2-p.m heat-in-
activated fetal calf serum-pretreated  membrane filters and
divided into two portions. The first portion was assayed for
cytopathic  effect. If (his portion was  negative, then the
second  portion was also assayed  for  cytopathic effect.
Otherwise, the second portion was assayed by the plaque
method.
  EV assays were  performed on  Buffalo Green  Monkey
Kidney  and  Wl-38 cell  monolayers. Cell cultures  were
grown at 37°C in minimum essential medium with 10% fetal
calf serum and antibiotics (gentamicin. 50 tig/ml: amphoteri-
cin  B  [Fungizone], 2.5  u,?Anl).  Cells  were washed  with
Hanks  balanced salt solution, inoculated with sample, and
rewashed after a 2-h virus adsorption period. The inoculated
cultures were then overlaid with either liquid- or agar-based
minimal  essential  medium and  assayed as previously de-
scribed (10). Virus isolates were identified by serum neutral-
ization by using pooled enterovirus antisera.
  Quality assurance. Before use and periodically throughout
the  project, each sampler was calibrated to determine air
flow rates  by using a precalibrated mass  flow  meter or
anemometer. These samplers were numbered, and collected
samples were identified with a particular instrument. Field
loading  and  unloading of  MSI  was monitored  by using
control agar plates. LVS and MSI were autoclaved at 12TC
for 15 min.
  During  sample  assay,  two  negative  and two  positive
organism control assays were performed for each field trial.
For the positive controls, suitable dilutions of Enterobacter
aerngenes. Escherichia coli. Streptococcus faecalis. Klebsi-
tlla pneunioniae. Salmonella enteritidi.t. MS-2 phage. and
poliovirus type 1 were used forTC. FC. FS. Klebsiella sp..
Salmonella sp.. CP. and EV tests, respectively.  Periodic
bacteria  assays for SPC  organisms with tryptone  glucose
extract by the spread plate procedure on Trypticase soy agar
were used  to confirm the SPC technique and the TABCP
medium. Plates used for TABCP determinations were incu-
bated at 35°C for 24 h  before  use and  discarded upon
evidence of colonial growth.
  To minimize the  possibility of cross-contamination,  posi-
tive control assays were performed after sample assays. In
     TABLE 1.  Microorganism-containing aerosol sampling
Microorganism*
TABCP
SPC
TC
FC
FS
Salmonella sp.
CP
EV
Sampling
device
MSI
LVS
LVS
LVS
LVS
LVS
LVS
LVS
Air viil
umploJ
(m'l
O.S-1.7
0.8-1.7
5-10
io-:o
io-:o
30-60
30-60
4IXWNK)
Units
CFU
CPU
CFU
CFU
CFU
MPN VU"
MPN PFU
CPU"
  • Vf. Viahlc umiv
  * CPL'. Cylopalhogcmc unils.
Pathogens  - 12

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VOL. 49. 1985
                                                       AEROSOLS CONTAINING BACTERIA AND VIRUSES
                                                                                        1193
addition, positive EV control assays were always performed
in a separate laminar  flow' hood from that  used for sample
assays. Virus isolates were stored at  -70°C  in a locked
freezer containing no other virus stocks.
   Data analyses. Data were analyzed to test the hypothesis
that the densities of the microorganism-containing aerosols
studied were  not  significantly different after  the O'Hare
Water Reclamation Plant began  operations than  were ob-
served in the ambient  air at the site of the future plant. The
nonparametric Mann-Whitney U test was used for determin-
ing significance at the P < 0.01 level (22. 23). Geometric
means were weighted by pin. where p  was the number of
positive observations and n was the total number of obser-
vations. This weighting procedure was similar to that de-
scribed by Snedecor and Cochran (23).

                       RESULTS
   During the late summer and fall after the plant  began
operating  the sewage  flow  rates  ranged  from 56.100 to
183,000 m}/day (14.8 to 48.4 MGD) during aerosol sampling.
The average flow rate was  106.000 mVday (27.9 MOD). A
total of 738 assays were performed for  TABCP. SPC. TC.
FC. FS, and  CP organisms among the four sampling loca-
tions during the fall  seasons of this study. Of the 316 assays
performed before plant  start-up. 29. 28. 28. and \&7c were
from the upwind. <150-m-downwind. 150- to 250-m-down-
wind. and >250-m-downwind locations, respectively. Of the
422 assays performed after the plant was started. 30, 31, 24.
and \S7c were from those respective locations. Of the 30 EV
assays. 12 were performed before and  18 were performed
after the plant was  started. One-half of these assays were
performed  from the  <150-m-downwind and the upwind
locations.
   SPC. The geometric mean aerosol densities of SPC bacte-
ria are shown in Table 2. The downwind densities increased
significantly during the night  at  all downwind  sampling
locations after the plant began  operating.  At the <150-m
sampling location the increase was from 55 to  1.325 CFU/m'
(P < 0.001). at the 150- to 250-m location the increase was
from 65 to 410  CFU/m3 (P <  0.01). and at the >250-m
location the increase was from 60 to 262 CFU/m3 (P < 0.01)
after the  plant began operating. Significant increases were
not observed during the daytime at any  location.
   TABCP.  TABCP aerosol densities (Table 2) were gen-
erally  lower  than those observed  for the  SPC  bacteria
during plant operation, suggesting that aerosolized  particles
                                         TABLE 2.  Aerosol densities of SPC bacteria and TABCP

                                                                 Dcnxilv iCFU.m'i
                                       Microorganism*     Upwind
                                                                       Downwind imi
                                                                          150-2JO
                                                    DJV  Night  Day  Nifhi  Day  Night  Djy  Nifhi

                                      SPC bacteria
                                       Preoperaiion    43   26    49    55   32   65   52    60
                                       Posioperation  157  297   220  1.325  102  410   194   262

                                      TABCP
                                       Preoperation   141   76    65   102  113  104   163   270
                                       Postoperaiion   79   52   272   373  115  175   194   191
                                     contained multiple organisms. After plant operations com-
                                     menced, significant geometric mean density increases (P <
                                     0.001) were observed during both the day (65 to 272 CFU/m3)
                                     and night (102 to 373 CFU/m3) at the <150-m-downwind
                                     location, but were not observed at further downwind loca-
                                     tions. The upwind  and  most distant downwind locations
                                     were sometimes (depending  on  the prevailing wind direc-
                                     tion) downwind from heavy road traffic, which contributed
                                     dust to  the area and could have  increased the  density of
                                     TABCP aerosols at those  sites, especially during daytime
                                     rush-hour periods.
                                       TC. TC geometric  mean  densities  (Table 3) increased
                                     significantly (P < 0.01)  from 0.27 to 5.17 CFU/m3 at the
                                     <150-m  location  during the  night after  the  plant began
                                     operations. During the day, these densities increased from
                                     0.24 to 6.81 CFU/m3. These differences were substantial but
                                     were not accepted as significant  (P = 0.026). The increases
                                     of from 0.18 to 0.57  CFU/m3  during the night and from 0.28
                                     to 0.86 CFU/m' during the day at the 150- to 250-m-down-
                                     wind locations were not significant. The densities  beyond
                                     250 m downwind and at  upwind locations did not  increase
                                     significantly during either the day or night after plant oper-
                                     ations started.
                                       FC. No FC-containing  aerosols were  detected  during
                                     either the day or night before the plant began operating.  As
                                     shown in Table 3. the densities of these  bacteria increased at
                                     all downwind  locations  after the plant began  operating.
                                     During plant operations, the  weighted FC aerosol densities
                                     were 0.01 CFU/m' upwind of the plant during both  the day
                                     and night. At night the geometric mean densities were 2.09,
                                     TABLE 3.  Aerosol densities of TCFC. and FS
 Microorcanisrm
                                                            Density (CFt'/m'l
                           Upwind
                                                                         Downwind (ml
                                                                           IJO-^O
                      Day
             Niphi
                                              Div
                         Nifhi
                         Day
                         Nifhi
                          Day
                         Night
TC
  Preoperaiion
  Postoperaiion

FC
  Preoperaiion
  Posiope ration

FS
  Preope ration
  Posioperation
 0.21
 0.22
<0.04
 0.01
 0.13
 0.04
 0.28
 0.09
<0.06
 0.01
 088
 0.83
 0.24
 6.81
<0.03
 1.67
 0.04
 0.29
 0.27
 5.17
<0.06
 2.09
 0.70
 2.07
 0.28
 0.86
<0.04
 0.18
 0.14
 0.15
 0.18
 0.57
<0.06
 0.64
  1.00
  1.21
 0.22
 0.40
<0.03
 0.29
 0.06
 0.48
 0.12
 0.34
<0.06
 0.15
 0.58
 0.86
                                                                                                  Pathogens -  13

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       11V4    FANMN. VANA. AND JAKLBOWSKI


                    TABLE 4. Aerosol density of Cl>
                                     (MI'N ITl m250-m-downwind locations, respectively. Daytime densi-
       ties at the <150- and 150- to 250-m-downwind locations (1.67
       and  0.18  CFU/m\ respectively) were  lower than those
       observed at night. At the most distant downwind locations.
       the density was 0.29 and 0.15 CFU/rrr during the day  and
       night, respectively.
         FS. FS densities  were consistently higher at night than
       during the day at  all sampling locations both before  and
       during plant  operations.  Night densities before  the plant
       began operating were higher than those observed during the
       day during plant operations at all sampling locations. Back-
       ground FS geometric mean densities (Table 3) ranged from
       0.04 to 0.14 CFU/m' during the  day and from 0.58 to  1.00
       CFU/'m3 during the night at all downwind locations. After
       the plant began operations, night densities ranged from  0.86
       to 2.07 CFU/m' at the >250- and <150-m-downwind loca-
       tions, respectively.
          Members of the family Enterobacteriactae. The diversity of
       bacterial isolates identified from TC  aerosols increased after
       the plant began operations. Before plant operations, bacteria
       were detected from five genera:  Klehsiellu. Enieruhuiter.
       Serrutia. Salmonella, and Aeronwnux. During plant opera-
       tions, the number of genera  identified increased to 11. In
       addition to those genera found before plant operations, the
       genera Escherichiu. Provident-id. Citrohucier. Acinetttbur-
       ter, Pusteiirella and Proteus were also identified.
          Before plant operations, the genus Entrrnhucter consti-
       tuted 80Cr or more of the bacteria identified from each of the
       four sampling locations. Enierobacter agghmeram was the
       most frequently identified species  at all  locations. Other
       species were identified with  extremely low frequency. For
       example. Klehsielln pneiimtinitie. Klebsiella ozaenue. and
       Klebsietla luyim-a were  each detected with low frequency
       (on two or fewer occasions)  before the plant began opera-
       tions.
          During plant  operations,  the  most frequently  isolated
       genera were Escherichia followed by Enterohucter. Klehsi-
       elln. and Citmharter. Most of these isolates were found in
       aerosols <150 m downwind of the center of the  aeration
       tanks. A total of 889£ of the  Klebsiella. 969i of the Esche-
       richia. and 929£ of the Entenibacirr isolates were identified
       at downwind locations closer than 250 m.  The most  fre-
       quently  isolated Klehsiellu  species was  K. pneumonia*.
       followed by K..os\toca.
          Salmonella sp. Before  plant operations,  one isolate,  con-
       firmed as Salmonella clmlerae w'as detected within 150 m
       downwind of the center of the future aeration tanks. During
       plant operations. Salmnnclln sp.-containing aerosols  were
       detected  on one  occasion  at  <150 m.  and on another
       occasion Salmonella ptiratyphi was identified in samples at
        150 to 250 m downwind of the center of the aeration tanks.
          CP. The CP aerosol  density  increased at  all sampling
        locations during plant operations. As shown in Table 4. the
        CP geometric  mean density increased significantly (P <
        001) from  5.0 x  10"'  MPN PFU/m' to 7.3 x 10': MPN
                              Aw.. ENVIRON. MK HOHICII .


