Final TEnvir^n/$ieiital
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VOLUME III
PUBLIC PARTICIPATION and
RESPONSE to COMMENTS
Final Environmental Impact Statement
SITING
of
WASTEWATER
TREATMENT FACILITIES
for
BOSTON HARBOR
Prepared by-
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION I
Technical Assistance by;
THIBAULT/ BUBLY ASSOCIATES
PROVIDENCE. RHODE ISLAND
MICHAEL R. DELAND Date
Regional Administrator, U.S. EPA, Region I
This Final Environmental Impact Statement has been prepared
by the U.S. Environmental Protection Agency (EPA) with
/>>' ^^^ V assistance from the General Services Administration as a
5 t^SSv* £ Cooperating Agency under the requirements of the National
Environmental Policy Act. The FEIS identifies and evaluates
the environmental impacts of various site options for waste-
water treatment facilities for treating Greater Boston's
wastewater in compliance with federal and state water
pollution control laws.
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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 accepta-
bility of alternative locations for the construc-
tion of new wastewater treatment facilities for
Boston Harbor. The FEIS recommends the construc-
tion of a secondary wastewater treatment facility
at Deer Island.
VOLUMES:
I. COMPREHENSIVE SUMMARY
II. TECHNICAL EVALUATIONS
III. PUBLIC PARTICIPATION AND RESPONSE TO COMMENTS
IV. PUBLIC AND INTERAGENCY COMMENTS
LEAD AGENCY:
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION I
JFK Federal Building, Boston, Massachusetts 02203
COOPERATING AGENCY:
GENERAL SERVICES ADMINISTRATION
TECHNICAL CONSULTANT:
THIBAULT/BUBLY ASSOCIATES
Providence, Rhode Island
FOR FURTHER INFORMATION:
Mr. Ronald Manfredonia
Water Management Division
U.S. EPA, Region I
JFK Federal Building
Boston, MA 02203
617-223-5610
FINAL DATE BY WHICH
COMMENTS MUST BE RECEIVED:
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FINAL ENVIRONMENTAL IMPACT STATEMENT
SITING OF WASTEWATER TREATMENT FACILITIES IN BOSTON HARBOR
PUBLIC PARTICIPATION AND RESPONSE TO COMMENTS
VOLUME III
INTRODUCTION
This document, Volume III of the Final Environmental Impact
Statement (FEIS")on the Siting of Wastewater Treatment Facilities
in Boston Harbor, is one of four volumes prepared to:
o respond to comments raised on the Supplemental Draft
Environmental Impact Statement published on December 31,
1985,
o meet EPA's obligations under the National Environmental
Policy Act (NEPA).
The other volumes of the FEIS are:
Volume I - Comprehensive Summary
Volume II - Technical Evaluations
Volume IV - Public and Interagency
Comment
Volume III describes the public's involvement in the EIS process,
summarizes the questions and comments made concerning the SDEIS,
gives EPA responses to these concerns.
and
following sections:
It consists of the
Introduction
Glossary of
Section 1 -
Section 2 -
Section 3 -
Agency And Document Names
Public Participation Program Summary
Citizens Advisory Committee (CAC)
Recommendations
Summary of
and Agency
Public Comment
Responses
on SDEIS
Page i
Page ii
Page 1-1
Page 2-1
Page 3-1
A - Suitability of Deer Island as a Treatment Site
B - Suitability of Long Island as a Treatment Site
C - Suitability of Nut Island as a Treatment Site
D - Neighborhood Impacts
E - Health and Safety
F - Mitigation and Compensation
G - Omissions and/or Inadequacies of SDEIS Document
H - Level of Treatment
I - Water Quality Issues
J - Equitable Distribution of Regional Facilities
K - Decision Criteria
L - Segmentation Issue (Related Pollution Issues)
M - Growth of the System
N - Satellite (Subregional) Treatment
0 - Massachusetts Water Resources Authority (MWRA)
P - Public Participation
Note: See Volume IV - Public and Interagency Comment
copy of all letters/comments received.
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for a
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GLOSSARY OF AGENCY AND DOCUMENT NAMES
Agencies:
EPA - Environmental Protection Agency
EOEA - Executive Office of Environmental Affairs
MWRA - Massachusetts Water Resources Authority
MDC - Metropolitan District Commission
DWPC - Division of Water Pollution Control
Documents:
SDEIS - Supplemental Draft Environmental Impact Statement
FEIS - Final Environmental Impact Statement
DEIR - Draft Environmental Impact Report
FEIR - Final Environmental Impact Report
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GLOSSARY
advanced primary/intermediate
wastewater treatment:
The additional treatment, often using
chemicals, of sewage beyond primary
levels but less than secondary treatment.
bacteria: Single-celled microorganisms
that lack chlorophyll. Some cause dis-
eases, others aid in pollution control by
breaking down organic matter.
biochemical oxygen demand (BOD): The
dissolved oxygen required to decompose
organic matter in water. It is a measure of
pollution since heavy waste loads have a
high demand for oxygen.
chlorination: The application of chlorine
to drinking water, sewage, or industrial
waste to disinfect or to oxidize undesira-
ble compounds.
dissolved oxygen (DO): A measure of the
amount of oxygen available for biochemi-
cal activity in a given amount of water.
Adequate levels of DO are needed to
support aquatic life. Low dissolved oxy-
gen concentrations can result from inade-
quate waste treatment.
dredging: To remove earth from the
bottom of water bodies using a scooping
machine. This disturbs the ecosystem and
causes silting that can kill aquatic life.
environment: The sum of all external
conditions affecting the life, development
and survival of an organism.
environmental impact statement (EIS): A
document required of Federal agencies by
the National Environmental Policy Act
for major projects or legislative proposals.
They are used in making decisions about
the positive and negative effects of the
undertaking
fecal coliform bacteria: A group of orga-
nisms found in the intestinal tracts of
people and animals. Their presence in
water indicates pollution and possible
dangerous bacterial contamination.
headworks: A screening and degriting
operation.
incineration: Disposal of solid, liquid or
gaseous wastes by burning.
infiltration: Groundwater that seeps into a
sewer through cracks and joints.
inflow: Water, other than sewage, which
enters a sewer through openings such as
manholes and tidegates.
interceptor sewers: The collection system
that connects main and trunk sewers with
the wastewater treatment plant. In a
combined sewer system interceptor, sewers
allow some untreated wastes to flow
directly into the receiving streams so the
plant won't be overloaded.
lateral sewers: Pipes running underneath
city streets that collect sewage.
leaching: The process by whch nutrient
chemicals or contaminants are dissolved
and carried away by water, or are moved
into a lower layer of soil.
methane: A colorless, nonpoisonous, flam-
mable gas emitted by marshes and dumps
undergoing anaerobic decomposition, or
produced as a byproduct of waste treat-
ment process.
mgd: Millions of gallons per day. Mgd is
a measurement of water flow.
mitigation: Mitigation includes: (a) Avoid-
ing the impact altogether by not taking a
certain action or parts of an action, (b)
Minimizing impacts by limiting the degree
or magnitude of the action and its
implementation, (c) Rectifying the impact
by repairing, rehabilitating, or restoring
the affected environment, (d) Reducing or
eliminating the impact over time by
preservation and maintenance operations
during the life of the action, (e) Compen-
sating for the impact by replacing or
providing substitute resources or environ-
ments. (U.S. Council on Environmental
Quality, 1978)
outfall: The place where an effluent is
discharged into receiving waters.
plume: Visible emission from a flue or
chimney, or the effluent from a treatment
plant outfall pipe.
pollutant: Any introduced substance that
adversely affects the usefulness of a
resource.
ppm: Parts per million; a way of express-
ing tiny concentrations. In air, ppm is
usually a volume/volume ratio; in water,
a weight/volume ratio.
pretreatment: Processes used to reduce the
amount of pollution in water before it
enters the, sewers or the treatment plant.
primary treatment: The first stage of
wastewater treatment; removal of floating
debris and solids by screening and
sedimentation.
pumping station: A machine installed on
sewers to pull the sewage uphill. In most
sewer systems, wastewater flows by grav-
ity to the treatment plant.
raw sewage: Untreated wastewater.
scope: Scope consists of the range of
action, alternatives, and impacts to be
considered in an environmental impact
statement.
secondary treatment: Biochemical treat-
ment of wastewater after the primary
stage, using bacteria to consume the
organic wastes. Use of trickling filters or
the activated sludge process, removes
floating and settleable solids and about 90
percent of oxygen demanding substances
and suspended solids. Disinfection with
chlorine is the final stage of secondary
treatment.
sewage: The organic waste and wastewater
produced by residential and commercial
establishments.
sewer: A channel that carries wastewater
and storm water runoff from the source to
a treatment plant or receiving stream.
Sanitary sewers carry household and
commercial waste. Storm sewers carry
runoff from rain or snow. Combined
sewers are used for both purposes.
suspended solids (SS): Tiny pieces of
pollutants floating in sewage that cloud
the water and require special treatment to
remove.
tertiary treatment: Advanced cleaning of
wastewater that goes beyond the secon-
dary or biological stage. It removes
nutrients such as phosphorus and nitrogen
and most suspended solids.
wastewater: Water carrying dissolved or
suspended solids from homes, farms,
businesses, and industries.
ill
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public participation program summary
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SECTION 1
PUBLIC PARTICIPATION PROGRAM SUMMARY
I. INTRODUCTION
Public participation is an important consideration in any
investigation of environmental impact. Public involvement
throughout the Environmental Impact Statement (EIS) process can
ensure that the resulting plans, recommendations and policies
are not only technically appropriata, but also politically and
socially acceptable, and likely to be implemented. The
complexity of issues and concerns, and the large number of
communities, interest groups, and government agencies involved in
this EIS increase the need for organized and integrated public
participation.
The public participation program designed for this EIS
performs two basic functions:
o provides the public with information on the EIS
process and the technical investigations performed
for the EIS
o creates opportunities for the public to provide
input and consultation to the EIS study team
and responsible agencies.
Several major public participation activities fulfilled these
functions. Each public participation event provided the
participants with the facts and background information needed to
make informed comments and ask pertinent questions. Public
participation activities were designed and planned in close
collaboration with the technical study team. Meetings,
workshops, exercises and questionnaires were structured to
provide the study team with specific information it needed, while
offering opportunities for general, less structured comments from
the participating public. The major public participation
activities were timed to provide public input at points in the
EIS process when important decisions were about to be made by the
study team. The activities and services provided to support the
public participation program are explained later in this section.
