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
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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:
-------
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.
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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.
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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
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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
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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.
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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.
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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
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PROPOSED
PIER SITE
LONG
ISLAND
Lee Pare & Associates, Inc.
PROPOSED PIER SITE
LONG ISLAND
FIGURE 2
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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.
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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.
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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.
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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.
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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.
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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
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0>
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o
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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
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NOTES
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WOOD PILt
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FHISTIttG GOAWTf BLOCK • I
MARGINAL *HiRF TO SC - -.- '
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valves .n the barte will be opened.
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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.
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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.
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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
£ euif
I
a
- f/ff HACK a
WALKWAf
UOORIH6
DOL PHirvS - -
SLUDCC
TANKCR
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.
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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
-------
II-2
odors
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
RECEPTOR AND PLANT LOCATIONS FOR
ODOR DISPERSION MODEL
BEACHMCNT
DEER 'SLAKQ PRISON
DEER ISLAND
W.W.T R
COiNT ALLERTQNJ
Odor - 10
-------
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
-------
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
-------
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
-------
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
-------
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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V)
13
5 "!»
•2 -1 O1
/09,o Hzs
\~ \4 5
\ I . .
£000 jxy/rt
Odor - 16
Pb
-------
FIG. C5 -
ODOR SVcHT
OF CONC£,VT£A7I3MS OF
FPOM LONG IS LAMP PLANT
&E P&SS6 M rATIV? .?eC£PTO/?S
I
VJ
*T
Q
I
EFFECT
I
a
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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
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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:
-------
II-5
legal and institutional
-------
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
Legal - 4
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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)
Legal - 10
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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.
Legal - 16
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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
Legal - 20
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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
Legal - 22
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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.
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II-6
air toxics
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
II-7
water quality outfall evaluation
-------
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
-------
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
-------
ALTERNATIVE OUTFALL SITES
Figure 1
Water Quality - 3
-------
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
-------
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
-------
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
-------
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
-------
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
-------
II-8
costs
-------
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
-------
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 $40 million was made to
account for the more complicated layouts which would be
expected and for additional problems in scheduling and
executing construction.
In addition, allowances were made for the mitigation of
environmental impacts and for ancillary construction - particularly
bridge repairs - which would be needed to allow construction to take
place. Special cost allowances were also made for bussing and
barging of personnel and materials to the construction site, control
of construction noise, provisions for local recreational facilities,
special treatment for visual enhancement, bridge
rehabilitation/replacement and archaeological preservation. Table
C-l shows the costs of these items, by site option and the
assumption of the presence or absence of the existing institutions
on each island.
The differences in such costs amongst the alternatives were in the
areas of bridge rehabilitation, visual enhancement, local recreation
and the need for control of construction noise. The differences in
the bridge costs reflect the estimated cost for replacement of the
two smaller bridges on the approach to Deer Island, versus the cost
for replacement of the large span bridge from Moon Island to Long
Island. Costs allowances for visual enhancement on the Long Island
site were higher because the island has more shoreline, and because
it was expected that the plant construction would result in greater
change to the landform. Local recreational opportunities were
judged to be possible at Deer Island, but not at Long Island. And
finally, allowances for some form of construction noise control were
provided for both Islands with the institutions in place, but only
at Deer Island if the institutions were removed.
Costs - 2
-------
TABLE C-l
POTENTIAL MITIGATION EXPENDITURES
($ 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
-------
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
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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.
Historical - 2
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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
Historical - 4
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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.
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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
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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.
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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.
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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-
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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''
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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.
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Figure 35: Superintendent.' s Office, 1985
l-'i pin- .': S i I
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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.
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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.
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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.
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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.
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,?— -•-•"
St.al \:>li. i. H
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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
-------
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
-------
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
Chlorine - 5
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
(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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
11-13
disposal of properties on Deer Island by GSA
-------
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
-------
GSA - 2
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
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Pathogens - 16
-------
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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
11-17
EPA draft permit for secondary treatment
-------
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
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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.
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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.
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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.
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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
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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
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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.
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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.
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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.
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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
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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
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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.
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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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Bibliography - 10
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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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