PFU/m' al  the  <150-m-downwind  location after the plani
began opcraiing.  The  CP  density  was also significantly
higher at 150 to 250  m downwind  after as compared with
before starting plani operations. CP densities were highest at
the >250-m-downwind locations both before and after start-
ing plant operations  at 2.8 x  10": and 7.6 x 1()': MPN
PFU/m'. The background  density  after  plani  operations
began was increased by  the  high CP density  thai was
observed in the single positive sample. Nevertheless, signif-
icant differences  could not be  accepted  using the  data
analyses procedures employed in this study.
  EV. No EV were detected before the initiation of plant
operaiions in air sample volumes ranging up to 552 m'. After
the initiation of plant operations. EV were  detected on two
of nine  occasions. No viruses were detected during the
daytime in  air sample volumes of  up to 428 m\ The two
occasions on which EV were detected were during the night
within 150  m of the  operating  aeration tanks. The general
wind direction on both occasions was from the south at ca.
4 to 5 m/s. These viruses were detected in Buffalo Green
Monkey Kidney  but  not in WI-38 cells from air sample
volumes of 211 and 193 m\ respectively. When detected, the
EV density ranged from 4.7 x 10'' to 1.0 x 10~: CPU/m' of
air. Although one virus isolate was not identified with the
Lim-Benyesh  Melnick antisera  pool,  the  two  remaining
viruses  were  both identified as coxsackievirus B-l.
   Aerosol particle size. The size of bacteria-containing aero-
sols was greater after the plant began operating compared to
pre-operations. Although  the  aerodynamic count median
diameter of TABCP was  generally in the  3.3- to 4.7-jim
range, the  percentage of the  particles counted that was
below 3.3 jim decreased at all downwind sampling locations
after the plant operations began. The cumulative percentage
of these aerosols decreased from 38 to 24.40 to 26. and 45 to
26 at downwind locations of <150.  150 to 250. and >250 m.
respectively.  The percentage of aerosols in this smaller size
range remained relatively unchanged in the  samples taken at
the upwind locations.

                     DISCUSSION

   The air  near residential environments is not sterile but
contains microorganisms,  some of potential enteric origin.
which have  unknown significance to human health and
welfare. The air  of  the suburban environment  of a major
U.S. midwestern metropolitan area, for example, contained
microorganisms of potential enteric origin before initiation
of operations at  a major wastewater treatment plant site.
Densiiies.of these microorganisms  in the air were generally
highest during  the night. Of the indicator bacteria studied
during  the late summer and early  fall season before plant
operations. FS observed in the night had the highest densi-
ties, with geometric means ranging from 0.58 to 1.00 CFU/m'.
TC ranged from 0.12 to  0.28 CFU/m'.  but no FC were
detected in air sampling volumes  of 10 to 20 m'. Enteric
 bacteria from five genera. Klch.iicllu. Enierohafter. Semi-
tin. Stiliniiiielln. and Aenmwnus. were identified. The geo-
 metric  mean densities of TABCP  ranged from  65 to 163
 CFU/m' during the day and from 76 to 270 CFU/m' during
 the night over four different sampling locations.  SPC bacte-
 ria densities were lower, ranging  from 32 to 51 CFU/m
 during  the day and 29 to 65 CFU/m' at night. The densities
 of the  TABCP aerosols  were within the same order  of
 magnitude as those  observed in the suburbs of an eastern
 metropolitan area, which had a geometric mean of 79 CFU/
 m' (151.
Pathogens -  14

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Voi .
                                                         AEROSOLS CONTAINING BACTERIA AND VIRUSES
  The source*  ol' microorganism-containing aerosols are
muliiplc jnJ may include natural processes :is well us those
produced by human activities.  One such activity, thai of
wastewater treatment, increases the aerosol density of cer-
tain microorganisms above those observed in the absence of
such a plant. After starling the operation of a wastewater
treatment plant, the creates)  increases in  the densities of
SPC. TABCP. TC. FC. FS. CP. and EV were observed at
downwind locations closest  «150 m) to  center of the
aeration tanks. Many of  these samples were within a few
meters of the edge of the tanks. The densities of all of the
microorganisms  studied decreased  at 150-  to 250-m-down-
wind sampling locations. Although these densities remained
above the pre-plant-operaiion levels, significant (P < 0.01)
increases at locations beyond 250 m downwind  were  only
observed for the SPC bacteria.
  The occurrence of potentially infectious microbial  aero-
sols per  se does not provide evidence of associated health
risks. Several studies on the health of populations living near
wastewater treatment processes did not demonstrate signif-
icant adverse health effects due to exposure to wastewater-
generated  microorganism-containing aerosols  (20). These
studies,  however,  all had major  limitations that made it
difficult  to  attach  significance  to  either the  positive  or
negative findings.  There  were low  numbers of  persons
subject to exposure to high doses of microbial aerosols, and
the rate of this exposure throughout the population could not
be adequately and quantitatively determined (14). Further-
more, the epidemiology of exposure to microbial aerosols in
heterogeneous and mobile communities is largely affected by
the secondary exposure rate and by the susceptibility of the
population.
  The possibility of exposure to higher densities of microbial
aerosols in a suburban environment are greater during the
night than during the day. These higher densities observed
during the night indicate  either increased  microorganism
survival  rates or greater atmospheric stability, or both. The
data clearly demonstrate that daytime sampling of the envi-
ronment for microorganism-containing aerosols will result in
underestimation  of the densities to which a population may
be  exposed at  night.  Since the  highest ambient airborne
microorganism densities occur at night, any efforts to deter-
mine maximum exposure rates or to limit or control expo-
sure will be most effective when employed during that  time
period.
  Higher densities  of SPC  bacteria  than  of TABCP  at
downwind locations during plant operations demonstrate the
differences of assaying bacteria and bacteria-containing par-
ticles. If the particles contain multiple bacteria, enumeration
for SPC  bacteria will promote disassociation of these organ-
isms. The data suggest that more bacteria were associated
with airborne panicles during plant operations than before
such operations  began.
  This  study documents  the  first  reported  isolations  of
enterovirus-containing  aerosols from outdoor secondary
wastewater treatment  processes. EV were, however,  only
detected at the  ,<150-m-downwind sampling locations and
only at  night. Other investigators have reported low-level
enterovirus densities around.spray irrigation facilities (19.
25) and  in enclosed secondary treatment  processes  (21).
Earlier studies demonstrated that the aerosol density of EV
around  wastewater  treatment processes is  very low com-
pared with indicator bacteria  and CP and  that detection
requires sampling  methods with high sensitivities (10. 12).
   Both  CP (10) and FS (7) have been suggested as possible
indicators of the potential for  microbial aerosol contamina-
 tion from  wastewater treatment processes. CP.  which in-
 creased at all Uounuind locations after plant start-up, have
 been shown to be  more  stable than coliform bacteria  at
 distant locations from the  source (10). The CP. f2. was also
 demonstrated to be more  stable than  bacteria during treat-
 ment with chlorination and were detectable at distances up
 to 137 m downwind (4). These CP have  also been demon-
 strated to  be more stable in wastewater aerosols than are
 polioviruses (K. F. Fannin. S. C. Vana. and R. Ehrlich.
 Abstr.  Annu. Meet. Am. Soc. Microbiol. 1981. Q115.  p.
 219). suggesting that they  may survive in aerosols to travel
 to greater distances than certain EV.
  The data from the present study indicate that CP are stable
 in aerosols, with the highest densities observed at distances
 of >250 m downwind from an operating wastewater treat-
 ment plant. The FS also demonstrated greater stability than
 (he other indicator bacteria at these downwind locations, but
 showed  marked  differences in  densities  between day and
 night.  Although  these data support the conclusions  that
 certain FS and CP organisms could be used as indicators.of
 domestic wastewater treatment plant aerosols, the relatively
 high background densities of  FS. especially  at  night, in-
 crease the difficulty in determining the originating source of
 these bacteria. Whereas the sensitive detection of appropri-
 ate indicator organisms do not  indicate densities of patho-
 gens, it can measure the potential for airborne contamination
 and could serve as a measure of exposure for epidemiolog-
 ical studies.

                  ACKNOWLEDGMENTS
  The cooperation of the City of Des Plaines. 111., the Metropolitan
.Sanitary District of Greater Chicago, and the Institute of Gas Tech-
 nology is gratefully acknowledged. The programming assistance of
 Wludyslawa Toczycki. the encouragement of James Feniers. and the
 technical assistance of Paul Andressen. Charles  Cradle. William
 Mega, and Dennis Sullivan are appreciated. Although the research
 described in this article has been funded in pan by the U.S. Envi-
 ronmental Protection Agency through grant  R-806062  to the 1IT
 Research Institute, it has not been subjected to the Agency's review
 and therefore does not necessarily reflect the views of the Agency
 and no official endorsement should be inferred.
                   LITERATURE CITED

 1. Adams. A. P.. and J. C. Spcndlove. 1970. Coliform aerosols
    emitted by sewage treatment plants. Science 169:1218-1220.
 2. American Public Health Association. 1973. Standard methods for
    the examination of water and  wastewater.  Uth ed. American
    Public Health Association. Washington. D.C.
 3. Andersen. A. A. 195K. New sampler for the collection, sizing.
    and enumeration of viable airborne  panicles. J.  Bacteriol.
    7«:471-»84.
 4. Bausum. H.  T., S. A. Schaub.  K. F. Kenron. and M. J. Small.
    1982. Comparison  of coliphage and  bacterial  aerosols at a
    waslewaler  spray irrigation site. Appl.  Environ.  Microbiol.
    43:28-38.
 J. Ba>lor. E. R.. V. Peltrs. »nd M. B. Baylor. 1977. Waler-lo-air
    transfer of virus. Science  197:763-764.
 6. Bnvallius. A.. B. Bucht. R. RofTty. *nd P.  Anas. 1978. Long-
    range air transmission of bacteria. Appl. Environ.  Microbiol.
    35:1231-1232.
 7. Crawford. G. V.. and P. H. Jones. 1979. Sampling and differen-
    tiation techniques for airborne organisms emitted from waste*li-
    ter. Water Res. 13:393-399.
 8. Cronholm. D. S. 1980. Potential health hazards from microbial
    aerosols in densely populated urban regions. Appl. Environ.
    Microbiol. 39:6-12.
 9. Dutkitwkz. J. 1978. Exposure to dust-borne bacteria in agricul-
    ture.  I.  Environmental  studies.  Arch.   Environ. Health
                                                                                                       Pathogens  -  15

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      11%    FANNIN.  VANA.  AND JAKUBOWSKI
                                  APPL. ENVIRON. MICROBIOL.
         33:250-159.
      10. Fannin.  K.  F..  J.  J.  Cannon.  K. C. Cochran.  and J. C.
         Spendlovc. 1977. Field  studies on coliphages and coliforms as
         indicators of airborne animal viral contamination from wastcwa-
         ter treatment facilities.  Water Res.  11:181-188.
      11. Fannin.  K. F.. J. C. Sprndlove. K. W.  Cochran. and J. J.
         Cannon. 1976. Airborne coliphages  from wastewater treatment
         facilities. Appl. Environ. Microbiol. 31:705-710.
      12. Fannin, K. F., and S. C. Vana. 1982. Development and evalua-
         tion of an ambient viable microbial  air sampler. EPA'-600 l-Sl-
         069. U.S. Environmental Protection Agency. Cincinnati. Ohio.
      13. Fannin. K. F., and S. C. Vana. 1983. Study of microbial aerosols
         emitted from a water reclamation plant. EPA-600/1-83-013. U.S.
         Environmental Protection Agency. Cincinnati. Ohio.
      14. Jakuhowski, VV. 1983. Wastewater aerosol health effects studies
         and the need for disinfection, p. 68-82. In A. D. Venosa and E.
         W. Akin fed.). Municipal wastewater disinfection: proceedings
         of the second  national symposium.  EPA-600/9-83-009. U.S.
         Environmental Protection Agency, Cincinnati. Ohio.
      15. Jones, B. L.. and J. T. Cookson.  1983.  Natural atmospheric
         microbial conditions in a typical suburban area. Appl. Environ.
         Microbiol. 45:919-934.
      16. Kenner,  B. A., and H. P. Clark. 1974. Detection and enumera-
         tion  of Salmonella  and Pseudomonas aeruginosa. J.  Water
         Pollut. Control Fed. 46:2163-2171.
      17. Ltmbke, L. L., and R. N. Kniseley.  1980. Coliforms in aerosols
         generated by a municipal solid waste recovery system. Appl.
         Environ. Microbiol. 40:888-891.
18. Millncr. P. D.. D. Bassttt. and P. B. Marsh. 1980. Dispersal of
    Aspercillit.i fiimmuni\ from sewage sludge composl piles sub-
    jected to mechanical agitation in open  air. Appl.  Environ.
    Microbiol. 39:1000-1009.
19. Moore. B. E.. B. P. Sagik. and C. A. Sorbcr. 1979. Procedure for
    the recovery of airborne human enteric viruses  during  spray
    irrigation of treated wastewater.  Appl.  Environ. Microbiol.
    38:688-693.
20. Pahren.  H.. and W. Jakubowski led.). 1980. Wastewater aero-
    sols and disease. EPA-600/9-80-028. U.S. Environmental Pro-
    tection Agency. Cincinnati. Ohio.
21. Sekla, L.. D. Gemmill. J. Manfeda. M. Lysyk. W. Stack!*, C.
    Kay, C. Hopper. L. Van  Buckenhout. and G. Eibisch.  1980.
    Sewage treatment plant workers and their environment: a health
    study, p. 281-294. In H.  Pahren.  and W.  Jakubowski  (ed.l.
    Wastewater aerosols and disease.  EPA-eOO^-SO^S. U.S. En-
    vironmental Protection Agency. Cincinnati. Ohio.
22. Siegei, S. 1956. Nonparametric  statistics for the behavioral
    sciences. McGraw-Hill Book Co.. New York.
23. Snrdecor, G. W., and W. C. Cochran. 1967. Statistical methods.
    The Iowa State University Press. Ames.
24. Spendlove, J. C. 1974. Developments in industrial microbiology.
    p. 20 to 27. American Institute of  Biological Sciences, Wash--
    ington. D.C.
25. Teltsch, B.. S. Kedmi. L. Bonnet, Y. Borenzstajn-Rotem, and E.
    Katzenelson. 1980. Isolation and  identification of pathogenic
    microorganisms at wasiewater-imgated fields: ratios in air and
    wastewater. Appl. Environ. Microbiol. 39:1183-1190.
Pathogens  -  16