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II. MAJOR PUBLIC PARTICIPATION ACTIVITIES
1) Public Participation Coordination
Management and coordination are required for the success of a
public participation program. Barry Lawson Associates, Inc.
provided overall management, coordination, and production of
materials for this public participation program with Barry R.
Lawson as project manager and Ann Jacobson and Edward lonata as
public participation coordinators.
2) Planning
A public participation workplan was developed by
representatives of the U.S. Environmental Protection Agency
Region I (EPA), the technical consultants, and the staff of
Barry Lawson Associates. The workplan includes all of the
activities and services summarized in this appendix and permits
ongoing evaluation and modification of the plan to meet changing
conditions.
3) Formation and Support of Citizens' Advisory Committee
A twenty-six member Citizens' Advisory Committee (CAC) was
appointed in October 1983, by Michael Deland, Regional
Administrator, EPA, to assist and advise the study team.
Nominations for CAC members were solicited from concerned
groups representing affected communities, and environmental,
recreational, business, and governmental interests. The
members have held regular monthly meetings and occasional task
force meetings since their appointment. Attendance at CAC
meetings has averaged 18 members, representatives, and staff
persons.
(A detailed explanation of the role of the CAC is found in
the first set of CAC recommendations, page 2-3 of this volume)
When EPA reopened nominations for new CAC members in in June
1985, one member resigned and two new members joined the
committee. A list of current CAC members is included in Section
2 of this volume.
The CAC has worked diligently with EPA and the consultants to
become familiar with the issues examined in the EIS and has
offered insightful comments at every stage of the EIS process.
Members participated in structured exercises to assess the
importance of various siting impacts and to develop potential
mitigation methods.
In June 1984, the CAC offered testimony before the state
legislature supporting the establishment of a Massachusetts Water
Resources Authority.
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The members of the CAC produced a two reports summarizing
their concerns and recommendations regarding wastewater treatment
plant siting in Boston Harbor, which are included as section 2
of this volume.
Results of CAC exercises performed before the printing of the
SDEIS are reported in Volume 2, section 10.2.3. In June 1985 the
CAC took part in a demonstration of the method EPA was
considering to assist the technical staff in making the siting
decision. While individual CAC members completed the exercise,
no clear concensus on a siting choice was reached by the group.
The group did agree that the method used by EPA was thoughtful
and functional, and was a satisfactory effort toward a final
decision making tool.
Barry Lawson Associates is responsible for coordinating the
activities of the CAC, producing meeting agendas and minutes,
assisting the CAC in document and testimony preparation and
keeping CAC members supplied with current EIS information.
4) Formation and Support of Technical Advisory Group
A thirty-five member Technical Advisory Group (TAG) was
formed in October 1983, to provide technical assistance to the
study team and create a forum where study results could be
presented to concerned public agencies for discussion. The
members of the TAG were appointed by local, state, and federal
agencies interested in the project. The TAG met periodically
during the initial stages of the study and less frequently in the
middle stages (using discussions between individual TAG members
and the consultant as forums for review). After the release of
the SDEIS, the TAG once again began meeting monthly advise and
monitor the additional technical studies conducted for the final
EIS,
A list of current TAG members appears as table 1-1.
5) Production and Distribution of Newsletters
A series of newsletters entitled Boston Harbor Update
has been produced and distributed to all individuals and agencies
on the project mailing list. The Update is circulated to
approximately 1500 readers. Six Updates have been published to
date, informing the public on study progress and upcoming public
participation events. A seventh Update is will announce the
schedule for public hearings on this EIS. A final Update will
announce EPA's final decision (Record of Decision of the Regional
Administrator)
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Table 1-1
TECHNICAL ADVISORY GROUP
Sandy Uyterhoven
Mass. Water Resources Authority
One Center Plaza, 7th floor
Boston, MA 02108
Mr. Daniel Bubly
Thibault/Bubly Associates
235 Promenade Street
Providence, RI 02908
Mr. Chris Mantzaris
Habitat Protection Branch,
National Marine Fisheries
Federal Building - 14 Elm Street
Gloucester, MA 01930
Joseph Horowitz
Impact Analysis Branch, Pig. Div,
U.S. Army Corps of Engineers
424 Trapelo Road
Waltham, MA 02154
Mr. Ken Jackson
Regulatory Branch
U.S. Army Corps of Engineers
424 Trapelo Road
Waltham, MA 02154
Mr. Howard Larson, Reg. Dir.
U.S. Fish and Wildlife Service
1 Gateway Center
Newton Corner, MA 02158
Mr. Jim Mikolaites
U.S. Fish and Wildlife Service
P.O. Box 1518 - 55 Pleasant St.
Concord, N.H. 03301
Mr. Michael Frimpter
U.S. Geological Survey
150 Causeway Street
Boston, MA 02114
Mr. William Patterson,
Regional Environmental Officer
U.S. Department of Interior
1500 Custom House
165 State Street
Boston, MA 02109
Attn: Lois Rich
Lt. Commander Allen Boetig
U.S.C.G. Marine Safety Div.
First Coast Guard District
150 Causeway Street
Boston, MA 02114
Ms. Beverly Boyle
A-95 Coordinator
Executive Office of
Communities and Development
100 Cambridge St. - 9th Fl.
Boston, MA 02202
Ms. Evelyn Murphy, Secretary
Executive Office of
Economic Dev. & Manpower Affairs
1 Ashburton Place
Boston, MA 02108
Ms. Cheryl Breen
Office of Coastal Zone Management
20th Floor - 100 Cambridge Street
Boston, MA 02202
Mr. Sam Mygatt, Executive Director
Environmental Impact Review
MEPA Unit
20th Floor - 100 Cambridge Street
Boston, MA 02202
Mr. Jim Baecker
Department of Environmental Mgmt.
225 Friend Street
Boston, MA 02114
Mr. Emerson Chandler
Water Resources Commission
100 Cambridge Street
Boston, MA 02202
Mr. Steven Lipman
DEQE
1 Winter Street-7th Floor
Boston, MA 02108
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Table 1-1
TECHNICAL ADVISORY GROUP
Mr. Ron Lyberger
Div. of Water Pollution Control
1 Winter Street
Boston, MA 02108
Mr. Eugene Kavanaugh
Division of Water Ways
1 Winter Street
Boston, MA 02108
Mr. Leigh Bridges, Director
Division of Marine Fisheries
19th Floor - 100 Cambridge St.
Boston, MA 02202
Ms. Valerie Talmage, Exec. Dir.
Massachusetts Historic Commission
294 Washington Street
Boston, MA 02108
Ms. Roberta Ellis
Massport Planning Division
10 Park Plaza
Boston, MA 02116
Mr. Martin Pillsbury
Metropolitan Area Planning Council
110 Tremont Street
Boston, MA 02108
Mr. Noel Barratta, Director
MDC Sewerage Division
20 Somerset Street
Boston, MA 02108
Mr. Justin Radlow
Bureau of Project Development
Department of Public Works
100 Nashua Street
Boston, MA 02114
Mr. David" Graber
118 Larson Road
Stoughton, MA 02072
Mr. Paul Anderson
55 Sea Street
Quincy, MA 02169
Mr. David Standley
4 Spillers Lane
Ipswich, MA 01938
Mr. Peter Scarpignato
Department of Public Facilities
26 Court Street - 6th Floor
Boston, MA 02108
Mr. Ronald Jones
Office of Environmental Affairs
Department of Health and Hospitals
Administration Building Mezzanine
818 Harrison Avenue
Boston, MA 02108
Ms. Libby Blank
Boston Water and Sewer Commission
10 Post Office Square
Boston, MA 02109
Ms. Kathleen Castagna
Project Manager
U.S. Environmental Protection Agency
Room 2103 - J.F.K. Building
Boston, MA 02203
Mr. Stewart Jacobson
Suffolk County Extension Service
U. Mass - Downtown Center
Boston, MA 02125
Senator LoPresti
Room 213c
State House
Boston, MA 02133
Attention: Susan Rozzi
Mr. Ronald Manfredonia
U.S. EPA
Room 2103
J.F.K. Building
Boston, MA 02203
Mr. Daniel Garson
Lombardo and Associates
149 Staniford Street
Boston, MA 02114
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6) Production of Public Meetings and Workshops
Several public meetings and workshops have been organized
during this project to seek input from the general public at key
decision-making junctures. In September 1983, two public scoping
meetings and one agency scoping meeting were held. One hundred
members of the general public and twenty-one representatives of
concerned agencies attended and offered opinions on the scope of
work for this SDEIS.
A public workshop was held in November 1983 to identify and
discuss factors which should be considered in the technical
process to screen project options. Sixty people attended
and identified important factors they wished analyzed. Results
of this workshop were reported in section 10.2.2 of the SDEIS.
Two public meetings were held during January 1984 to obtain
public reaction to EPA's recommendation of six sites for further
study. One meeting was held in each of the two communities where
major impacts were likely to occur: Winthrop and Quincy.
Approximately one hundred people attended each meeting and
enthusiastically voiced a wide variety of concerns. A summary of
the comments made at these meetings was published as Appendix A
of the Report of Final Screening Results (May 16, 1984).
A public workshop was held in August 1984 to update the
public on the progress of the SDEIS, introduce and gather opinion
on the factors being considered in siting decisions, and elicit
public comment on potential mitigation and compensation measures.
Thirty-five members of the public attended and discussed these
issues with project staff. Results of this workshop (including
an opinion survey) were also reported in section 10.2.2 of the
SDEIS.
Three public information meetings were held in February 1985
to explain the findings of the EIS and allow for direct dialogue
between the the EIS team and the public. The meetings were held
in Quincy, Winthrop, and Cambridge and were attended by nearly
300 people.
Three public hearings on the SDEIS were held in late February
and early March 1985 in Cambridge, Winthrop, and Quincy.
Approximately 4000 people attended these hearings, which resulted
in 646 pages of testimony by witnesses ranging from Congressmen
to middle school students. A summary of the public comment and
agency response to SDEIS issues appears as Section 3 of this
volume.
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III. SUPPORT SERVICES
1) Mailing List Maintenance
A mailing list of approximately 1200 concerned citizens,
organizations, agencies, and media outlets was developed and is
continually updated. The list is used for distribution of the
"Boston Harbor Update" and announcements of public participation
events. The list has been loaned to many organizations concerned
with Boston Harbor, including the Massachusetts Water Resources
Authority. Separate CAC and TAG lists are maintained for
mailings to those groups.
2) Media Relations
Barry Lawson Associates acts as a source of EIS information
for media personnel and encourages coverage of EIS public events.