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United States
Environmental Protection
Agency
Health Effects Research
Laboratory
Cincinnati OH 45268
Research and Development
EPA-600/S1-81-002 Mar. 1981
Project Summary
Health  Risks  of  Human
Exposure to Wastewater
C. S. Clark, C. C. Linnemann. Jr.. G. L Van Meer, G. M. Schiff. P. S. Gartside,
A. B. Bjornson, E. J. Cleary, J. P. Phair, C. R. Buncher, D. L. Alexander. S. E.
Trimble, and B. C. Barnett
  The  primary  objective  of  this
research was to determine the health
effects associated with occupational
exposure to biological agents present
in municipal wastewater. An  addi-
tional objective was to determine the
sensitivity  of the  methodology for
detecting potential health impacts of
other wastewater exposures, such as
recreational  contact  with  surface
water receiving wastewater effluents.
The procedure was a prospective sero-
epidemiologic  study applied to
municipal  wastewater workers and
controls in three metropolitan areas:
Cincinnati.  Ohio;  Chicago. Illinois;
and  Memphis.  Tennessee.  The
primary study group consisted of
more than 100 workers  recruited at
the time they began work at activated
sludge plants and who remained in Jhe
study for a minimum of 12 months. In
addition, a Chicago group of 30 expe-
rienced  sewage  treatment  plant
workers  were  included  and. in
Cincinnati, two other wastewater-
ex posed groups were recruited con-
sisting  of about  50 sewer
 maintenance workers and 50 primary
 wastewater treatment plant workers.
 The tatter group was recruited into the
 study just  before start-up of plant
 improvements that included activated
 sludge facilities.  The  purpose of
 including this group was to differen-
 tiate between aerosol exposure and
 exposure to wastewater and sludge
 through those operations associated
with primary wastewater treatment.
  The protocol involved quarterly col-
lection  of  blood, throat, and rectal
swabs;  yearly medical examinations;
collection of illness information; work
observations;  and  environmental
monitoring. Initial  recruitment  of
workers began April  1975  in
Cincinnati; July 1976 in Chicago; and
July 1977 in Memphis. Final speci-
mens in all  cities were collected in the
fall of  1978. The serological survey
included testing for antibodies to a
large group of viruses and bacteria and
determination   of  immunoglobulin
levels.  Work observations were used
to evaluate the level  of  the workers'
contact with wastewater and, in con-
junction with the biological air moni-
toring,  to assess the extent of contact
with aerosols.  The environmental
monitoring included viral and bacterial
analyses of wastewater and the use of
six-stage Andersen samplers to deter-
mine the respirable concentrations of
bacteria in the work areas of the plant.
  A  total  of  over  500 volunteers
participated in the.study  including
both subjects and controls.

   This  Project  Summary was devtl-
oped by EPA's Health Effects Re-
search  Laboratory. Cincinnati. OH. to
announce key findings of the research
project that is fully documented in a
separate report of the same title (see
Project Report ordering information ft
back).
                     Pathogens - 17

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Introduction
Objectives
  The  purpose of this study was to
determine the health effects, if any, of
the  occupational  exposure  to  the
viruses, bacteria, and parasites present
in municipal wastewater. The central
feature was an extensive surveillance
of  the health  of  100  newly-hired
activated  sludge  treatment  plant
workers during  a  minimum of  12
months of occupational  exposure to
wastewater. Specific objectives of the
project were:

1.   To  determine whether wastewater
    workers develop clinical illness or
    specific bacterial, viral,  and para-
    sitic infections due to occupational
    exposure to sewage.

2.   To  determine the immunologic re-
    sponse among workers presumed
    to be exposed to a high level of anti-
    genie   simulation,   i.e.,  through
    wastewaters.

3.  To  determine whether wastewater
    workers serve as  a  reservoir of
    certain  infections  and,   if  so,
    whether members of the workers'
    families are affected.

4.  To determine the effect of exposure
    10  aerosols generated by the acti-
    vated sludge treatment process.

5.  To  determine the concentration of
    bacterial  aerosols at wastewater
    treatment  plants, and to compare
    them to levels at other public works
    facilities.

   An underlying objective of the  study
was the determination of the sensitivity
of  various elements of the epidemic-
logical-serological approach  for the
detection of wastewater-related health
effects. Such a determination would
permit an assessment of the  potential
application of this methodology to the
study  of health risks associated with
other  population exposures to waste-
waters.  The  latter  would   include
persons working with or living near
wastewater   land-disposal   facilities,
persons living in the vicinity of waste-
water  treatment plants, and  persons
engaged in recreational use of bodies of
water  receiving waste effluents.
Background
  Information  regarding  the human
health risks associated with contact
with wastewater and related materials
brought  about by  occupational and
other exposures is  limited. However.
assumptions concerning these risks are
providing  motivation  for  the
promulgation  of  state and federal
standards  designed to protect
populations from  various wastewater


Table 1.    List of Viruses, Bacteria.
            and Immunoglobulins for
            Which   Workers'   Sera
            Were  Tested  for  Anti-
            bodies.
Viruses
1.  Polio 1.2. and 3
2.  Coxsackie A-7.  A-9.  A-16.  A-21.
    and B-1 to B-6
3.  Echo 1. 3. 4. 5,  6. 8. 9. 11. 13. 14.
    19. 24. 30
4.  Reovirus
5.  Adenovirus
6.  Cytomegalovirus
7.  Herpes simplex
8.  Hepatitis A antibody and Hepatitis B
    antibody and antigen
      Test Methods: Microneutraliza-
      tion for Polio. Coxsackie and all
      Echo   viruses;  Radioimmuno-
      assay for Hepatitis A and B; and
      Complement  Fixation  for  the
      others.

Bacteria
1.  Sa\mone\\a:GroupA.B.C.D.andE
      Test Methods: Rapid slide agglu-
      tination (1975-1976)
      Microagglutination (1978)
2.  Leptospira
      Test Method:  Microagglutination
3.  Legionella pneumophila
      Test Method: Indirect immuno-
      fluorescence

Immunologic factors
 1.  IgA
2.  IgG
3  IgM
4.  Rheumatoid Factor
       Test Methods: Radial immunodif-
      fusion  for  immunoglobulins,
      latex  reaction  for rheumatoid
      factor
exposures. The growing emphasis on
the land application of wastewater and
sludges as a viable method of wastes
utilization  increases the  need  for
reliable and up-to-date information on
the  health  risks,  if  any,  involved.
Wastewater  also  contains  a  wide
variety of harmful chemicals which may
under some conditions compromise the
health  of  wastewater  workers.
However, chemical hazards  were not
considered in this study.
Methods
  The study consisted of an intensive
serologic survey correlated with epide-
miological, clinical, and environmental
data on  the study populations.  The
central feature of the design was an
evaluation of the effects of occupational
exposure to wastewater over at least a
12-month  period  based  on  the
measurement  of  specific  viral  and
bacterial antibodies and immunoglobu-
lin  in  sera  collected  over that time
period. In order to  help  separate the
effect of the occupational exposure from
that associated with other possible
disease pathways, appropriate  control
groups were utilized. In addition, many
of  the  wastewater  workers  were
recruited into the study at the  time of
their initial employment in the waste-'
water treatment industry
  Each quarter blood  samples, throat
swabs,   and  fecal  samples  were
collected from participants in the study.
Blood  specimens were  used  for the
serologic surveys and the throat swabs
and fecal specimens were used  for
analysis   for  bacteria,   viruses  and
parasites. (Parasitic examinations were
performed only during the early period
of the study in Cincinnati.) The serologic
survey involved the determination of
antibodies to a  group cf viruses and
bacteria  and  measurement  of
immunoglobulin levels  (Table  1). Of
concern  in  the serologic survey  was
whether the prevalence  and level of
antibodies  were   different  in  the
wastewater  exposed  and  control
groups,and  whether  the number of
infections as indicated by increases in
antibody concentration  was different
among the various study  groups.
   Illness  information was obtainea by
 monthly health diaries  maintained by
 the workers supplemented by telephone
 and on-the-job contact. Illness symptom
 information  from  all   sources  was
  Pathogens -  18

-------
combined in a manner designed to avoid
double counting and was categorized as
"respiratory."  "gastrointestinal,"  and
"other."  The data processing proce-
dures  provided for   coding  various
possible  combinations of  these.  The
definition of  these illness  categories
was based on the symptoms indicated
on the health diary, as follows:

Respiratory      •  Cold symptoms,
                 sore throat, cough
                 or  other  lower  res-
                 piratory symptoms.

Gastrointestinal  - Nausea,   vomiting,
                 diarrhea, or intesti-
                 nal upset.