3) Information Depositories
Information concerning the SDEIS has been distributed to
libraries in Boston, Quincy, Wellesley, and Winthrop. The
libraries were provided with binders to file the information and
updated EIS information is sent periodically.
4) Field Trips
Field trips were organized to allow the TAG and CAC members
to view the Nut Island and Deer Island wastewater treatment
facilities and to view Boston Harbor by boat. A tour of the
Greater Lawrence Sanitary District treatment plant was held in
September 1985 to allow CAC members to examine a modern secondary
treatment plant.
5) Summaries
Summaries and analyses of all public workshops and meetings
were prepared by Barry Lawson associates for use by the study
team.
6) Management
A collection of miscellaneous tasks are carried out to
support the public participation program. A project telephone
number and a post office box are maintained and advertised to
provide public access to the public participation coordinator.
Requests for information or documents from concerned citizens
agencies, and media personnel are processed continually. Barry
Lawson Associates staff provides advice to the study team
regarding public communications and analysis of opinion data.
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7) Evaluation
The public participation program was evaluated by members of
the study team in April 1984 and June 1985 and is continuously
evaluated and modified as the EIS progresses. A final evaluation
by the study team, the CAC, and the TAG is planned during the
review period for the final EIS.
IV. CONCLUSION
The public participation program for this EIS is producing a
diversity of information. The study team has been provided with
detailed comments and opinions on study design, impacts, and
mitigation and compensation for the various options. Public
input has been extensively incorporated into the work of the
study team and plans are in place to ensure the same or greater
levels of public involvement for the remainder of this project.
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in-a
citizen advisory committee
recommendations
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SECTION 2
CITIZEN ADVISORY COMMITTEE RECOMMENDATIONS
The Citizens Advisory Committe formed by EPA for this project
has produced two sets of recommendations on siting wastewater
treatment plants and more generally, cleaning up Boston Harbor.
The first set of recommendations were drafted during the SDEIS
phase of this project. This set was distributed by the CAC to
approximately 150 decisionmakers and interested parties involved
in the issues surrounding the harbor.
The CAC also has drafted a second set of recommendations
which take into consideration additional work and studies done
since the release of the SDEIS. The CAC continues to strongly
support its first set of recommendations, and considers the
second set an amendment which adds detail and emphasis to some
points raised in the first set while also bringing some new
concerns to light.
The CAC sincerely hopes that all decisionmakers involved will
seriously consider both sets of recommendations when determining
the future of harbor cleanup efforts.
Both sets of recommendations follow.
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RECOMMENDATIONS ON WASTEWATER TREATMENT FACILITIES
FOR
BOSTON HARBOR
Citizen Advisory Committee
Supplementary Draft Environmental Impact Statement
Boston Harbor Wastewater Facilities Siting
August 1984
Prepared with the assistance of:
Barry Lawson Associates, Inc.
P.O. Box 648
Concord, Massachusetts 01742
C.E. Maguire, Inc.
One Davol Square
Providence, Rhode Island 02903
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I. Introduction: The Role of the Citizen Advisory Committee
The Boston Harbor Wastewater Treatment Facilities Siting
Citizen Advisory Committee (CAC) was established in the Fall of
1983 to assist the United States Environmental Protection Agency
and the consultants under contract in the preparation of the
Supplementary Draft Environmental Impact Statement(SDEIS) for the
siting of wastewater treatment facilities in Boston Harbor.
The CAC is a major element of the comprehensive public
participation program designed for the EIS. The following
advisory functions were considered for the CAC when it was
established:
o providing a direct link to the wider community
interested in and affected by waste treatment in
Boston Harbor;
o assisting in the development, implementation
and monitoring of the public participation
program;
o commenting on the progress and conclusions of
the SDEIS [and EIS];
o providing information to others about the
project and its likely impacts;
o assisting the project team in gathering and
understanding the concerns and opinions of the
publics affected by the project;
o advising the project staff on the scope of the
study and offering members' representative
perspectives on the viability of options being
considered.
The CAC members were nominated from a cross-section of
environmental, community, government, and business interest
groups. The underlying factor uniting the members of this group
was a desire to ensure that Boston Harbor returns to being a
healthy, useful, and beautiful resource for the benefit of all,
and that undesirable impacts of wastewater facilities
construction and operation be minimized and borne as equitably as
possible. The CAC has worked diligently to perform all of the
functions considered for the group when it was established.
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There is general agreement within the CAC that the present
wastewater treatment situation in Boston Harbor is deplorable.
The factors outlined in Chapter 1, Volume 1 (Purpose and Need for
Action) of the SDEIS are of great concern to the CAC. Boston
Harbor and the communities surrounding it are being continually
polluted because of poor planning, inadequate maintenence, and
improper operation of an out-dated and over-burdened wastewater
system. The members of the CAC view the harbor as a valuable
economic, recreational, residential, and esthetic resource that
is well worth cleaning up and preserving, and are equally
concerned about the impacts of construction of wastewater
treatment facilities on the communities where they will be built
and operated.
The CAC has met once per month and a task force subcommittee
has met at two week intervals between committee meetings. Members
have been continually briefed by the engineering consultant on
the progress of the study while it was underway. The CAC offered
advice on factual details and data accuracy directly to
the consultants and this advice is incorporated into the analysis
and conclusions of the SDEIS [and EIS].
This section describes the major concerns and recommendations
of the CAC regarding the larger issues of wastewater treatment in
Boston Harbor.
The opinions and recommendations of the CAC must be viewed
with the realization that they arise from a group that has worked
long and hard with EPA, the consultants, and members of the
communities and groups represented in order to gain a full and
balanced understanding of the problems facing those who must
determine siting for wastewater treatment facilities in Boston
Harbor. It is the hope of the CAC that these ideas will have
impact on the decisionmakers for this necessary and important
project.
II. Recommendations
1) Planning and Growth
The construction of wastewater treatment facilities for the
MDC sewer system is of obvious importance, but is only one
component of a broader planning and improvement program which
must be undertaken if the current situation in Boston Harbor is
to be remedied. The following planning issues must be addressed
if the construction of new treatment facilities or the
rehabilitation of old facilities is to have any lasting positive
effect:
a long term, integrated plan for improving
Boston Harbor must be developed and the issues of
combined sewer overflows, dry weather overflows,
extraneous sources of flow, and all sources of
pollution must be considered in this plan;
expansion of the present system to communities
not currently included in the system should not be
allowed;
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expansion within communities in the system
beyond the system's ability to provide adequate service
should not be allowed;
a prioritized schedule of projects should be
developed to ensure implementation of short term and
long term projects is coordinated and integrated so
that improvements to the harbor begin soon and continue
into the future;
the possibility of building satellite treatment
plants to reduce flow to the current treatment system
and to allow expansion of communities must not be
abandoned. Siting possibilities for satellite plants
should not be limited to those included in the EMMA
study, and new technologies should be examined as
possible solutions to upstream problems;
disposal of sludge produced by the proposed
facilities must be studied and planned for. Public
input must be sought before the facilites are
constructed. Alternative modern sludge treatment
methods should be examined and pre-treatment of
industrial wastes should be more extensive to remove
toxic products from sludge and make it more useful as a
fertilizer. Current pre-treatment efforts are not
acceptably implemented and enforced. Planning for land
disposal of sludge must be coordinated with water
supply managers to protect the watershed where disposal
will take place.
some members of the group feel that, because of
project timing, additional State funds should continue
to be made available for upgrading existing MDC [MWRA]
treatment plants without further delay. Sewage rates
should be increased as soon as possible to build up
funding for the proposed facilities. These two items
will show good faith for implementation on the part of
the Commonwealth and the MDC [MWRA] or whatever agency
assumes control and will enhance public awareness of
the situation.
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2) Facility Operation
The following recommendations are made regarding the
operation of the proposed facilities in an attempt to avoid the
types of management and operation problems currently taking place
in the MDC [MWRA] treatment facilities:
establish a fiscally independent, self
supporting metropolitan water resources authority
similar to the body proposed in Massachusetts House of
Representatives Bill HR 5915 with modifications to
ensure more representation of communities where
facilities will be sited [legislation has been passed
creating the Massachusetts Water Resources Authority
(MWRA)];
facilities must be designed for optimum
continual performance at normal and peak flows;
facilities must be designed with a planned
lifetime and replacement or refurbishment at the end
of this lifetime must be provided for;
operation, maintenence, and repair of facilities
must be carried out by trained professionals and must
be budgeted as part of the project (some members of
the CAC have suggested that the facilities should be
operated by private firms under contract). If
secondary treatment is the chosen option, a higher
degree of training and sophistication will be required
of the operating personnel;
operations issues such as noise, odor, visual
esthetics and traffic created by facility employees,
chemical deliveries, and sludge removal must be
planned for and mitigated with the communities where
the facilities will be built before construction takes
place.
3) Facility Siting Options
The field of options recommended by the consultant and EPA at
the time this document was produced was still quite large. The
CAC has chosen to provide decision makers with a list of factors
influencing siting decisions rather than examining each potential
option individually. These factors will come into play at any
site chosen and it is the intent of the CAC that describing the
factors of major concern will provide decision makers with a
gauge of public opinion to measure their decisions. Not all of
the factors listed below are the views of all members; those that
are not are so noted.
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Neighborhood Concerns - CAC members representing the
communities of Winthrop and Quincy are generally
opposed to any new facility development within their
communities. Members of both communities feel that
their neighborhoods are currently overburdened by the
operation of the present facilities and Winthrop
members point out that they also are impacted by Logan
Airport and the Suffolk County House of Correction.
From a neighborhood viewpoint, favorable siting would
occur with plant locations at a greater distance from
residential sections than now existing at Deer or Nut
Islands.
Mitigation and Compensation - there is a general
consensus that the communities where facilities will
be built must be compensated in some way for
unavoidable adverse impacts generated by the
construction and operation of facilities. Efforts
must be made to mitigate as many impacts as possible
and to provide substantial, guaranteed, long-term
compensation for remaining impacts. Citizens of the
communities involved must be allowed to take an active
part in determining mitigation/compensation plans,
plans must be in place before construction begins, and
mechanisms must exist to modify plans if projected
conditions change. A representative body should be
formed to ensure that the interests of impacted
residents are continually taken care of and a
mechanism of appeal should be established to provide
unsatisfied residents with a means of resolution.
The CAC wishes to emphasize that sewage
treatment is the responsibility of all communities in
the MDC region and that just compensation be made to
those communities which bear the burden of treatment
facility impacts.
Long Island - division within the group exists
concerning Long Island as a potential site. Some
members feel that the recreational potential, the
historic and archaeological value, and the relatively
untouched condition of portions of Long island warrant
protection and preservation, while the sites on Deer
and Nut Islands are already greatly impacted and (with
adequate mitigation measures) would not be greatly
changed by further construction.