Other           - Fever.    persistent
                 headache,  eye in-
                 flammation or other
                 eye  trouble,   ear-
                 ache or other ear
                 trouble, skin  infec-
                 tion, rash, boils, or
                 open sores.
  From  time to time  job locations of
participants were visited to determine
types and levels of exposure and other
work  conditions. Work site  air  was
monitored  periodically  for bacterial
concentrations,  and  concurrent
wastewater samples at the wastewater
treatment  plants  were analyzed for
bacterial and viral concentrations. Six-
stage Andersen samplers were use-J to
collect the airborne bacteria. In order to
process  the  air samples  as soon as
possible, preparation  and analyses of
the plates for bacterial sampling were
performed   in  Chicago  by  the
Metropolitan  Sanitary  District of
Greater  Chicago (MSDGC). in Memphis
by the Memphis State University, and
by the bacteriologist on the study staff
 in  Cincinnati. All wastewater samples
for virus assay were processed by the
 aluminum hydroxide  continuous flow
 centrifuge technique and assayed by a
 plaque  assay procedure.
   On a  yearly basis, study volunteers
 were offered a medical evaluation that
 included hematologv. urinalysis, pul-
 monary function testing,  blood chem-
 istry (including tests of liver and kidney
 function), and examination by a physi-
 cian.
   A  number   of  comparisons and
 correlations  were  made  from  the
 epidemiological,  environmental,
 clinical, and serological aspects of the
 study.
  As initially conceived, the study goals
were limited to the first three specific
objectives listed above. The population
groups  planned for  the  study were
sewer   and  highway  maintenance
workers  in Cincinnati. The  research
design initially called for recruitment of
an equal number of men beginning their
respective jobs as those recruited who
had two or more years experience, for
both exposed and control groups. Soon
after the study was initiated economic
conditions in the municipal government
forced  a moratorium on hiring new
employees  in the Cincinnati  Public
Works  Department which eliminated
prospects for establishing  a  newly
employed highway maintenance study
group.
  About  one  year after this research
began,  its  goals were expanded  to
include a determination of the  health
effects associated with the dispersion of
aerosols generated  by the  activated
sludge wastewater treatment process
(Specific Objectives  4 and 5). At this
time the study design was expanded to
include two additional exposed popula-
tion groups: 50 men  at the Cincinnati
Mill  Creek Sewage  Treatment Plant
which  was  in  the  process  of  being
expanded from  primary  wastewater
treatment to  include the  activated
sludge process; and a total of 100 men
newly  employed  at  activated  sludge
treatment plants. Since only one-third
of the  100  inexperienced  activated
sludge plant workers  were expected to
be available in Cincinnati, the study was
expanded to  include  workers  at the
plants  in Chicago and Memphis. These
cities were chosen because at least 50
new employees would be hired  within
the next year, the plants contained the
activated process in open basins with
porous plate-type diffusers, they were
reasonably accesible to Cincinnati, and
the  plant  administrators  were
agreeable to the study. MSDGC hirjsd a
significant  number  of new  workers
because of normal work force turnover
by virtue of its size. In addition, its long
experience in  wastewater treatment
and  the  technical support  for
monitoring available from its Research
and Development Department made it
very suitable for study. Memphis was in
the final stages of construction of its
second  activated sludge  treatment
plant,  the North Treatment  Plant,  an
entirely new facility. In addition,  its first
plant,  the  Maxson  Wastewater
Treatment Plant had plans to hire more
workers.
  Comparison  groups  in  Cincinnati,
 Chicago and Memphis  were highway
 maintenance  water  treatment  plant
 workers and  gas and  electric utility
 workers, respectively.
Conclusions
 1.   Gastrointestinal illness rates were
     higher in the inexperienced waste-
     water exposed workers than in the
     experienced workers and controls.
     Wastewater   workers  were  not
     found  to  be  subject   to   any
     detectable risks due  to parasites
     present in wastewater. There was
     only slight evidence, if any, to sug-
     gest that there were  risks due to
     viruses and bacteria in wastewater.

 2.   Immunoglobulin  levels  were  not
     found to be cor.sistently higher in
     wastewater-exposed workers than
     in  controls in any of the cities
     studied.

 3.   Wastewater   workers  were  not
     found to serve as a source of viral
     infections for their family members.

 4.   In a few instances levels of antibody
     to  certain viruses appeared to be
     related  to  level of exposure to
     wastewater aerosols.

* 5.   Bacterial aerosol levels in buildings
     where  wastewater sludge  was
     being processed  were generally
     higher than levels adjacent to out-
     door aeration tanks at the same
     treatment plants.

 6.   Since the seroepidemiologic  ap-
     proach   did  not  detect  any
     significant health effects of occu-
     pational exposure to wastewater, it
     is unlikely that this approach would
     detect potential health impacts in
     populations with  lower  levels of
     exposure to wastewater.


 Recommendations
   Since the basic design of this study
 was  to  compare  antibody  levels
 between two quarters  in  each year of
 the study, all sera  collected over the
 entire  study period  have  not  been
 tested. It is possible that changes in
 antibody levels were not detected by
 semiannual testing. Selected viruses of
 high prevalence should be  studied by
 testing all sera for each individual.
                                                                                                      Pathogens -  19

-------
  Because  the  predominance  of
seroconversions to Hepatitis B were in
the sewage-exposed groups (seven of
123  sewage-exposed  workers com-
pared to one of 52  control workers).
additional testing should be done on
workers not yet evaluated to determine
whether this trend persists.
  Additional testing of sera of workers
occupational^ exposed to soil, such as
some sewer and highway maintenance
workers, would be useful in attempting
to verify previous suggestions that soil
exposure increases the risk of infection
to Legionella pneumophila.
  Because of the limited testing of sera
for antibody to Hepatitis A, the initial
sera of a  number  of workers has  not
been tested. It would be useful to test
these sera to determine whether any of
these people  acquired the antibody
during the course of the study.
  Serologic  testing  for rotavirus or
parvovirus  agent was not performed
during the study. Since these viruses
 are  now recognized as a major cause of
 gastrointestinal illness, the sera  col-
 lected during  the  study  should be
 analyzed for antibody to them.
C. S. Clark. C. C. Linnemann. Jr.. C. L  Van Meer. G. M. Schiff. P. S. Ganside.
  A. B.  Bjornson. £.  J. Cleary.  J. P. Phair. C. ft. Buncher. D. L. Alexander,
  S. E. Trimble,  and B. C. Barnett are with the University of Cincinnati Medical
  Center. Cincinnati.  OH 45267.
Walter Jakubowski is the EPA Project Officer (see below).
The complete report, entitled "Health Risks of Human Exposure to Waste-
  water." (Order No.  PB 81-143 406; Cost: S15.SO. subject to change) will be
  available only from:
        National Technical Information Service
        5285 Port Royal Road
        Springfield. VA 22161
        Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
        Health  Effects Research Laboratory
        U.S. Environmental Protection Agency
        Cincinnati. OH 45268
Pathogens -  20

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                                         HP.\-600 9-80-028
                                           December 1980
                 Wastewater Aerosols

                     and Disease

              Proceedings of a Symposium


                   September 19-21, 1979


                     Sponsored by the
              Health Effects Research Laboratory
                       Edited by
              H. Pahren and W. Jakubowski
        OFFICE OF RESEARCH AND DEVELOPMENT
       U.S. ENVIRONMENTAL PROTECTION AGENCY
                CINCINNATI, OHIO  45268
This document is available 10 the public through the National Technical Information Service,

Sprinfield. Virginia 22161.
                                                      Pathogens - 21

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                                          Ill
                                 FOREWORD
            The U.S. Environmental Protection Agency was created because of
          increasing public and government concern about the dangers of pollu-
          tion to the health and welfare of the American people. Noxious air, foul
          water, and spoiled land are tragic testimony to the deterioration of our
          national environment. The complexity of that environment and the in-
          terplay between its components require a concentrated and integrated
          attack on the problem.
            Research and development  is that necessary  first step in  problem
          solution; it involves defining the problem,  measuring its impact, and
          searching for solutions. The primary mission of the Health Effects Re-
          search  Laboratory in Cincinnati (HERL) is to provide a sound health
          effects  data base in support of the regulatory activities of the EPA. To
          this end, HERL conducts a research program to identify, characterize,
          and quantify harmful effects of pollutants that may result from exposure
          to chemical, physical, or biological agents found in the environment. In
          addition to the valuable health information generated by these activities,
          new research techniques and methods are being developed that contrib-
          ute  to a better understanding of human biochemical and physiological
          functions and how these functions are altered by low-le-vel insults.
            These proceedings represent an attempt to publish current knowledge
          on the  human  health aspects of exposure to microbial aerosols  from
          wastewater  treatment plants.  With  a  better  understanding of  these
          health  effects, design engineers, municipal  officials, and  persons in-
          volved with regulatory decisions can make more informed judgments on
          the  siting and operation of such plants.

            R. J. GARNER
            Director
            Health Effects Research Laboratory
Pathogens - 22

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                          PREFACE
   Many wastewater treatment plants are constructed in  urban areas
 close to residential areas. These systems generally contain aeration bas-
 ins or trickling filters where there is an opportunity for small droplets of
 wastewater to be emitted. These droplets, which could contain a bacter-
 ium or virus, evaporate very rapidly to yield small droplet nuclei  known
 as aerosols.
   A number of persons have investigated the types of organisms emitted
 and their concentration in  the air as a function of distance from the
 treatment plant. These microorganisms travel passively with the-wind,
 and their concentration decreases with time and distance as a result of
 atmospheric dispersion, die-off, and deposition. The potential for plant
 workers and nearby residents to inhale viable organisms certainly exists.
 However, there has never been a systematic investigation to confirm or
 negate  the existence of a health hazard from these viable wastewater
 aerosols.
   With this background, the Health Effects Research Laboratory of the
 U.S. Environmental Protection Agency arranged for several epidemiol-
 ogical studies to gather information on health effects associated  with
 aerosols from uncovered wastewater treatment  plants. These studies
 were conducted by personnel from universities or research institutions.
   The purpose of this symposium was to present and discuss the  results
.of the  epidemiological studies, as well as related health topics which
 could aid in understanding the findings. The  symposium  brought to-
 gether interested persons from several countries, who contributed freely
 and provided an opportunity to summarize the current knowledge in a
 single publication.
   The proceedings are organized according to the format of the sympos-
 ium into six main sections addressing the topics of contaminants, health
 fundamentals, population  studies,  occupational  studies,  and aerosol
 suppression and providing an assessment. In many cases, the proceed-
 ings papers are more comprehensive than the symposium presentations
 to provide a more thorough coverage of a given topic. Edited discus-
 sions are included with the papers, and an attempt was made to identify
 each questioner. A list of registrants is presented to allow the reader to
 contact any participant for further information.

   HERBERT R. PAHREN
   WALTER JAKUBOWSKI
   Editors
                                                                Pathogens - 23

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                                   ABSTRACT
             The Health Effects Research Laboratory of the U.S. Environmental
           Protection Agency sponsored a Symposium  on Wastewater Aerosols
           and Disease on September 19-21, 1979, in Cincinnati, Ohio.
             This symposium brought together scientists, engineers, physicians,
           and public health officials from all over the world to present and discuss
           current state-of-knowledge on human health aspects of exposure to mi-
           crobiological agents emitted  as aerosols from wastewater treatment
           plants. Sessions on the nature of the contaminants, health aspects, epi-
           demiological studies, and aerosol  suppression and a panel discussion
           assessing the information were held. The proceedings consist of 22 in-
           vited papers and associated discussions.
Pathogens - 24

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                       CONTENTS


    Foreword	:	 Hi
      R. J. Garner
    Preface	 iv
      H. R. Pahren, W. Jakubowski
    Abstract	  v
    Acknowledgments	 vi
    Keynote Address	  xi
      R L. Longest

SESSION I: CONTAMINANTS	     1
      S. A. Schaub, Session Chairman
    Methods for Detecting Viable Microbial
    Aerosols	     1
      K. F. Fannin
    Indicators and Pathogens in Wastewater
    Aerosols and Factors Affecting Survivability	  23
      C. A. Sorber, B. P. Sagik
    Nonviable Contaminants from Wastewater:
    Hexachlorocyclopentadiene Contamination
    of a Municipal Wastewater Treatment Plant	  36
      J. R. Kominsky
    A Model for Predicting Dispersion of
    Microorganisms in Wastewater Aerosols	  46
      D. E. Camann

SESSION II: HEALTH ASPECTS	  71
      R. B. Dean, Session Chairman
    Infection and Resistance: A Review	  71
      J. P. Phair
    Infection with Minimal Quantities of
    Pathogens from Wastewater Aerosols	  78
      D. O. Giver
    Responses to Wastewater Exposure
    with Reference to Endotoxin	  90
      R. Rylander, M.°Lnndholm
                                                          Pathogens - 25

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                 Health Effects of Nonmicrobiological—
                 Contaminants [[[  99
                   J. B. Lucas
                 Epidemiologic Approach to Disease
                 Assessment [[[  109
                   R. K. Miday


              SESSION III: POPULATION STUDIES .......................  117
                   S. Poloncsik, Session Chairman
                 Acute Illness Differences with Regard
                 to Distance from the Tecumseh, Michigan,
                 Wastewater Treatment Plant .............................................  117
                   K. F. Fannin, K. W. Cochran,
                   D. E. Lamphiear, A. S. Monto
                 Health Effects from Wastewater Aerosols
                 at a New Activated Sludge Plant: John
                 Egan Plant, Schaumburg, Illinois .......................................  136
                   D. E. Johnson, D. E. Camann, J. W. Register,
                   R. J. Prevost, J. B. Tillery, R. E. Thomas,
                   J. M. Taylor, J. M. Hosenfeld
                 Wastewater Aerosol and School Attendance
                 Monitoring at an Advanced Wastewater
                 Treatment Facility: Durham Plant, Tigard, Oregon ................  160
                   D. E. Camann. D. E. Johnson,
                   H. J. Harding, C. A. Sorber
                 Health Effects of Aerosols Emitted
                 from an Activated Sludge Plant .........................................  180
                   R. L. Northrop, B. Carnow, R. Wadden,
                   S. Rosenberg, A. Neal, L. Scheaff,
                   J.  Holden, S. Meyer, P. Scheff