Other members of the group, particularly those
representing Quincy and Winthrop, feel strongly that
neighborhood concerns greatly outweigh the
recreational, archaeological, and conservation
potentials of Long Island and would rather see a
project impact "bones, trees, and arrowheads" than the
health and safety of living people.
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There is consensus that if Long Island is not
considered as a viable option because of its
recreational/historic value, assurances must be made
that the island will indeed be preserved indefinitely.
The CAC does not want to see the island spared from
development as a wastewater treatment facility only to
be developed as residential or industrial land by the
City of Boston.
Satellites - the prospect of satellite treatment
plants should not be abandoned. There is concern
among some CAC members that the list of sites
considered for satellite plants, which arose from the
1978 EMMA study, was too restricted and that more
sites could be evaluated. [ A proposal by Quincy
Shores Associates regarding satellite plants was
examined as part of the evaluation ]. Satellites
could play a valuable role in reducing flows to Boston
Harbor facilities and allowing future expansion of
community systems.
Other Sites - it is the opinion of a few members of
the group that the list of options considered for this
project was not extensive enough and that other
places, in particular Moon Island, should have been
seriously studied as possible sites, because they
could offer sites where immediate action could take
place with a minimum of community and neighborhood
impact.
Fast-Track Improvements - under no circumstances
should a "no action" option be considered after the
current fast-track improvements are complete. The
upgrading to 1968 standards of wastewater treatment
plants now in place should never be accepted as a long
term solution to the problems of Boston Harbor.
4) Levels of Treatment
The members of the CAC share an enthusiastic concern for the
water quality of Boston Harbor, but temper their enthusiasm with
knowledge of the limitations of time, money, and technology and a
realization of the trade-offs involved. It is a general
conclusion within the group that the dumping of sludge and
untreated sewage into Boston Harbor must stop as soon as
possible.
some group members feel that pending decision on
MDC's 301(h) waiver application should be granted
allowing upgraded primary treatment with long
outfalls because any untreated sewage produced by
wastewater treatment facility malfunction would be
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carried out of the harbor, [decision has been made to
deny the waiver, requiring secondary treatment]
other members see the project resulting from
this SDEIS [and EIS] as an opportunity to upgrade to
secondary treatment, an opportunity which they feel
will be precluded if primary plants are built.
concerns exist among some members about the
effects of long outfalls on Massachusetts Bay.
primary treatment is unacceptable without long
outfalls and adequate pumping capability.
some members feel that the expense of
constructing secondary treatment plants along with
long outfalls is justified and should be considered.
concerns exist about sludge disposal and there
are further concerns regarding the additional sludge
produced by secondary treatment. Additional planning
and investigation into using sludge as a resource
(fertilizer) is called for.
alternatives to chlorination as a disinfection
method should be investigated.
sludge incineration should not be considered
because of its negative impacts on air quality.
5) Construction Impacts
The construction or rehabilitation of a wastewater treatment
facility will undoubtedly affect neighboring residential areas at
any of the proposed sites. Members of the CAC share the view
that mitigation of construction impacts is of extreme importance.
They are very concerned about the safety and comfort of people
living in the affected area. They also realize that any
undesirable conditions created by construction must be tolerated
for the relatively long construction period of five to ten years.
The following are the group's suggestions :
every effort should be made to reduce
construction related highway traffic through
residential communities. Roads in the potentially
impacted communities (Quincy and Winthrop), although
busy at times, do not currently carry much heavy
trucking. Roads leading to the proposed site carry
very little truck traffic. There is great concern
about the safety of other drivers and pedestrians if
narrow, residential roads are pressed into service as
truck routes.
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barging should be used to transport personnel
and materials to the construction site whenever
possible.
mass transit should be utilized by construction
and operation personnel as an effort to reduce
traffic.
periods of traffic activity to the construction
site should be timed so as to not interfere with
normally busy traffic times in neighborhoods.
an organized method of compensation for possible
damages to property (private and public) caused by
trucking or construction must be established before
construction begins. A mechanism of compensation must
be developed to account for the decrease in property
value and the increase in difficulty of selling real
estate before and during the relatively long
construction period.
effective measures must be established to
minimize noise, dust/ odors, and mitigate other
construction-related nuisances.
a mechanism must exist for public input in the
mitigation/compensation plans and an opportunity to
change those plans in response to changes in
construction operations must exist.
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III. Summary
The Citizen's Advisory Committee is greatly concerned with
the environmental quality of Boston Harbor, the islands in the
harbor, and the surrounding communities. The CAC has a strong
desire to see an integrated, prioritized plan developed for
improving the sewage system and the harbor. There is also a
desire to see this plan, and the building of a wastwater
treatment facilities as part of this plan, carried out in a
manner that minimizes adverse effects on communities most
impacted and the region as a whole. There is a need for building
quality facilities and ensuring mitigation and compensation, even
if the economic cost to the region is greater than for building
marginal facilities in a less responsible manner. The CAC
sincerely hopes that the concerns and recommendations put forth
in this document are considered by the decision makers, and will
offer additional advice when a final siting option is chosen.
The members of the CAC wish to thank the
Gillette Company for their kind hospitality
and the use of their conference rooms as
meeting places for the Citizen's Advisory
Committee.
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The Citizen Advisory Committee
Supplementary Draft Environmental Impact Statement
Boston Harbor Wastewater Facilities Siting
Co-Chairpersons:
Ms. Lorraine M. Downey
Boston Conservation Commission
Boston Harbor Associates
Boston Harbor Citizens'
Advisory Committee
Members:
Ms. Eugenie Beal
Mr. George Marsh
Friends of Boston
Harbor Islands
Mr. Richard C. Boutiette
Department of Public Works
Wakefield, Massachusetts
Mr. Robert M. Calder
Boston Shipping Association
Mr. Waldo Holcombe
Boston Harbor CAC
Neponset Conservation
Association
Ms. Frances H. Lavallee
Boston Harbor Water Quality
Committee
Mr. Andrew Locke
Mr. Terry N. Fancher
Community Development Manager
South Shore Chamber of
Commerce, Inc.
Mr. Phillip Goodwin
Mass. Bay Yacht
Club Association
Ms. Blossom Hoag
Sierra Club -
Greater Boston Group
Mr. Tom Morell
Massachusetts Lobstermans'
Association
Ms. Lois Murphy
Nut Island CAC
Mr. Robert Noonan, Chairman
Winthrop Board of Selectmen
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Ms. Anne Porter
Point Shirley Association
Deer Island CAC
Mr. Frank Powers
Quincy Bay Flounder Fleet
Ms. Peggy Riley
Deer Island CAC
Mr. T. Rollins Ross
Boston Facilities Plan
Public Advisory Group
Ms. Andrea Sault
Nut Island CAC
Mr. Anthony Termine
The Gillette Company
Mrs. Emilie DiMento
Winthrop Concerned
Citizens Committee
Mr. Verne Porter
City of
Newton, Massachusetts
Mr. Joseph B. Walsh, Senator
Special Commission on the
Development of Boston Harbor
Mr. Jack Walsh, Chairman
Nut Island CAC
Ms. Nancy Wrenn
Boston Harbor CAC
Ms. Ethel Shepard
Metropolitan Area Planning
Council
Mr. Eric Thomson
Utility Contractors of
New England
Boston Harbor CAC
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Boston Harbor Wastewater Treatment Facility Siting
Environmental Impact Statement
Citizens Advisory Committee
AMENDED RECOMMENDATIONS
November, 1985
The following is a set of recommendations for the
consideration of the Environmental Protection Agency, Region I
(EPA), and the Massachusetts Water Resources Authority (MWRA).
These recommendations were developed by a Task Force of the
Citizens Advisory Committee (CAC) and have been reviewed and
approved by the entire committee. The CAC was formed from a
cross section of concerned interests to advise EPA and MWRA in
the preparation of environmental assesments for the siting of
wastewater treatment facilities in Boston Harbor and has worked
closely with the agencies and consultants involved in this
project for the last two years, meeting regularly throughout that
period.
The CAC produced a set of recommendations which were included
in the SDEIS/EIR and still supports those recommendations. These
additional recommendations were developed to address new
information and issues which have become known since the
SDEIS/EIR was published, and to restate in a brief form the CAC's
major concerns.
It is the hope and intent of the CAC that these
recommendations will be used to assist decision makers in
determining the siting and mitigation measures for wastewater
facilities in Boston Harbor and in other projects relating to
cleaning up the harbor.
Members of the CAC representing the community of Winthrop
wish to emphasize that these recommendations are not
site-specific, and that the community of Winthrop is opposed to
any expansion of the current facilities at Deer Island.
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PROPOSED NON-SITE-SPECIFIC RECOMMENDATIONS FOR IMPACTED
COMMUNITIES HOSTING PLANNED WASTEWATER TREATMENT FACILITIES:
1. That the wastewater treatment facility be the only operating
facility on the island chosen. No sludge disposal facility
should be built on the chosen island, and the prison should be
removed from Deer Island and the hospital from Long Island if
either of those sites is selected.
2. That the transportation of chlorine or other hazardous
materials through the communities surrounding the selected site
be prohibited. The CAC encourages a full evaluation of
alternative disinfection methods to avoid the safety and
environmental problems associated with chlorine. No excessive
stockpiling of hazardous materials should occur at the treatment
plant site.
3. That all materials and personnel associated with the
construction and operation of treatment facilities be barged or
ferried to the site, with the only exception being emergency
response vehicles.
4. That any community impacted by the treatment facilities be
consulted regarding mitigation efforts. Citizens of the impacted
communities must be allowed to take an active part in determining
mitigation and compensation plans and plans must be in place
before construction begins. Mechanisms must exist to modify
plans if projected conditions change. A representative body
should be formed to ensure that the interests of impacted
residents are continually addressed and a method of appeal should
be established to provide unsatisfied residents with a means for
appeal. The CAC wishes to emphasize that sewage treatment is the
responsibility of all communities in the MWRA district and that
just compensation be made to those communities bearing the burden
of treatment facilities.
5. That all efforts toward the reduction of visual, noise and
odor impacts be provided during initial construction and that any
landscape-type mitigation measures (berms, mounds, plantings,
etc.) be aesthetically pleasing.
6. That all residuals be disposed of at sites remote from the
Harbor Islands.
7. That a full operation and maintenence and preventive
maintenance program be developed and funded to eliminate the
historic problems of failing facilities.
8. That financial assistance be provided to the governments of
impacted communities to support monitoring and consulting
services required by the communities to monitor the construction
and operation of treatment facilities.
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9. That financial reimbursement be made for expenditures by
community fire and police departments incurred in responding to
treatment facility emergencies. It is strongly recommended that
the facility have its own capabilities for dealing with medical,
fire, hazardous material, and security emergencies.
10. That a park be developed at the chosen site to utilize any
recreational potential remaining after the construction of a
well-designed plant, although the design of the plant and its
effectiveness should not be constrained by recreational plans.
11. That financial compensation be provided to the communities
bearing the burden of the treatment facility impacts in the forms
of eliminating sewer charges or in payments to the community.
12. That the "no action" alternative mentioned in the SDEIS/EIR
is totally unacceptable.
13. That satellite treatment plants be encouraged to handle
growth of the MWRA system and that no expansion beyond the
initial design capacity be allowed for the harbor treatment
facility. The current NPDES discharge limit should be used as a
maximum limit for effluent flow to the harbor from the proposed
treatment plant.
14. That an advisory committee be formed in the impacted
communities to advise EPA and MWRA on the facility planning,
construction, and operation of the plant and that this group be
provided with all documents produced regarding the project.
15. That the site(s) not chosen be left in public domain. Sites
should be utilized as originally intended when preserved from
development as treatment plant sites.
16. That long term, integrated pollution abatement planning take
place to reduce reliance on a single treatment plant and that all
of the agencies responsible for controlling harbor pollution
establish a schedule for such measures as CSO facility
construction, industrial effluent pretreatment, elimination of
polluted storm sewers and combined storm drains and sewers.
17. That the industrial pretreatment program be strengthened and
vigorous enforcement of the program begin immediately.
18. That the MWRA address and control the addition of septage to
the system and provide means for receiving and treating septage
and licensing and charging septage haulers. Septage should not
be hauled through impacted communities.
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CAC TASK FORCE MEMBERS:
Karl Christ - Gillette Company
Emilie DiMento - Winthrop Concerned Citizens Committee
Richard Dimento - Winthrop Concerned Citizens Committee
Waldo Holcombe - Boston Harbor CAC
T. Rollins Ross - Boston Harbor EIS CAC
Anthony M. Termine - Gillette Company
Jack Walsh - Nut Island CAC
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in-5
summary of public comment on sdeis
and agency responses
-------
SECTION 3
SUMMARY OF PUBLIC COMMENT ON SDEIS AND AGENCY RESPONSES
INTRODUCTION
The Environmental Protection Agency released the Supplemental
Draft Environmental Impact Statement (SDEIS) on the "Siting of
Wastewater Treatment Facilities for Boston Harbor" in January
1985. In early February, a series of three public information
meetings was held to highlight the data contained in the SDEIS
and to answer questions posed by the public. A summary of issues
raised at these public information meetings is available from EPA
upon request.
In late February and early March, three public hearings were
held to obtain formal written and verbal comment on the SDEIS
document. A legal notice concerning the hearings was placed in
the Boston Globe. A Boston Harbor Update newsletter containing
details of the hearings was sent to the mailing list of 1600
interested agencies, organizations and residents. A list of
media outlets received a press release with hearing details. Ads
encouraging attendance were taken out in the Winthrop
Sun-Transcript and the Quincy Patriot Ledger by local groups.
The hearings were well attended. EPA and Commonwealth
officials heard more than 15 hours of testimony, received
numerous petitions, surveys and written letters as well as
physical evidence of pollution problems caused by faulty
wastewater treatment facilities.
Written comments were accepted until March 18, 1985. During
this period, EPA and the Commonwealth received hundreds of
written comments from officials (federal, state, local);
environmental, neighborhood and business groups; area residents;
approximately 2800 postcards opposing siting of a wastewater
treatment facility at Deer Island; and approximately 1200 form
letters opposing use of Nut Island as a site for wastewater
facilities. [For a list of all comments received, see Volume IV,
Section 1: Log of Written and Oral Comments]
The remainder of this document addresses the written and
verbal comments received. These comments have been summarized
and organized by broad "issue categories" for clarity and greater
ease of reading. [Originals of all comments can be found in
Volume IV, Section 2]. Agency responses follow each category.
EPA believes that sufficient evaluation has been completed for
purposes of selecting the preferred alternative. The Agency
recognizes that further environmental evaluation is needed on
certain topics. This detailed evaluation will be undertaken
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during the completion of "phase two" facilities planning.
The issue categories are as follows:
A - Suitability of Deer Island as a Treatment Site Page 3-2
B - Suitability of Long Island as a Treatement Site Page 3~^
C - Suitability of Nut Island as a Treatment Site Page 3-6
D - Neighborhood Impacts Pa9e 3~7
E - Health and Safety Pa9e 3~°
F - Mitigation and Compensation Page 3-9
G - Omissions and/or Inadequacies of SDEIS Document Page 3-11
H - Level of Treatment Pa9e 3~36
I - Water Quality Issues Page 3-37
J - Equitable Distribution of Regional Facilities Page 3-39
K - Decision Criteria Page 3-40
L - Segmentation Issue (Related Pollution Issues) Page 3-41
M - Growth of the System Page 3-44
N - Satellite (Subregional) Treatment Page 3-45
0 - Massachusetts Water Resources Authority (MWRA) Page 3-46
P - Public Participation Page 3-47
For additional information on the comments received, please
contact:
Kathleen Castagna, Project Monitor
U.S. Environmental Protection Agency
Environmental Evaluation Section
Room 2100B, J.F.K. Building
Boston, MA 02203
(617) 223-0835
COMMENTS AND RESPONSES BY ISSUE CATEGORY
A - Suitability of Deer Island as a Treatment Site
Many comments received from Winthrop residents argued that
Deer Island is an inappropriate site for a wastewater treatment
facility. Traffic congestion, noise and air pollution, and
environmental health were of great concern to Winthrop residents
who stated that construction of a new facility would destroy the
fabric of life in Winthrop. In addition, many comments focused
on the likely property value decline following treatment plant
construction. It was argued that such decline is associated only
with Deer Island siting options.
Several commentors suggested the Town block use of Deer
Island by such methods as banning certain sized vehicles, filing
of an injunction to prohibit a decision on the draft and final
EIS, opening up Shirley Gut or undertaking acts of civil
disobedience. One commentor noted that the East Boston
neighborhood is severely impacted by anything that happens in
Winthrop.
Some commentors suggested that a more objective comparison
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could be made of the suitability of the Deer and Long Island
sites if the FEIS included an analysis of the recreational
potential of a restored Deer Island, independent of proposed
recreation plans. It was suggested that such an analysis include
benefits and impacts of recreational use, such as traffic impacts
compared to those of sewage plant construction and operation. In
addition, several commentors stated that Deer Island's
architectural and historical significance had been undervalued
and urged EPA to undertake a more thorough survey of the drumlin
and pump house.
Others felt that Deer Island is the most suitable site,
calling it the most technically feasible and cost effective of
the options under review. With its large land area, Deer Island
was called the best equipped to handle a new treatment facility.
Deer Island was called one of the two "least bad" sites by one
commentor who said that if the Deer Island House of Correction
were moved, the Deer Island option could be implemented in a way
which would produce net environmental improvements for Winthrop
residents.
Agency Response; Following an extensive environmental
analysis of the suitability of Deer, Nut and Long Island
as sites for an expanded wastewater treatment facility
to service the Metropolitan Sewerage District, EPA has
designated Deer Island as its preferred alternative.
The SDEIS evaluated the full range of environmental
impacts, including social, technical, economic, environ-
mental, political, legal and institutional impacts of
the siting decision. In addition, EPA performed sub-
stantial additional work to clarify many issues which
were raised during the review of the SDEIS. Areas of
reexamination include: traffic, noise, odor, air
quality, health, property values, recreational,
archaeological/historic, and legal and institutional
impacts. As a result of the information developed, the
Deer Island site was found to be environmentally
acceptable (when specific mitigation measures are
applied) and is the Agency's preferred alternative. See
Volume I (Decision Process section) for a detailed
discussion of the reasons for the selection of Deer
Island.
Mitigation measures required of the MWRA as a
condition of receipt of federal funds are:
o Barging of all bulk materials.
o Busing/ferrying of construction workers to and from
the wastewater treatment facilities site.
o Installation of appropriate odor control facilities.
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o Use of all practical noise reduction methods.
Construction of a sound barrier adjacent to the Deer
Island House of Correction and excavation of the drumlin
from the south side are specifically required.
o Erosion, dust and sedimentation control.
o Control of volatile organic compound (VOC) emissions.
o Prohibition of trucking of liquid chlorine through
Winthrop (after completion of required barging pier
facilities).
o Prohibition of the long term use of chlorine unless a
clear and convincing need is shown and acceptable safety
measures are demonstrated.
o Use of Roll-on/Roll-off transport for heavy trucking.
o Exploration of the following in the Facilities Plan:
alternative techniques for disinfection of effluent
(other than the use of liquid chlorine), alternative
treatment processes, and joint recreational use
of the wastewater treatment facilities site.
The MWRA has committed to establising a noise
control program, the purpose of which is to ensure that
adverse impacts are not experienced in the community.
Specific aspects of the program will be developed in the
Facilities Plan but will include an acoustical review
board, use of feasible control technology, staff
training and community involvement. The MWRA has made a
number of other commitments with respect to mitigation
measures which can be found in Volume I of the FEIR.
The MWRA is also in the process of exploring
non-environmental mitigation measures and is currently
preparing information on such measures for review by its
Board of Directors.
B - SUITABILITY OF LONG ISLAND AS A TREATMENT PLANT SITE
The suitability of Long Island as a treatment plant site has
long been a hotly debated subject, and SDEIS commentors focused a
great deal of comment on this topic.
Those in favor of Long Island felt that it was most suitable
as a treatment plant site because it is farthest from any
shoreline community, uninhabited, except for the chronic care
patients of the Long Island Hospital, and accessible from the
mainland. These commentors stressed that the welfare and quality
of life of 20,000 Winthrop residents is more important than a
possible park, prehistoric remains, Civil War graves, wildlife or
wetlands located on Long Island.
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With regard to the proposed Long Island park, many pointed
out that there has been no firm designation of Long Island for
recreation, and the recreation plan should not preclude the use
of Long Island for wastewater facilites. One person stated that
the topography of Long Island (bluffs twenty to seventy feet
above beaches with precipitous drops) precludes its use as a
recreation site. Several commented that the park system is
simply being used as "short hand" for the elimination of Long
Island as a treatment plant site. Winthrop residents stressed
that Deer Island has equal potential as a recreational resource.