              SESSION IV: OCCUPATIONAL STUDIES .................  228
                   J.  P. Phair, Session Chairman
                 Epidemiological Study of Wastewater
                 Irrigation in Kibbutzim in Israel ......................................... 228
                   H. /. Shuval-B. Fattal
                 Health Effects of Occupational Exposure
                 to Wastewater [[[ 239

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    Worker Exposure to Organic Chemicals at an
    Activated Sludge Wastewater Treatment Plant	 265
   .  V. J. Ella, C. S. Clark, V. A. Majeti,
      T. Macdonald, N. Richdale
    Disease Rates Among Copenhagen Sewer Workers	 274
      R. B. Dean
    Sewage Treatment Plant Workers and Their
    Environment: A Health Study	 281
      L. Sekla, D.  Gemmill, J. Manfreda,
      M. Lysyk, W. Stackiw, C. Kay,
      C. Hopper, L. Van Buckenhout,
      G. Eibisch
    Interim Report on a Mortality Study
    of Former Employees of the Metropolitan
    Sanitary District of Greater Chicago	 295
      P. S. Gartside, B. Specker,
      P. E. Harlow, C. S. Clark

SESSION V: AEROSOL SUPPRESSION	 302
      O. J. Sprout, Session Chairman
    Suppression of Aerosols at a
    Wastewater Reclamation Plant	 302
      C. Lue-Hing, J. O. Ledbetter, S. J. Sedita,
      B. M. Sawyer, D. R. Zenz, C. W. Boyd
    Effectiveness of Aerosol Suppression
    by Vegetative Barriers	 324
      J. C. Spendlove, R. Anderson, S. J. Sedita,
      P. O'Brien, B. M. Sawyer, C. Lue-Hing

SESSION VI: ASSESSMENT	 339
      H. R. Pahren, Session Chairman
    Assessment of Health Effects, Panel Discussion	 339
      L. J. McCo.be, C. Lue-Hing,
      M. Singal, C. S. Clark

REGISTRATION LIST	 355
                                                      Pathogens - 27

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	11-16
301 (h) evaluation summary

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                         TECHNICAL SUMMARY
        Revised Application for Section 301(h) Modification
      Metropolitan District Commission, Boston, Massachusetts


     The Clean Water Act (the "Act") of 1972 required all publicly
owned treatment works (POTWs) to provide the equivalent of secondary
treatment.  Secondary treatment, as defined by the Environmental
Protection Agency (EPA)  regulations, requires 85% removal of the
biochemical oxygen demand (BOD) and 85% removal of the suspended
solids (SS) in the waste material.  In 1977, Congress amended the
Act to allow POTWs which discharge to marine waters to seek a
waiver under section 301{h) of the Act from the secondary treatment
requirement.

     The EPA may grant such a waiver provided the following condi-
tions are met:

     (1)  there is an applicable water quality standard specific to
     to the pollutant for which the modification is requested, which
     has been identified under section 304(a)(6) of the Act;

     (2)  such modified requirements will not interfere with the
     attainment or maintenance of that water quality which assures
     protection of public water supplies and the protection and
     propagation of a balanced, idigenous population of shellfish,
     fish and wildlife,  and allows recreational use of the water;

     (3)  the applicant has established a system for monitoring the
     impact of such discharge on a representative sample of marine
     biota, to the extent practicable;

     (4)  such modified requirements will not result in additional
     requirements on other point or nonpoint sources;

     (5)  all applicable pretreatment requirements for dischargers
     to the treatment works will be enforced;

     (6)  to the extent practicable, the applicant has established
     a schedule of activities to eliminate the entrance of toxic
     pollutants from nonindustrial sources into such treatment works;

     (7)  there will be no new or substantial increase in the effluent
     volume specified in the permit.

     On September 31, 1979, the Metropolitan District Commission,
Boston, Massachusetts, submitted to the EPA an application seeking a
301(h) waiver.  .EPA, after extensive review, denied the waiver
application on June 30, 1983.  In accordance with EPA regulations,
the MDC submitted a second and final revised application for a
waiver on June 30, 1984.  The revised application proposed a further
extension of the treatment system outfall into Massachusetts Bay.
The MDC proposed the following effluent characteristics in the
                                                                301(h)  - 1

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   revised  application:

             BOD                 437,000   Ibs/day
             SS                  263,000   Ibs/day
             pH                    6-9
             Flow                  485     million gallons/day

   It  should be noted  that  the  proposed  effluent characteristics are
   for the  year 1990.   Substantially higher  levels  are expected for
   the year 2010.

        Of  particular  importance in the  review of a 301(h)  waiver
   application  is  the  determination of the expected solids  deposition
   resulting from  the  proposed  discharge.  Solids deposited on the
   seabed can have a significant impact  on shellfish,  fish, and
   bottom dwelling organisms.   Further,  the  deposited  solids,  if
   resuspended  during  the critical summer months, could lower  the
   dissolved oxygen level of  the receiving water to undesirable levels.

        As  a part  of the review process,  EPA Task Force scientists, in
   consultation with Tetra  Tech, Inc., an EPA contractor, and  a
   scientist at the Massachusetts Institute  of Technology,  have
   determined that the expected solids deposition rate would be
   nearly 100 times greater than the solids  deposition rate estimated
   by  the MDC in  the 301(h) application.  Using the significantly
   higher deposition rate,  EPA  has concluded that:

         (1) The  Commonwealth's dissolved oxygen standard would be
        violated  during resuspension events; and

         (2) The  benthic  (sea floor) community would be adversely
        modified  over  an area of at least 8.5 km2.   This area  is
        nearly  50  times greater than the zone of initial dilution
         (ZID).  The ZID, specifically defined by t.be 301(r,.) guidance
        documents, is  the region of initial  -mixing  surrourofling the
        discharge  diffuser.

        The EPA Task Force  also has conducted an extensive  review
   of  studies depicting existing physical, cbenical, and biological
   conditions of  Boston Harbor  and Massachusetts Bay.   The  EPA Task
   Force  concluded that (1) significant  .deterioration  of benthic
   biological communities  is presently occurring in Bo^on  Harbor;
    (2) ambient  receiving water  and sediments of Boston Harbor  are
   contaminated by toxic pollutants;  (3)  existing waste discharges
   including effluents from Deer and Nut Island treatment facilities
   contribute large amounts of  solids contaminated  with toxic  pollutants
   to  Boston Harbor; and  (4)  present discharges from Deer Island are
   likely contributing to  the incidence  of fish disease in  Boston Harbor

        The EPA Task Force  has  concluded that similar  biological
   degradation  due to  deposition of sewage solids and  associated
   toxic  pollutants will occur  at the proposed site.

        The tentative  'decision  document  outlines in detail  the various
   technical determinations which resulted in denial of the MDC's
   revised  application for  a section 301(h)  modification.
301(h) - 2

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                             FACT SHEET
                    Tentative Decision Document
        Revised Application for Section 301(h) Modification
      Metropolitan District Commission, Boston, Massachusetts

0  Task Force recommends denial of section 301(h) modification

0  Natural conditions

   - Circulation pattern is characterized by variable current
     direction and slow net drift
   - Important recreational and commercial fisheries are sustained
     by the waters in Boston Harbor and Massachusetts Bay
   - The proposed discharge area presently shows signs of'environ-
     mental degradation

0  Existing facilities consist of two primary treatment plants,
   Deer and Nut Island, which in 1984 treated average annual
   flows of 304 and 117 mgd, respectively

0  Proposed modifications include relocating the outfall from Boston
   Harbor to Massachusetts Bay as well as upgrading the treatment
   facilities and improving operation

0  Discharge characteristics (Proposed)

   - Effluent discharge approximately 9.2 mi from Deer Island at a
     depth of 118 ft
   - Design flow for 1990 is 485 mgd which is 9.1% industrial  (44.1
     mgd) in origin
   - Critical initial dilution (90:1)
   - Proposed treatment removal efficiencies: 28% BOD and 61% SS

0  Projected impacts

   - The discharge will result in sedimentation  rates of sewage
     particles approximately two orders of magnitude greater than
     those predicted by the Applicant
   - Major reductions in total density and diversity of pollution
     sensitive benthic species resulting from deposition of sewage
     particles (357 g/m2/yr over 8.5 km^) and associated toxic
     materials
   - State water quality standard for dissolved  oxygen adopted to
     protect marine  life will  be violated during summer resuspension
     events
   - Important commercial and  recreational fisheries will be ad-
     versely affected near  the proposed discharge
   - Bioaccumulation of priority pollutants will occur in benthic
     and  pelagic species
   - PCBs  and  copper will exceed EPA water quality criteria
   - Sedimenting sewage particles may  cause combined adverse im-
     pacts on  recreation and biota  in North Shore areas
                                                               301(h) -  3

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	11-17
EPA draft permit for secondary treatment

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             REGION I
                 JOHN F. KENNEDY FEDERAL BUILDING
                   BOSTON, MASSACHUSETTS.02203
                            FACT SHEET


DRAFT NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT
TO DISCHARGE TO WATERS OF THE UNITED STATES AND DENIAL OF A SECTION
301(h) VARIANCE REQUEST.

NPDES PERMIT NO.:  MA0102351

NAME AND ADDRESS OF APPLICANT:

     Massachusetts Water Resources Authority (MWRA)
     7th Floor
     One Center Plaza
     Boston, MA  02108

NAME AND ADDRESS OF FACILITY WHERE DISCHARGE OCCURS:

     MWRA Publicly Owned Treatment Works (POTW) to Boston Harbor,
     Combined Sewer Overflow (CSO) Treatment Facilities to the
     Charles River, Inner Harbor, and Mystic River, and
     CSO Outfalls to the Charles River.
     c/o MWRA
     7th Floor
     One Center Plaza
     Boston, MA  02108

RECEIVING WATERS:  Boston Harbor, Charles River, Inner Harbor and
Mystic River.

CLASSIFICATION:  As designated by the Massachusetts State Water Quality
Standards, 314 CMR 4.00.


I.  Proposed Action, Type of Facilities, Discharge Locations

The above named applicant has applied to the U.S. Environmental
Protection Agency (EPA) for reissuance of a NPDES permit to discharge
into the designated receiving waters.  The EPA has prepared Draft
NPDES Permit No. MA0102351 for public notice and comment.  The draft
permit is for discharges from publicly owned treatment works (POTW),
combined sewer overflow (CSO) facilities and CSO outfalls, as
specified in the draft permit.  The facilities are engaged in the
collection and treatment of municipal wastewater.

The Massachusetts Water Resources Authority (MWRA) is a public corpora-
tion established pursuant to the Massachusetts Water Resources Authority
                                                              NPDES - 1

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     Act of 1984.  It came into existence on January 1, 1985.  On July 1,
     1985, responsibility for the management and operation of the sewer-
     age system operated by the Metropolitan District Commission (MDC)
     passed to the MWRA pursuant to the enabling legislation.  Also on
     July I, 1985, responsibility, coverage, and liability under NPDES
     Permit No. MA0102351 issued August 12, 1976, to the MDC transferred
     to the MWRA pursuant to 40 CFR 122.61(b).  The 1976 permit expired
     May 1, 1981, but continues in force pursuant to 40 CFR 122.6 because
     the MDC submitted a timely application for a new permit.  The MDC
     and MWRA have agreed that the application for a new permit and for a
     section 301(h) variance filed by the MDC shall be treated as an
     application by the MWRA and that the new permit shall be issued to
     the MWRA.


     II.  Denial of Section 301(h) Variance Request

     On September 13, 1979, the MDC pursuant to section 301(h) of the
     Clean Water Act (CWA or the "Act") applied for a variance from the
     secondary treatment requirements contained in section 301(b)(l)(B)
     of the Act.  The MDC submitted three addendums to the application
     in 1982.  The Administrator of EPA denied the application in June
     1983.  In July 1984, the MDC submitted a revised and final section
     301(h) waiver application, which was supplemented in October 1984.
     On March 29, 1985, the Regional Administrator of EPA tentatively
     denied the revised application for a modification of the secondary
     treatment requirements of the CWA pursuant to section 301(h) and 40
     CFR Part 125, Subpart G.

     An eighty-five page analysis of the revised section 301(h) applica-
     tion was prepared by Region I EPA and was issued concurrently with
     the Regional Administrator's tentative denial.  As stated in that
     decision document, EPA made the following findings with regard to
     compliance with the section 301(h) statutory and regulatory criteria
     based upon its review of the data, references, and empirical evidence
     furnished in the application, the applicant's responses to EPA's
     requests for additional information, and the technical review report
     prepared by EPA's outside contractor:

          0 The proposed discharge is expected to violate the Common-
            wealth of Massachusetts' water quality standard for dissolved
            oxygen during summer resuspension events, but is not expected
            to violate the Commonwealth's standard for suspended solids.

          0 The proposed discharge is expected to interfere with the pro-
            tection and propagation of a balanced, indigenous population
            of marine life and may not allow for recreational activities.
            The proposed discharge will not adversely impact public water
            supplies.
NPDES - 2

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     0 The applicant has established a system for monitoring the'
       impact of its discharge.  This program contains deficiencies
       as discussed in the technical review report.

     0 The proposed discharge may impact other point and non-point
       sources to the north and west.

     0 The applicant has developed a program to enforce all appli-
       cable pretreatment requirements.  This program has been sub-
       mitted to the EPA Regional Office and approved under the
       pretreatment regulations, 40 CFR part 403.  A recent EPA audit
       shows that the program has not been adequately administered.

     0 The applicant has proposed a schedule of activities intended
       to limit the entrance of toxic pollutants from non-industrial
       sources into the treatment works.  This schedule of activities
       contains deficiencies as discussed in the technical review
       report.
     o
       There may be new or substantially increased discharge of pol-
       lutants in the effluent from the proposed discharge above that
       specified in the permit.

The Region concluded that the applicant's proposed discharge would
adversely impact the ecosystem and beneficial uses of the receiving
waters and would not comply with the requirements of section 301(h)
and 40 CFR Part 125, Subpart G, and recommended denial of the vari-
ance request.  Accordingly, the Regional Administrator authorized
the Region to prepare a draft permit with effluent limitations based
upon secondary treatment in accordance with his tentative decision
to deny a section 301(h) modified permit.

This action will implement the Regional Administrator's decision,
by requiring secondary treatment, in accordance with the procedures
for decisionmaking at 40 CFR Part 124.


III.  Description of Discharges

A quantitative description of the POTW discharges, in terms of
significant effluent parameters, based on discharge monitoring reports
from January 1984 to June 1985 is presented in Attachment 1.


IV.  Limitations and Conditions

The effluent limitations and monitoring requirements are set forth
in the attached Draft NPDES Permit No. MA0102351 which consists of
28 pages in Part I and 19 pages in Part II.
                                                             NPDES - 3

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      V.   Permit Basis and  Explanation of Effluent Limitation Derivation

           A.  POTW Discharges:   Conventional  Pollutants

      Under section 301(b)(l)(B)  of  the CWA,  POTW must  achieve effluent
      limitations based upon secondary treatment by July 1,  1977.   The
      secondary  treatment requirements are set  forth at 40  CFR Part 133.
      The regulations  describe  the  secondary  treatment  requirements for
      biochemical oxygen demand (BOD), suspended solids (TSS), and  pH.
      The "Average Monthly"  and "Average Weekly" BOD and TSS limitations
      are based  on the requirements  of 40 CFR 133.102.   Numerical  "Maximum
      Daily"  limitations, where applicable, and the numerical limitations
      for settleable solids,  pH,  and fecal coliform are based on  the
      Commonwealth's state  certification requirements under  section
      401(a)(l)  of the CWA,  as  defined in 40  CFR 124.53. Total residual
      chlorine permit  conditions  and numerical  limits for oil and  grease
      of  petroleum origin are based  on the Massachusetts Surface Water
      Quality  Standards.

      In  accordance with the provisions of 40 CFR 133.103(a), EPA  has
      determined that  the 85 percent removal  requirement established
      under 40 CFR 133.102  is not attainable.  The determination  is
      based upon the fact that  the  existing MWRA POTW are served by a
      combined sewerage system  resulting in wastewater  influent with
      less than  200 mg/1 of  BOD or  TSS.  Should circumstances change as
      to  future  MWRA POTW,  EPA  will  reevaluate  this determination.

           B.  POTW Discharges:   Toxic Pollutants

      Under section 301(b)(l)(c)  of  the CWA,  discharges are  subject to
      effluent limitations  based  on  water quality standards  as well as
      on  secondary treatment.   The  Massachusetts Surface Water Quality
      Standards  include a narrative  statement that prohibits the dis-
      charge  of  any pollutant or  combination  of pollutants  in quantities
      that would be toxic or injurious to human health  or aquatic  life.
      314 CMR  4.03(4).   The  Commonwealth does not have  numerical criteria
      for specific toxic pollutants  or toxicity criteria.  According to
      314 CMR  4.03(2),  EPA  water  quality criteria are to be  used to inter-
      pret the narrative standard in 314 CMR  4.03(4).

      Information and  data  from the  permittee's Industrial  Pretreatment
      Program  and the  301(.h)  application demonstrate that toxic pollutants
      are being  discharged  from the  MWRA POTW.   Evaluation of this  infor-
      mation  and data  shows  that  the POTW discharges may contain toxic
      pollutants in concentrations  that after dilution  exceed EPA water
      quality  criteria (see,  EPA  Water Quality  Criteria Documents,  45
      Fed.  Reg.  79318,  Nov.  28,  1980).  EPA's analysis  of the section
      301(h)  application concluded  that there is a likelihood of toxic
      effects  to biota in the receiving water from the  permittee's
      discharges.
NPDES - 4

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Therefore, in accordance with EPA policy, the draft permit includes
chronic and acute effluent toxicity limitations, toxicity reduction
evaluation requirements, and bioaccumulation assessment requirements.
(See, e.g., "Policy for the Development of Water Quality-Based Permit
Limitations for Toxic Pollutants", 49 Fed. Reg. 9,016 (Mar. 9, 1984);
see also, EPA's Technical Support Document for Water Quality-Based
Toxics Control).  The principal advantages of biological techniques
are: (1) that the effects of complex discharges of many known and
unknown constituents can be measured only by biological analyses;
(2) bioavailability of pollutants after discharge is best measured
by toxicity testing; and (3) pollutants for which there are inade-
quate chemical analytical methods or criteria can be addressed.

The No Observed Effect Concentration (NOEC) limitation in the draft
permit prohibits chronic adverse effects (e.g. , on survivial,
growth, and reproduction) when marine organisms are exposed to the
POTW discharges at the calculated available dilution of 10:1 or
less.  The No Observed Acute Effect Levels (NOAEL) limitation pro-
hibits acute effects (lethality) when marine organisms are exposed
to the POTW discharges at half of the calculated available dilution
of 10:1 or less.  Because of the immediacy of acute toxicity
(lethality), a margin of safety is applied to the NOAEL limitation.
Should the dilution available for future POTW discharges differ
from the 10:1 calculated available dilution for the existing POTW
discharges, the NOEC and NOAEL permit limits will be modified
accordingly.

The draft permit requires the permittee to conduct a toxicity
reduction evaluation if there are two or more violations of the
NOEC or the NOAEL limitations within a six month period.  A toxicity
reduction evaluation is an investigation of the sewerage system to
isolate the sources of effluent toxicity and specific causative
pollutants and to determine the effectiveness of pollution control
options in reducing the toxicity.

EPA also will evaluate and may use the results of the aquatic
toxicity tests and bioaccumulation assessment (which addresses
potential human health hazards) in conjunction with the chemical
analyses required by the permit and any other relevant information
or data to develop site-specific numerical effluent limitations for
specific pollutants.  The permit may then be modified to incorpor-
ate such limitations, particularly if specific chemicals in the
POTW discharge are identified as bioaccumulative or the cause of
effluent toxicity.

    C.  Combined Sewer Overflow:  Conditions for Discharge

The draft permit prohibits discharges from the permittee's combined
sewer overflow (CSO) outfalls and CSO treatment facility outfalls
during dry weather.  Dry weather discharges must be monitored as
                                                             NPDES - 5

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      specified in sections 4.a and 5.b of the draft permit and reported
      in accordance with General Requirement 1 on pages 5 and 6 of Part II.

      During wet weather, discharges from the permittee's CSO treatment
      facility outfalls and CSO outfalls are permitted providing the
      discharges receive the level of treatment described in section D
      below.  In addition, wet weather discharges shall not violate
      water quality standards.

      Wet weather discharges from the CSO treatment facilities outfalls
      must be monitored as follows:  (1) conventional and nonconventional
      pollutants for each discharge; (2) several toxic pollutants during
      one storm related discharge per month; and (3) 48 hour acute toxicity
      tests and chemical analyses once every two months.   When wet weather
      discharges occur from the permittee's CSO outfalls, the following
      information must be  abmitted for each outfall:  (1)  the period of
      discharge; (2) the estimated volume of discharge; and (3) precipita-
      tion data from the National Weather Service for the area.

            D.   Combined Sewer Overflows:  Required Treatment

      Section 301(b)(l)(A) of the CWA requires by July 1, 1977, the
      achievement of effluent limitations for combined sewer overflows
      which are based on application of the best practicable control
      technology currently available (BPT).  (See Montgomery
      Environmental Coalition v. Costle, 11 E.L.R.  20,211 (D.C. Cir. 1980)
      and Decision of the EPA General Counsel No. 49, June  30, 1976).   As
      of July 1, 1984, CSOs also must receive treatment at  a level provid-
      ing Best Conventional Pollutant Control Technology  (BCT) to control
      and abate conventional pollutants and Best Available  Technology
      economically achievable (BAT) purusant to section 301(b)(2) of
      the CWA.

      On September 29, 1978, EPA submitted a report to Congress on the
      "Control  of Combined Sewer Overflow in the United States" as required
      by section 516(c) of the CWA.  The report concluded that there is no
      single best CSO control alternative which can be applied in all
      cases.  Consequently, EPA has not issued national BPT, BCT, or BAT
      effluent  guidelines for CSOs.  In the absence of national standards,
      CSO limitations must be established on a case by case basis using
      best professional judgement (BPJ)  pursuant to section 402(a)(l)  of
      the CWA.

      The permittee's current permit, which was issued in 1976 and con-
      tinues in force pursuant  to 40 CFR 122.6, requires  that the nineteen
      specified CSOs owned and  operated by the MDC  receive  treatment
      based on  BPT by July 1, 1977.  (Special Condition A(2)(a) of 1976
      permit).   Prior to the issuance of the permit in 1976, CSO construc-
      tion projects were organized into five planning areas as a mechanism
      to provide treatment based on BPT for the 108 or more CSOs which
      discharge into Boston Harbor and its tributaries, including the 19
NPDES - 6

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or more CSOs owned and operated by the MDC.  (See, MDC's 1976 Eastern
Massachusetts Metropolitan Area Wastewater Engineering and Management
Study).  The MDC, as the overall operator of the region's sewage
system, was required by the 1976 permit to complete by July 1, 1977,
the following construction projects for the following five areas:
(1) Neponset River combined sewers; (2) Charles River combined
sewers; (3) Dorchester Bay combined sewers; (4) Inner Harbor combined
sewers; and (5) Charles River Marginal combined sewers.  (Special
Condition B.5 of the 1976 permit).

In an Enforcement Compliance Schedule Letter (ECSL) issued to and
signed by the MDC on August 11, 1976, EPA defined the level of treat-
ment to be attained upon completion of the five CSO projects, in
order to meet BPT, as follows:

        All Combined Sewer Overflow Projects shall be designed
        and constructed such that untreated discharges of com-
        bined sewage shall not occur at rainfalls less than a
        storm of 1 year severity and 6 hour duration.
        After completion of the Combined Sewer Overflow Projects,
        all flows shall receive,  as a minimum, screening, chlor-
        ination and detention prior to discharge.  All flows
        discharged shall contain a minimum chlorine residual
        of 1.0 mg/1 at all times.