Many questioned the viability of the Long Island Hospital,
which they said is outdated, underutilized, and scheduled for
closure. Concerning the City of Boston's objections to the site,
one commentor said that the Commonwealth could force the City to
turn over Long Island for use as a site for wastewater treatment
facilities.
Some commentors said that Long Island's architectural and
historical significance has been overstated and suggested that
secondary wastewater treatment facilities could be constructed to
avoid the most sensitive resources.
Long Island was considered one of two "least bad" sites by
one commentor who wrote that, as long as the hospital is moved,
Long Island's topography and the use of stringent design criteria
could lead to a facility which would be consistent with the use
of the island as a keystone of a harbor park system.
Those opposed to the use of Long Island as a site for
treatment facilities included those concerned with neighborhood
impacts (primarily in Squantum), preservation of the island's
archaeological and historical sites, and its potential as a
regional recreation resource and hospital/shelter site.
Those commenting on neighborhood concerns stated that access
to Long Island requires vehicular passage over three miles of
narrow, inadequate roads which are presently unable to
accommodate local traffic. Because of its topography, it was
alleged that a treatment facility on Long Island would result in
a severe visual impact on the Squantum neighborhood.
Use of the island would have an impact on its significant
archaeological and historic resources. One person stated that
the island's resources are unique as they contain the site of the
only Early Archaic prehistoric evidence within the City of
Boston. Others noted the important barrier beach and wetlands.
A large number of commentors focused specifically on the
proposed park and its compatibility with a treatment plant. The
Commonwealth's Department of Environmental Management stated that
Long Island could help meet the huge unfulfilled demand for
public access to the coast for swimming and recreation and that
locating a sewage treatment facility on Long Island would prevent
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its development into a major park. The BRA commented that the
area offers an unparalleled recreation opportunity to the City
and the region. In their view, Long Island's location and
accessibility make it a particularly appropriate site for linkage
to -other islands. Finally, Mayor Flynn commented that Boston is
committed to integrating Long Island with other recreational uses
of Boston Harbor.
Several people said that a treatment plant is an
inappropriate neighbor for the chronic care hospital or the
shelter for the homeless, which serve vital functions to the
City's residents. Boston's Mayor Flynn emphasized that the City
intends to maintain the medical and emergency shelter uses of
Long Island.
Agency Response; The SDEIS did a complete analysis of
the feasibility of Long Island as a site for both
primary and secondary treatment. In addition, EPA
performed additional work to clarify issues raised
during the review of the SDEIS. As a result of the
analysis contained in the SDEIS and further studies,
Long Island was judged to be suitable and environ*-
mentally acceptable as a wastewater treatment plant
site provided the Long Island Chronic Disease Hospital
is relocated. Archaeological investigations and mitiga-
tion strategies to comply with the National Historic
Preservation Act would also be required, as would the
mitigation measures described in the previous section.
However, in part because of legal constraints on the use
of the Island, it is not the preferred agency
alternative.
C - Suitability of Nut Island as a Treatment Site
A large number of people commented that Nut Island was
totally inappropriate as a treatment plant site. They said that
the original decision to site a treatment plant on Nut Island had
been a mistake, and called the area far too small to be con-
sidered as a site for improved facilities. Residents of Hough's
Neck and Quincy Great Hill emphasized the danger of using the
narrow, hilly streets for heavy construction traffic, and
complained about noise and odor problems associated with
construction and operation of a treatment facility in such close
proximity to a residential neighborhood.
A central issue of concern to residents of the area was the
possibility that homes might have to be taken to accommodate a
buffer zone adjacent to the new facility. Many people said that
the removal of homes was unacceptable. Equally as unacceptable
to many was the notion of filling three acres of Quincy Bay to
achieve a buffer zone.
By contrast, one person called for further evaluation of the
issue of fill, saying that permits for filling could be obtained
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if it could be shown that there would be no impact on natural
resources.
Agency Response; As detailed in Volume I, the SDEIS
determined that the Nut Island site is closely limited
by both adjoining houses and the sea. Its use as a
wastewater treatment facility site would generate severe
environmental effects, particularly noise, odor, and
water quality impacts due to filling of the Harbor to
create even a minimal buffer. It was further determined
that it would be useless to incur such impacts, given
the marginal (zero to ten acre) increase in land
required to consolidate facilities at Deer Island.
Subsequent noise and odor reviews undertaken since
the publication of the SDEIS indicate that the impacts
would be even more severe than those described in the
SDEIS. Therefore, EPA judged that the limited area
available and close proximity of residences to the site
make expansion of wastewater treatment facilities at the
Nut Island site environmentally unacceptable.
D - Neighborhood Impacts (Note: Comments specific to Deer
Island are listed under category A, Long Island - category B, Nut
Island - category C)
The severe impacts of wastewater treatment facilities on
neighborhood residents were of utmost concern to the hundreds of
citizens who took the time to attend public infomation meetings
and hearings, write letters, organize petitions and prepare
surveys and comments. In their view, the possibility of
devastating impacts on the day-to-day lives of neighborhood
residents must outweigh all other factors in selecting a site for
treatment facilities.
Many commented that the SDEIS sets communities and
neighborhoods against each other. They found all three sites to
be inappropriate because of their close proximity to residential
areas, each with site access limited to narrow residential
streets. It was suggested that the creation of a new harbor
island would have been preferable in this regard. A number
proposed that the current SDEIS be scrapped and a new site
selection process be developed to identify non-residential sites.
Construction-related neighborhood impacts were most
frequently mentioned by residents near all three sites.
Commentors considered traffic congestion and safety to be the
worst impact. Residents complained that each site has only
one-road access and none was built to accommodate the heavy truck
trafffic which would result from construction nor cars or buses
which would transport workers. Such traffic would increase noise
levels and seriously impede traffic flow. Construction noise was
also of great concern to residents. With regard to potential
impacts during plant operations, odor and truck traffic were
frequently cited.
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Agency Response: EPA recognizes that construction of
required wastewater treatment facilities will entail
neighborhood impacts during the expected construction
period. However, the Agency believes that the EIS
process produced a comprehensive and fair analysis of
the available options and that the alternative selected
is environmentally acceptable, when specific mitigation
measures are applied.
Additional work done as a result of comments made
following the publication of the SDEIS focused on three
of the impacts perceived as most annoying by neighbor-
hood residents, traffic/transportation, noise and odor.
With regard to construction traffic, EPA found that
none of the options are acceptable without barging of
all bulk materials and busing/ferrying of construction
workers. Regarding noise, EPA determined that
construction noise will be within the limits allowed by
the Boston Noise Control Regulations. To ensure
compliance with these regulations the Agency has
required the construction of a noise barrier adjacent to
the prison and excavation of the drumlin from the south
side. Regarding odor, additional work suggests that the
MWRA must design and construct appropriate facilities
and/or equipment to reduce odors. (See Volume I,
Decision Process section for a complete description of
required mitigation measures.)
E - Health and Safety
The majority of comments on this topic focused on what was
called the SDEIS1s inadequate portrayal of the dangers of
transporting chlorine through Winthrop's narrow residential
streets. Several people felt that the document did not carefully
consider the possible effects of a chlorine gas spill and the
impossibility of safe evacuation in such an event. Others stated
that EPA should insist upon such alternatives as on-site
manufacture of sodium hypochlorite from sea water or use of
ultra-violet lights for disinfection. This would eliminate the
harmful effects of discharging chlorinated water into the harbor
and eliminate the need to truck chlorine.
Senior citizens of Winthrop noted that they are dependent
upon moving around the Town safely by foot. They expressed
concern that large increases in traffic might increase safety
hazards and seriously impair their mobility.
Several people were concerned about health dangers posed by
proximity to the treatment plant, swimming in polluted water, and
possible consumption of tainted fish. A doctor commented that
his patients have suffered from increased incidence of gastro-
intestinal disease from swimming in the polluted Quincy Bay. He
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was concerned that increased contamination of the Bay with
bacteria and viruses might place his patients at higher risk of
contracting disease.
Agency Response; EPA recognizes the potential safety
problems posed by trucking of liquid chlorine through
narrow residential streets and has prohibited the
trucking of liquid chlorine after barge pier facilities
have been completed. In addition, EPA has placed a
conditional prohibition on the long term use of liquid
chlorine and required that the MWRA consider in its
Facilities Plan alternative techniques for disinfection
of effluent. This investigation will also include an
evaluation of chlorine toxicity to marine life. EOEA
has also directed MWRA to explore feasible alternatives
to trucking of liquid chlorine. MWRA is now assembling
information on alternative methods of disinfection which
might be initiated as an interim practice.
Regarding traffic safety, the mitigation measures
described earlier (see Section A) are expected to reduce
the likelihood of traffic dangers to residents.
EPA believes that the quality of the secondary
effluent from the improved wastewater treatment facility
will result in water quality improvements. The effluent
will meet applicable state water quality standards for
bacterial levels designed to protect the public from
bacterial contamination. EPA believes that a properly
operated secondary treatment plant (with disinfection)
will provide a meaningful step to improved toxics and
bacterial loadings to the Harbor. Additional measures
such as elimination of sludge disposal to the Harbor and
CSO control are also necessary to restore the Harbor to
its fullest potential.
F - Mitigation and Compensation
Several comments focused on the desirability of extensive
mitigation measures. One commentor noted that the burden must be
mitigated "virtually without regard to cost". However, many were
concerned about the lack of guarantees that these measures would
be implemented. One commentor questioned EPA's authority to
require implementation of mitigation measures, especially those
not made specific grant conditions or those not directly related
to water quality and thus not federally fundable. This lack of
authority made assurances concerning mitigation "hollow", and the
SDEIS was called seriously flawed because of its reliance on such
uncertain mitigation measures. It was suggested that the FEIS
clarify EPA's authority to require implementation of mitigation
measures.
Many individual measures were proposed by commentors,
uding noise/odor control, barging, busing, safety
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precautions, traffic patterns which minimize use of residential
streets, alternatives to chlorine trucking, opening of Shirley
Gut, relocation of the Deer Island House of Correction, and
relocation of the Long Island Hospital. Specific visual quality
measures were suggested, including prompt removal/reuse of all
disposal materials and equipment, construction of a detailed
architectural scale model including proposed landscaping and
visual screening. Several suggested that an entity be created to
oversee facilities design. One person suggested that surcharges
on large new system hookups be used to fund rate reduction for
affected communities.
Several commentors urged that the feasibility, implement-
ability and cost of all suggested measures be examined in further
detail on a site-by-site basis and included in the capital cost
estimate for each option. Another commented that the compen-
sation issue should be developed further before a site option is
selected, since it might have a significant bearing on the siting
decision. Particular attention was paid to the need for further
analysis of the shoreside impacts of barging of construction
supplies and busing of workers, two of the measures proposed by
EPA as integral to any siting solution. Barging comments focused
on the need to evaluate potential barge terminal sites.
By contrast, many residents of Winthrop asserted that no
measures could sufficiently mitigate the destructive impacts of
wastewater facilities construction. For example, the Town would
not benefit from traffic control or truck route mitigation
because it is already experiencing capacity problems.
Agency Response: EPA believes that its preferred
alternative is environmentally acceptable when certain
specific mitigation measures are undertaken. The Agency
has made receipt of federal funds conditional upon
adherence to this mitigation program. The program is
outlined in detail in Volume I, Decision Process
section, and includes:
o Barging of all bulk materials.
o Busing/ferrying of construction workers to and from
the wastewater treatment facilities site.
o Installation of appropriate odor control facilities.
o Use of all practical noise reduction methods.
Construction of a sound barrier adjacent to the Deer
Island House of Correction and excavation of the drumlin
from the south side are specifically required.
o Erosion, dust and sedimentation control.
o Control of volatile organic compound (VOC) emissions.
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o Prohibition of trucking of liquid chlorine through
Winthrop (after completion of required barge pier
facilities).
o Prohibition of the long term use of chlorine unless
a clear and convincing need is shown and acceptable
safety measures are demonstrated.
o Use of Roll-on/Roll-off transport for heavy trucking.
o Exploration of the following in the Facilities Plan:
alternative techniques for disinfection of effluent
(other than the use of liquid chlorine), alternative
treatment processes, and joint recreational use
of the wastewater treatment facilities site.
The MWRA has committed to establising a noise
control program, the purpose of which is to ensure that
adverse impacts are not experienced in the community.
Specific aspects of the program will be developed in the
Facilities Plan but will include an acoustical review
board, use of feasible control technology, staff
training and community involvement. The MWRA has made a
number of other commitments with respect to mitigation
measures, which can be found in Volume I of the FEIR.
The MWRA is also in the process of exploring non-
environmental mitigation measures and is currently
preparing information on such measures for review by its
Board of Directors.
G - Omissions and/or Inadequacies of SDEIS document
A large number of people focused on the data contained in the
SDEIS document. Information was described as missing, insuffi-
cient or biased. Many requested that additional or revised data
be developed as part of the FEIS process. Omissions/inadequacies
have been divided into major impact categories. EPA responses
follow each bulleted point.
Traffic and Transportation;
- Traffic impacts
o The SDEIS description of baseline traffic conditions both in
Winthrop and Quincy was called inaccurate and incomplete. In
particular, information was requested on bridge capacity or
condition constraints that may affect truck routes; number of
homes along Deer Island truck route in Winthrop and East
Boston; and traffic impacts of Long Island bridge
construction.
Because of concern expressed during review of
the SDEIS, EPA reexamined existing traffic data and
conditions of the roadways to the alternative
sites. It was found that:
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- existing conditions on access roads to Deer
Island have more traffic problems than previously
reported.
- Long Island and Deer Island were determined
to have similar access limitations with regard to
connections to the major highway network. However,
if permission could be obtained to use Morrissey
Boulevard for trucks, Long Island's access would be
considered better.
In general, reexamination confirmed the SDEIS
contention that the majority of truck/automobile
traffic should be diverted to other transportation
modes, primarily barging/busing/ferrying. The
review indicated that a greater percentage of total
traffic could obtain access to the construction
site by water than had previously been estimated.
Complete information on the traffic
reexamination undertaken as part of the FEIS,
including data on population affected, road and
bridge capacity constraints and possible mitigation
measures, can be found in Volume I, and in Volume
II, Section II-l.
o There is a need to identify major intersections and points of
constriction along each proposed truck route and determine
volume-to-capacity relationships at these and the level of
service provided.
These items were covered in the reexamination
referred to above. See Volume II, Section II-l for
more information.
o Traffic patterns from the proposed plant sites to a major
highway should be developed.
See Volume II, Section II-l.
o Many comments focused on the omissions and lack of
reliability of the projected truck and bus estimates found in
the SDEIS.
Reexamination of traffic projections indicated
that the overall numbers of workers and truckloads
of materials and equipment estimated in the SDEIS
is reasonable.
o Information was requested on traffic impact of trucking
tunnel spoils; transportation implications of sludge
management; impact of trucking fuel to the plant during
operations; and impact of diesel fumes from buses.
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EPA believes that there is sufficient
information on these issues to make a siting
decision Further detailed study on spoils
disposal resulting from construction of
inter-island sewage pipes (either tunnels or
pipeline) will be undertaken as part of MWRA's
Facilities Plan, and will undergo subsequent
environmental review. Sludge management
transportation issues will be reviewed as part of
the MWRA's Residual Solids Management Study and
will also undergo further environmental review.
Fuel trucking impacts were considered in the SDEIS
and are considered slight. Impact of diesel fume
from buses is also considered slight.
o More information is available on Deer Island roads than those
of Long or Nut Islands.
EPA considers information now available on
Deer, Long and Nut Island roads to be sufficient to
complete the EIS analysis.
o The FEIS should carefully document and analyze maximum daily
materials and worker traffic to determine a "worst case" for
truck or auto use.
The SDEIS contains a "worst case" analysis of
truck/auto use in Section 12.2.2-3. Without
barging and busing/ferrying, peak traffic could
easily exceed 1000 autos and 500 heavy trucks per
day.
o The SDEIS failed to consider the extreme danger involved in
transporting and transferring chlorine by truck using narrow
roads through the center of a small community like Winthrop.
A similar problem was cited with respect to transportation of
sulphur dioxide if dechlorination is deemed necessary.
Both EPA and EOEA recognize the potential
safety problems posed by trucking of liquid
chlorine throught narrow residential streets. As
shown in the FEIS, Volume II, Section 11-11, EPA
has considered the dangers associated with overland
chlorine transportation and has prohibited trucking
of liquid chlorine after the barge pier facilities
have been constructed. MWRA has explored some
feasible alternatives to the trucking of liquid
chlorine in the FEIR, Volume I, in response to
EOEA's Certificate of Adequacy on the DEIR.
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- Barging/ferrying
o Feasibility and costs associated with barging/ferrying should
be resolved as part of the FEIS. Information would be
developed on potential barge and pier sites; criteria to be
used regarding materials to be barged versus trucked; impact
of weather conditions on barging; need for dredging to
construct piers.
EPA instructed its consultants to develop a
more detailed barging/ferrying feasibility study.
This study, summarized in Volume I, and reported in
detail in Volume II, Section II-l, reveals that
barging construction equipment and materials is
practicable and ferrying appears to be reasonable
for a significant fraction of the construction work
force.
Construction impacts;
o The FEIS should state which method will be used to construct
the outfall, conveyance pipeline, and piers. It should then
assess environmental impacts (especially on wetlands,
fish/wildlife) and include information on amounts/
composition of dredged materials; approximate shaft location
and spoil removal routes (if tunneling is to be used); and
potential disposal strategies and sites.
EPA believes these issues are not site
determinative. The MWRA will make this decision as
part of its Facilities Plan and will conduct an
environmental review of proposed facilities.
o Impacts on navigation of construction of wastewater treatment
components must be evaluated.
Since the publication of the SDEIS, EPA and
the Corps of Engineers have determined that further
evaluation on the impacts to navigation will be
necessary during the development of the detailed
Facilities Plan. Preliminary findings show that
impacts to navigation are not likely to pose
significant problems.
Noise;
- Existing/baseline conditions
o Comments suggested that baseline noise conditions were not
adequately analyzed. Several said that additional ambient
noise studies (both daytime and nighttime) should be
performed in Winthrop so that a reliable ambient data base
can be developed. Such noise monitoring should utilize
standard statistical sampling techniques. EPA should
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consider expanding noise monitoring to present information
for each site on current, consistent ambient noise level
determinations at the property line and at the nearest
receptor point.
Data on ambient noise levels near the three
candidate sites were reexamined. SDEIS data was
determined to be an adequate measure of real world
conditions. However, it was determined that
further morning readings at Point Shirley were
necessary and a series of such measurements were
made in the Point Shirley area. Complete
information on results of additional ambient noise
studies can be found in Volume II, Section II-3.
o Commentors noted that noise data collected from Massport and
not incorporated into the SDEIS indicates the severe impact
of overflights on the Point Shirley and Cottage Hill areas
which is exacerbated by the noise from the diesel engines at
the Deer Island treatment plant. This data should be used or
an explanation of its omission provided.
The SDEIS (Figure 12.6-4) does include a
summary of 1982 Massport data. The data indicates
average noise levels of less than 65 to more than
80 dBA in parts of Winthrop and East Boston.
Problems with Massport1s remote noise sensing
equipment precluded use of updated monitoring data
in the SDEIS.
EPA believes the use of airport noise in
establishing ambient conditions would artificially
elevate background noise levels. Therefore
background levels without overflight impacts were
measured and used to project contruction noise
impacts.
o Use of the Boston Noise Control regulations should be
clarified with regard to the proper noise limit
classification of the Point Shirley neighborhood.
Since the project is located in the City of
Boston, Boston Noise Control Regulations will be
used as the standard by which construction noise
limits will be measured.
- Noise impact analysis
o Commentors noted that operations noise measurements taken and
pronounced acceptable are not necessarily indicative of noise
levels which could be expected at a secondary plant.
The plant will be designed and operated to
meet operational noise standards as defined in the
Boston Noise Control Regulations.
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o Projections of construction noise levels should take into
consideration that multiple units of equipment will be used.
A reevaluation was made of the number of
pieces of heavy equipment likely to be used and of
the noise that such equipment would
generate. The new estimate, based upon a ratio of
construction equipment to construction workers of
1:7-8, yields about 80 pieces of equipment. The
reevaluation estimates that the resultant con-
struction noise level will be higher than described
in the SDEIS. However, noise impacts at all
locations are considered acceptable. A full
discussion of these findings appears in Volume II,
Section II-3.
o The SDEIS should review geotechnical data to determine
whether alternatives to noisy pile driving could be
considered.
This will be done as part of the MWRA's
Facilities Plan.
o Impact of diesel engines, either as primary or back-up source
of power should be included.
Impacts of diesel engines have been evaluated
and are included in the FEIR, Volume I (Noise
Analysis).
o EPA should consider measuring construction noise impacts
present at other similar projects.