To date, the following construction projects for the following four
areas have not been completed as required by the 1976 permit: (1)
Neponset River combined sewers; (2) Charles River combined sewers;
(3) Dorchester Bay combined sewers; and (4) Inner Harbor combined
sewers.  In 1982, the MDC completed facilities plans for the four
project areas.  As summarized in the MDC's l^ttZ CSO Project Report,
in order to complete the four remaining area-wide CSO projects,  the
completion of thirty-eight combined sewer overflow sub-projects  by
the MWRA is required.  (MDC Combined Sewer Overflow Project Summary
Report, pp.7-10, April, 1982).

The draft permit continues the requirements of the 1976 permit for
CSO treatment.  The statutory scheme established for effluent
limitations requires that BAT be at least as stringent as BPT.
Accordingly, EPA has made a BPJ determination pursuant to section
402(a)(l) of the CWA that BAT and BCT tor the CSOs in the five
project areas requires, as a minimum, the level of treatment provided
through the completion of the CSO sub-projects recommended in the
MDC CSO facilities plans and any amendments thereto approved by
EPA.

The draft permit requires that the completed CSO projects provide,
as a minimum and unless otherwise approved in writing by EPA,
screening, chlorination, and detention of all flows at rainfalls
less than a storm of one year severity and six hour duration.  EPA
no longer supports the concept that a minimum chlorine residual  is
                                                             NPDES - 7

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     required for all municipal discharges because chlorine residual
     concentrations have the potential to cause toxicity to the aquatic
     environment.

     Because section 301(B)(2)  of the CWA requires that CSOs acheive BCT
     and BAT by July 1,  1984, the draft permit requires the permittee to
     have completed by the effective date of the permit the thirty-eight
     CSO sub-projects recommended in the MDC CSO facilities plans and any
     revisions thereto approved by EPA.  EPA is aware that, in some
     instances, circumstances have changed since the completion of the
     CSO facilities plans in 1982 so that portions of the plans must be
     amended accordingly and the draft permit provides for this.  EPA
     also is aware that  in some instances the facilities plans do not
     provide for detention and  do not utilize the one year, six hour
     design storm.  The  draft permit also provides that the level of
     treatment may vary  from this standard, if approved in writing by
     EPA.

     EPA will review the level  of treatment provided by the required CSO
     projects and any approved  revisions thereto, the results of the CSO
     monitoring required by the draft permit, and available water quality
     data to determine what (if any) additional CSO controls are necessary
     to ensure that the  water quality standards of the receiving waters
     will be maintained  or attained.  EPA believes that the level of CSO
     treatment cannot be completely finalized until, among other things,
     required pretreatment standards are achieved by the industrial sources
     discharging to the  sewerage system, secondary treatment is achieved
     by the MWRA POTW, and dry  weather discharges are eliminated.

          E. Monitoring  Requirements

     The effluent monitoring requirements have been specified in accordance
     with 40 CFR 122.4KJ), 122.44(i) and 122.48 to yield data representa-
     tive of the discharge.

          F.  Sludge

     The discharge of sewage sludge into marine waters is prohibited by
     section 301 of the  CWA and implementing regulations.  The 1976 permit
     required the termination of all sludge discharges from the Deer
     Island and Nut Island wastewater treatment facilities by July 1,
     1977.

     The draft permit continues the prohibition of sludge discharges.
     It states that "the permittee shall not discharge sewage sludge."
     In addition, General Condition p (Removed Substances) of Part II of
     the draft permit requires  that solids, sludges, filter backwash, or
     other  pollutants removed in the course of treatment or control of
     wastewaters shall be disposed of in a manner consistent with applicable
     federal and state laws and regulations.
NPDES - 8

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     G.  Bypasses

The draft permit prohibits bypasses unless all of the  following
conditions occur:  (1) bypass was unavoidable to prevent loss of
life, severe injury, or severe property damage; (2) there were no
feasible alternatives to the bypass (e.g. , adequate backup equip-
ment, auxiliary treatment facilities, maintenance, etc.); and (3)
the permittee submitted notice of the need for an anticipated bypass
at least 10 days prior to the bypass date or the permittee submitted
notice of an unanticipated bypass within 24 hours from the time the
permittee became aware of the discharges to be followed by a written
submission within 5 days of discovery.

The draft permit makes it clear that even wet weather bypasses can
be unlawful: Discharges from any point source, regardless of owner-
ship (e.g. , discharges from the Boston Water and Sewer Commission's
Moon Island facility), which result from past, present, or future
failure to properly design, operate, or maintain the permittee's
POTW, or appurtenant facilities, or to adequately control or limit
incoming flows to the permittee's POTW will be considered unautho-
rized discharges by the MWRA. Thus bypasses will be considered
unlawful if, for example, they could be avoided through upgrading
and expansion of treatment facilities.

Pursuant to 40 CFR 122.41(e), the draft permit also requires the
permittee in cooperation with its member communities to operate
and improve its POTW and total sewer system to minimize the dis-
charge of pollutants from bypasses or CSOs.

     H. Infiltration/Inflow

The draft permit requires that the MWRA minimize Infiltration/In-
flow.

     I.  Pretreatment

The MWRA must implement and enforce the Industrial Pretreatment
Program required under section 307 of the CWA and implemented by 40
CFR Part 403.  The permittee's Industrial Pretreatment Program was
approved by EPA on July 20, 1982.  The annual reporting requirements
and other pretreatment program conditions of the draft permit will
assist EPA in determining the permittee's compliance with the require-
ments of 40 CFR Part 403.

Based on the potential for toxicity as a result of industrial dis-
charges to the POTW, the draft permit includes effluent toxicity
limitations and requires the performance of effluent toxicity tests
and bioaccumulation tests.  These tests will assist in assessing
the effectiveness of the permittee's pretreatment program and also
may be used as a basis for development of specific numerical
pretreatment limits.
                                                             NPDES - 9

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           J.   General  Conditions

      The general conditions of  the permit are based on 40 CFR Parts 122,
      Subparts A and D  and 40 CFR  124,  Subparts A,  D, E, and F and consist
      primarily of management requirements common to all permits.


      VI.   Interim Limits and Compliance Schedules

      The EPA  may develop interim  discharge limits  and compliance  schedules
      for the  existing  discharges  in enforcement actions subsequent to
      issuance of this  Permit.   On January 31, 1985, EPA filed a complaint
      in  the U.  S. District Court  for the District  of Massachusetts against
      the MDC, Commonwealth and  MWRA to enforce the requirements of the CWA.


      VII.   State Certification  Requirements

      The staff of the  Massachusetts Division  of Water Pollution Control
      has reviewed the  draft permit.   EPA has  requested permit certification
      by  the State pursuant to 40  CFR 124.53 and expects that the  draft
      permit will be certified.


      VIII.  Public Comment Period, Public Hearing, and Procedures for
            Final Decision

      All persons, including the applicant, who believe any condition of
      the draft permit  is inappropriate must raise  all issues and  submit
      all available arguments and  all supporting material for their
      arguments in full  by the close of the public  comment period  on
      September 11, 1985.  (See  40 CFR 124.13).  Comments should be
      directed to:

           U.S.  Environmental Protection Agency
           Compliance Branch
           John F. Kennedy Federal Building, Room 2109
           Boston, Massachusetts  02203
           Attn:   Veronica Hamilton

      A public hearing  will be held on  September 17, 1985, at Gardner
      Auditorium  located at the  State House from 7:00pm to 10:00pm.  In
      reaching a  final  decision  on the  draft permit the Regional
      Administrator will respond to all significant comments and make
      these responses available  to the  public  at EPA's Boston office.

      Following the close of the public comment period, the Regional
      Administrator will issue a final  permit  decision and forward a copy
      of  the final decision to the applicant and each person who has sub-
      mitted written comments or requested notice.   Within 30 days follow-
      ing the  notice of  the final  permit decision any interested person.
NPDES - 10

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may submit a request for a formal hearing to reconsider or contest
the final decision.  Requests for formal hearings must satisfy the
requirements of 40 CFR 124.74.


IX.  EPA Contact

Additional information concerning the draft permit may be obtained
between the hours of 9:00 a.m. and 5:00 p.m., Monday through Friday,
excluding holidays from:

     Gerald C. Potamis, P.E.
     Massachusetts State Coordinator
     U.S. Environmental Protection Agency
     John F. Kennedy Federal Building
     Boston, Massachusetts   02203
     Telephone:  (617)223-3949
August 16, 1985	        David A. Fierra, Director
        Date                   Water Management Division
                               U.S. Environmental Protection Agency
                                                             NPDES - 11

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                                 Attachment 1
                               MWRA Fact Sheet
                                  MA0102351
        Period January 1984 to June 85
         Pollutant                Monthly Average          Maximum Daily


         Deer Island

         BOD5 (mg/1)                   107                      155

         TSS (mg/1)                      90                      146

         Settleable  Solids (ml/1)         1.8                      4.1



         Nut Island

         BOD5 (mg/1)                    85                      127

         TSS (mg/1 )                      68 .                     123

         Settleable  Solids (ml/1)         1.1                      1.4
NPDES - 12

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                     Federal Register  /  Vol.  49. No. 48 / Friday. March 9. 1984  /  Notices
IOW-FRL-2533-1)

Development of Water Quality-Based
Permit Limitations for Toxic Pollutants;
National Policy

AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice.
SUMMARY: EPA has issued a national
policy statement .entitled "Policy for the
Development of Water Quality-Based
Permit Limitations for Toxic Pollutants."
This policy addresses the technical
approach for assessing and controlling
the discharge of toxic substances to the
Nation's waters through the National
Pollutant Discharge Elimination System
(NPDES) permit program.
FOR FURTHER INFORMATION CONTACT.
Bruce Newton or Rick Brandes, Permits
Division (EN-336). Office of Water
Enforcement and Permits, U.S.
Environmental Protection Agency.
Washington. D.C. 20460.426-7010.
                                                                                                   NPDES  -  13

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                          Federal Register  /  Vol. 49. No. 48 / Friday, March 9. 1984 / Notices
    SUPPLEMENTARY INFORMATION: As the
    water pollution control effort in the
    United States progresses and the
    "traditional" pollutants (oxygen
    demanding and eutrophying materials)
    become sufficiently treated to protect
    water quality, attention is shifting
    towards pollutants that impact water
    quality through toxic effects. Compared
    with the traditional pollutants,
    regulation of toxic pollutants is   •
    considerably more difficult. The
    difficulties include (1) the great number
    of toxic chemicals that may potentially
    be discharged to receiving  waters and
    the difficulties in their analysis; (2) the
    changes in the toxic effects of a
    chemical.resulting from reactions with
    the matrix of constituents in which it
    exists; and (3) the inability to predict the
    effects of exposure to combinations of
    chemicals.
      To overcome some of these  problems,
    EPA and the States have begun to use
    aquatic toxicity tests and various human
    health assessment techniques to
    complement chemical analyses of
    effluents and receiving water samples.
    Because these techniques or their
    application to effluent testing are new,
    EPA and the States have been cautious
    in their  use. Based on EPA's evaluation
    of these techniques and the experiences
    of several States. EPA is now
    recommeding the use of biological
    techniques as a complement to
    chemical-specific analyses to assess
    effluent discharges and express permit
    limitations. EPA has issued these
    recommendations through a statement
    of policy and is developing a technical
    guidance document to help implement
    the policy.
      The complete test of the  national
    policy statement follows:

    Policy for the Development of Water
    Quality-Based Permit Limitations for
    Toxic Pollutants
    Statement of policy
      To control pollutants beyond Best
    Available Technology Economically
    Achievable (BAT), secondary  treatment,
    and other Clean Water Act technology-
    based requirements in order to meet
    water quality standards, the
    Environmental Protection Agency (EPA)
    will use an integrated strategy
    consisting of both biological and
    chemical methods to address toxic and
    nonconventional pollutants from
    industrial and municipal sources. Where
    State standards contain numerical
    criteria for toxic pollutants, National
    Pollutant Discharge Elimination System
    (NPDES) permits will contain limits as
    necessary to assure compliance with
    these standards. In addition to enforcing
specific numerical criteria, EPA and the
States will use biological techniques and
available data on chemical effects to
assess toxicity impacts and human
health hazards based on the general
standard of "no toxic materials in toxic
amounts."
  EPA, in its oversight role, will work
with States to ensure that these
techniques are used wherever
appropriate. Under section 308 and
section 402 of the Clean Water Act (the
Act), EPA or the State may require
NPDES permit applicants to provide
chemical, toxicity, and  instream
biological data necessary to assure
compliance with standards. Data
requirements may be determined on a
case-by-case basis in consultation with
the State and the discharger.'
  Where violations of water quality
standards are identified or projected.
the State will be expected to develop
water quality-based effluent  limits for
inclusion in any issued  permit. Where
necessary, EPA will develop  these limits
in consultation with the State. Where
there is a significant likelihood of toxic
effects to biota in the receiving water,
EPA and the States may impose permit
limits on effluent toxicity and may
require an NPDES permittee  to conduct
a toxicity reduction evaluation. Where
toxic effects are present but there is a
significant likelihood that compliance
with technology-based  requirements will
sufficiently mitigate the effects, EPA and
the States may require  chemical and
toxicity testing after installation of
treatment and may reopen the permit to
incorporate additional limitations if
needed to meet water quality standards.
(Toxicity data, which are considered
"new information" in accordance with
40 CFR 122.62(a){2), could constitute
cause for permit modification where
necessary.)
  To carry out this policy. EPA Regional
Administrators will assure that each
Region has the capability to conduct
water quality assessments using both
biological and chemical methods and
provide technical assistance  to the
States.
Background
  The Clean Water Act establishes two
principal bases for effluent limitations.
First, existing dischargers are required
to meet technology-based effluent
limitations that reflect the best controls
available considering economic impacts.
New source dischargers must meet the
best  demonstrated  technology-based
controls. Second, where necessary.
additional requirements are imposed to
assure attainment and maintenance of
water quality standards established by
the States and approved by EPA. In
establishing or reviewing NPDES permit
limits, EPA must ensure that the limits
will result in the attainment of water
quality standards and protect
designated water uses, including an
adequate margin of safety.
  For toxic and nonconventional
pollutants it may be difficult in some
situations to determine attainment or
nonattainment of water quality
standards and set appropriate limits
because of complex chemical
interactions which affect the fate and
ultimate impact of toxic substances in
the receiving water. In many cases, all
potentially toxic pollutants cannot be
identified by chemical methods. In such
situations, it is more feasible to examine
the whole effluent toxicity and instream
impacts using biological methods rather
than attempt to identify all toxic
pollutants, determine the effects of each
pollutant individually, and then attempt
to assess their collective effect.
  The scientific basis for using
biological techniques has advanced
significantly in recent years. There is
now a general consensus that an
evaluation of effluent toxicity, when
adequately related to instream
conditions, can provide a valid
indication of receiving system impacts.
This information can be useful in
developing regulatory requirements to
protect aquatic life, especially when
data from toxicity testing are analyzed
in conjunction with chemical and
ecological data. Generic human health
effects methods, such as the Ames
mutagenicity test, and structure-activity
relationship techniques are showing
promise and should be used to identify
potential hazards. However, pollutant-
specific techniques are the best way to
evaluate and control human health
hazards at this time.
  Biological testing of effluents is an
important aspect of the water quality-
based approach for controlling toxic
pollutants. Effluent toxicity data in
conjunction with other data can be used
to establish control priorities, assess
compliance with State water quality
standards, and set permit limitations to
achieve those standards. All States have
water quality standards which include
narrative statements prohibiting the
discharge of toxic materials in toxic
amounts. A few State standards have
criteria more specific than narrative
criteria (for example, numerical criteria
for specific toxic pollutants or a toxicity
criterion to achieve designated uses). In
States where numerical criteria are not
specified, a judgment by the regulatory
authority is required to set quantitative
water quality-based limits on chemicals
and effluent toxicity to assure
NPDES -  14

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                      Federal Register / Vol. 49, No. 48 / Friday,  March 9. 1984 / Notices
compliance with water quality
standards.
  Note.—Section 308 of the Acl und
corresponding State statutes authorize FJ'A
and the States to require of the owner/
operator any information reasonably required
to determine permit limits and to determine
compliance with standards or permit limits.
Hiological methods are specifically
mentioned. Toxicity permit limits ttre
authorized under Section 301 And 402 und
supported by Section 101.

Application
  This policy applies to EPA and the
States. The policy addresses the use of
chemical and biological methods for
assuring that effluent discharges are
regulated in accordance with Federal
and State requirements. This policy was
prepared, in part, in response to
concerns raised by litigants to the
Consolidated Permit Regulations (see FR
52079, November 18.1982). Use of these
methods for developing water quality
standards and trend monitoring are
discussed elsewhere (see 48 FR 51400.
November 8.1983 and Basic  Water
Monitoring Program EPA-440/9-76-025).
This policy is part of EPA's water
quality-based control program and does
not supersede other regulations, policy.
and guidance regarding use
attainability, site-specific criteria
modification, wasteload allocation, and
water quality management.

Implementation

State Role
  The control of toxic substances to
protect water quality must be done in
the context of the Federal-State
partnership. EPA will work
cooperatively with the  States in
identifying potential water quality
standards violations, assembling
relevant data, developing appropriate
testing requirements, determining
whether standards are  being violated.
and defining appropriate permit limits.
  Note.—Under sections 303 and 40] of the
Act. States are given primary responsibility
for developing water quality standards and
limits to meet those standards. EPA's role is
to review the Slate standards and limits and
develop revised or additional standards or
limits as needed to meet the requirements of
the Act.

Integration of Approaches
  The'type of testing that is most
appropriate for assessing water quality
impacts depends on the type of effluent
and discharge situation. EPA
recommends that an integrated
approach, including both biological and
chemical techniques, be used to assess
and control water quality. The principal
advantages of chemical-specific
techniques are that (1) chemical
analyses are usually less expensive than
biological measurements in simple
cases: (2) treatment systems are more
easily designed.to meet chemical
requirements than toxicity requirements:
and (3) human health hazards and
bioaccumulative pollutants can best be
addressed at  this time by chemical-
specific analysis. The principal
advantages of biological techniques arc
that (1) the effects of complex
discharges of many known and
unknown constituents can be measured
only by biological analyses: (2)
hinavailability of pollutants after
discharge is best measured by  toxicity
testing: and (3) pollutants for which
there are inadequate chemical  analytical
methods or criteria can be addressed.
  Pollutant-specific, chemical analysis
techniques should be used where
discharges contain few. well-quantified
pollutants and the interactions and
effects of the  pollutants are known. In
addition, pollutant-specific techniques
should be used where health hazards
are a concern or bioaccumulation is
suspected. Biological techniques should
be used where effluents are complex or
where the combined effects of  multiple
discharges are of concern. EPA
recognizes that in many cases both
types of analysis must be used.
Testing Requirements
  Requirements  for dischargers to
collect information to assess attainmenl
or nunattainment of State water quality
standards will be imposed only in
selected cases where the potential for
nonattainment of water quality
standards exists. Where water quality
problems are suspected but there is a
strong indication that complying with
BCT/BAT will sufficiently mitigate the
impacts, EPA recommends that
applicable permits include testing
requirements effective after BCT/BAT
compliance and reopener clauses
allowing reevaluation of the discharge.
  The chemical, physical, and  biological
testing to be conducted by individual
dischargers should be determined on a
case-by-cjse basis. In making  this
determination, many factors must be
considered, including the degree of
impact, the complexity and variability of
the discharge, the water body  type and
hydrology, the potential for human
health impact, the amount of existing
data, the level of certainty desired in the
water quality assessment, other sources
of pollutants, and the ecology  of the
receiving water. The specific data
needed to measure the effect that a
discharger has on the receiving water
will vary according to these and other
factors.
  An assessment of water quality
should, to the extent practicable, include
other point and nonpoint sources of
pollutants if the sources may be
contributing to the impacts. Special
attention should be focused on Publicly
Owned Treatment Works (POTW's)
with a significant contribution of
industrial waste-water. Recent studies
have indicated that such POTW's are
often significant sources of toxic
materials. When developing monitoring
requirements, interpreting data, and  .
determining limitations, permit
engineers should work closely with
water quality staff «t boih the  State and
Federal levels.
  A discharger may be required to
provide data upon request under section
308 of the Act. or such  a requirement
may be included in its  NPDES permit.
The development of a final assessment
may require several iterations of data
collection.-Where potential problems are
identified. EPA or the Stale may require
monitoring lo determine whether more
information is needed concerning water.
quality effects.

Use of Data

  Chemical, physical, and biological
data will be used to determine whether,
after compliance with BCT/BAT
requirements, there will be violations of
State water quality standards  resulting
from the discharge(s). The narrative
prohibition of toxic materials in toxic
amounts contained in all State
standards is the basis  for this
determination taking into account the
designated use for the  receiving water.
For example, discharges to waters
classified for propagation of cold water
fish should be evaluated in relation to
acute and chronic effects on cold water
organisms, potential spawning areas,
and effluent dispersion.
Setting Permit Limitations

   Where violations of water, quality
standards exist or are  projected, the
State and EPA will determine  pollution
control requirements that will attain the
receiving water designated use. Where
effluent toxicity is an appropriate
control parameter, permit limits on
.effluent toxicity should be developed. In
 such cases. EPA may also Require a
 permittee to conduct a toxicity reduction
evaluation. A toxicity  reduction
 evaluation is an investigation conducted
 within  a plant or municipal system to
 isolate the sources of effluent toxicity,
 specific causative pollutants if possible,
 and determine the effectiveness of
 pollution control options in reducing the
 effluent toxicity. If specific chemicals
 are identified as the cause of the water
                                                                                                           NPDES -  15

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                                  Federal Register / Vol. 49, No. 4»,/ Friday. March 9. 1984 / Notices
            quality standards violation, these
            individual pollutants should be limited.
            If a loxicity reduction evaluation
            demonstrates that limiting an indicator
            parameter will ensure attainment of the
            water quality-based effluent toxicity
            requirement, limits on the indicator
            parameter should be considered in lieu
            of limits on effluent toxicity. Such
            indicator limits are not limits on
            causative pollutants but limits
            demonstrated to result in a specific
            toxicity reduction.
            Monitoring

              Where pollution control requirements
            are expressed in terms of a chemical or
            toxicological  parameter, compliance
            monitoring must include monitoring for
            that parameter. If an indicator
            parameter is used based on the results
            of a toxicity reduction evaluation,
            periodic toxicity testing may be required
            to confirm the adequacy of the indicator.
            Where biological data were  used to
            develop a water quality assessment or
            where the potential for water quality
            standards violations exist, biological
            monitoring (including inslream
            monitoring) may be required to ensure
            continuing compliance with  water
            quality standards.
              EPA believes that the intelligent
            application of an integrated  strategy
            using both biological and chemical
            techniques for water quality assessment
            will facilitate the development of
            appropriate controls and the attainment
            of water quality standards. EPA  looks
            forward to working with the States in a
            spirit of cooperation  to further refine
            these techniques.
              Policy signed February 3.1984 by Jack E.
            Ravan. Assistant administrator  for Water.
              Dated: PVbmaiy 1l». 19*4.
            Jack E. Ravan.
            Assistant A •Jniini.itmtor ft>r Wutcr.
            |KR Doc. B4-D44S KilUd 3-A-«4. 64', ...n|
            BILLING CODE W60-SO-M
NPDES -  16

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list of preparers and reviewers

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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 (MWRA), 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

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 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 t Associates, Inc.,  Pawtucket, RI:  Pier Facility Feasibility Study

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

 Grossman Engineering, Inc., Pawtucket, RI;   Traffic Assessment

 E. Raymond Grossman,  P.E.,  President

 C.E. Maguire,  Inc., Providence, RI;  Supplemental Draft  BIS

 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. Weissberg,  Analyst
 John Reinhardt,  Analyst
 R. Roethlisberger,  Analyst

 New England  Environmental Mediation Center,  Bos ton,  MA

 William  Humm,  Executive Director

 Warner fc 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 McKee, Inc.,  Boston, HA:  Consultants to the HWRA

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

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