EPA has reviewed the noise impact data with
acoustical consultants, who have performed noise
analyses on such major projects as the MBTA's Red
Line construction. Based on these discussions, EPA
believes that the assumed sound energy levels
projected for the construction phase of this
project are reasonable.
- Noise mitigation measures
o Commentors suggested that a noise performance standard,
monitoring and enforcement program should be developed as
part of the FEIS. Specific noise control measures, during
construction and operation, should be identified and costs
associated with such measures should be developed.
Information was requested on whether the mitigation measures
proposed in the SDEIS ensure that noise levels will not
exceed the maximum allowable increase above ambient levels.
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EPA recognizes the significant construction
noise problems posed by construction of a
wastewater treatment facility. The noise analysis
contained in Volume II, Section II-3 concluded that
noise levels will not exceed the Boston Noise
Control Regulations at Point Shirley. To ensure
compliance at the prison, EPA will require the
following noise mitigation measures: construction
of a sound barrier adjacent to the prison and
excavation of the drumlin from the south.
MWRA has committed to establishing a noise
control program, the purpose of which is to ensure
that adverse impacts are not experienced in the
community. Specific aspects of the program will be
developed in the Facilities Plan, but will include
an acoustical review board, use of feasible control
technology, staff training and community
involvement. For more information on potential
noise mitigation measures, see the FEIR, Volumes I
and II.
o Information was requested on features and costs of special
mitigation measures associated with Long Island Hospital.
The SDEIS evaluated the possibility of siting
the wastewater treatment facility adjacent to the
Hospital. This was judged unacceptable due to site
limitations and environmental constraints.
Therefore it was determined that any secondary
option involving Long Island would require moving
the Long Island Hospital.
Odor;
- Existing/baseline conditions
o Commentors said that current severe odor problems at Deer and
Nut Island are not seriously acknowledged in the SDEIS.
Several said that EPA should include the Winthrop Concerned
Citizens' Committee odor survey as part of the baseline
environment.
o Special causes of odors at Deer Island should be acknowledged
and investigated, according to several commentors.
As a result of concerns expressed following
publication of the SDEIS, EPA has conducted
additional analyses of potential odor impacts. The
results of this modeling effort suggest that odor
can be minimized with appropriate treatment
plant design and conveyance system controls. Full
documentation of odor modeling methodology and
results appears in Volume II, Section II-2.
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o Commentors said that odor problems associated with septage
disposal to the South System should be addressed as well as
what additional problems this might cause in transporting
wastewater to Deer Island.
As part of the additional odor analysis done
following the SDEIS, EPA's consultants found that
additional study is required to determine the exact
impact of septage on the South System. However, it
should be noted that the recommended odor control
program will include pre-chlorination of South
System waste prior to transport to Deer Island.
- Projected odor conditions
o EPA should provide more specific odor information,
particularly details on odor-generating components of
wastewater treatment plants, measurement and evaluation of
odor impacts (including effect of odors on health), odor
dispersion characteristics and methods of analyses, and
impact of odors in a coastal environment.
This was done as part of the odor analysis
described above. Hydrogen sulphide was determined
to be the most perceptable odor and was used as the
basis of further modeling work. Information was
collected on the annual average odor concentrations
at various receptor points, the number of hours per
year that odor emissions are above the threshold of
perception, and the amount the odor is above the
threshold of perception. The model predicted that,
without an odor control program, there is a
potential for substantial odor problems. A full
description of the odor modeling work appears in
Volume II, Section II-2.
o Information should be provided on odor problems associated
with other large wastewater treatment facilities around the
country.
As part of the further work done for the FEIS,
EPA's consultants contacted operators of other
wastewater treatment facilities with similar system
characteristics to discuss the effectiveness of
their odor control programs. In addition, the
consultants reviewed EPA's recent publication
entitled, "Odor and Corrosion Control in Sanitary
Sewerage Systems and Treatment Plants". Volume II,
Section II-2 includes some comparative information.
- Odor mitigation measures
o Information should be provided on specific odor control
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measures to be required for each alternative, on the costs
and reliability of such control measures, and on whether such
measures will be taken both at treatment plants and
headworks.
As part of the additional odor work referred
to above, EPA's consultants surveyed possible
causes of odors in incoming sewage and compared
available odor control technologies. Recommended
odor control methods appear in Volume II, Section
II-2. The MWRA outlined possible odor control
measures in the FEIR, Volume I, and will develop an
odor control program as part of its Facilities
Plan.
o The FEIS should state whether an odor performance standard
will be established, who would be responsible for enforcing
such a standard, and whether other large sewerage agencies
have adopted an ambient air odor standard.
EPA will not be imposing an odor standard. It
will, however, make receipt of grant funds
contingent upon installation of appropriate odor
control facilities.
o EPA should comment on the reasonableness of Winthrop's
suggested use of an "odor panel" to measure odors.
EPA considers such a panel not an unreasonable
method of obtaining community input. The MWRA, in
its FEIR, recommends such a panel.
- Other odor issues
o Information was requested on odor issues associated with
sludge processing facilities at each site.
Odors associated with sludge thickeners were
evaluated in Volume II, Section II-2. Odor issues
associated with other sludge management processes
will be handled as part of the MWRA's Residual
Solids Management Plan.
Recreation and visual quality;
- Recreation impacts
o The FEIS should provide an analysis of the recreation
potential of a restored Deer Island. Such an analysis should
assess both benefits and impacts of recreational use of the
area.
EPA developed a comparative recreational
analysis of Deer and Long Islands as part of the
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FEIS. The analysis, shown in Volume II, Section
II-4, concludes that each island has significant
potential value as a recreational resource,
although each would play different roles for local
residents, the surrounding regional populations,
and out-of-state visitors.
- Visual quality
o The FEIS should provide a more detailed visual quality
analysis of Deer Island, including information on extent of
rip-rapping; stockpiling of grit and scum; possibilities of
maintaining or moving the drumlin; impact of tank-stacking.
A general visual quality analysis of Deer
Island was done in conjunction with the rec-
reational analysis described in the previous
response. Information on rip-rapping and
tank-stacking will be developed as part of MWRA's
Facilities Plan. The drumlin will be removed
during construction. It is possible that a visual
buffer might be constructed between the treatment
plant and the Point Shirley neighborhood. Stock-
piling of grit and scum will be evaluated as part
of MWRA's Residual Solids Management Plan.
Air Quality;
- Baseline/existing conditions
o Commentors noted that the SDEIS inadequately considers air
pollution due to plant-induced traffic.
Given EPA's reliance on barging/busing/ferrying,
the increment of additional traffic is expected to be
small.
o The FEIS should contain a separate description of air quality
baseline conditions at each site, including an analysis of
any available Massport air quality data.
A general description is sufficient for the
EIS since the air quality baseline is well
documented in such other studies as the SDEIS/EIR
on Third Harbor Tunnel, Interstate 90/Central
Artery, Interstate 93, prepared by the Federal
Highway Administration and the Massachusetts
Department of Public Works in June 1983 and the F-
EIS/EIR on the Proposed Development of Bird Island
Flats, prepared by Massachusetts Port Authority and
the U.S. Department of Transportation, Federal
Aviation Authority in 1984. These reports are
available for review at EPA or from the responsible
agency.
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Traffic related air quality concerns were not
considered an important feature of the wastewater
treatment facility because all options rely on
barging of the majority of materials and supplies.
The Residual Solids Management Plan will include a
detailed description and analysis of air quality as
it relates to sludge management options.
o Air quality monitoring programs should be undertaken at each
site, including collection of data measuring compounds
entering the Deer or Nut Island plants and volatile organic
compounds (VOC's) at Deer Island.
Following publication of the SDEIS, EPA
conducted additional studies of VOC's and air
toxics and modeled the results to predict annual
concentrations at residential reception points.
Results of the modeling work indicate that virtual
safe doses are not exceeded at any of the receptors
for any pollutant. However, the initial evaluation
showed that the secondary wastewater treatment
plant may be a major source of VOC's to the air and
may have to be controlled to ensure progress
towards the attainment of the ozone standard. In
addition, it is postulated that a significant
amount of VOC's are being emitted in the collection
system and at the headworks. EPA outlined'a
further sampling and monitoring effort to be done
as part of MWRA's facility planning process to
clarify this situation and validate the modeling
results. More detailed information on air quality
studies is found in Volume II, Section II-6.
o Information should be provided on any other studies done on
VOC's at publicly owned treatment plants.
EPA has conducted at least two case studies to
determine if POTWs are sources of VOC's creating
air quality impacts. Studies of the Philadelphia
and Indianapolis POTWs documented that these
specific plants had specific air toxics problems in
need of control. The MWRA needs to undertake
further sampling and analysis to determine if such
a problem exists.
o Air quality impacts of the on-site scum incinerator should be
considered.
This will be evaluated during the MWRA's
Residual Solids Management Study or as additional
facilities planning work.
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- Air quality impact evaluation
o Further work is needed on the air quality impacts of the
proposed treatment plant. In particular, air dispersion
modeling should be performed to evaluate potential impacts of
VOC's, air toxics and ozone. This modeling should take into
consideration the effect of distance from source on
dispersion of air toxics and impact of aerosols containing
pathogenic microorganisms.
See above explanation on EPA's further air
quality monitoring work.
o Further work is needed on potential air quality impacts of
sludge facilities.
As previously noted, sludge disposal options
will be reviewed as part of the MWRA's Facilities
Plan and Residual Solids Management Study.
- Air quality mitigation measures
o Information should be provided on available air toxics
control technologies and costs.
Information on available air emissions control
technologies can be found in Volume II, Section
II-6. Subsequent detailed study on control
technologies will be undertaken as part of the
Facilities Plan.
o The FEIS should contain information on whether an air quality
monitoring and pollution control enforcement program will be
developed and who would be responsible for enforcing such a
program.
EPA has recommended that the MWRA develop a
properly designed sampling and monitoring program
as soon as possible so it can be used in designing
the wastewater treatment plant. Details concerning
such a program can be found in Volume II, Section
I1-6. Enforcement of air pollution control
requirements will be handled in accordance with EPA
and State regulations.
Water Quality:
- Baseline/existing conditions
o The SDEIS lacks a detailed discussion of the actual
significance of the various pollution sources to the Harbor.
An objective comparative analysis of source contributions and
a quantification of impacts and environmental costs is
needed. For example, information is required on whether
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effluent or sludge solids contribute more significantly to
high metals concentrations in Boston Harbor.
The SDEIS/EIR on Siting of Wastewater
Facilities for Boston Harbor did attempt to
quantify pollution sources to the Harbor. The
quantification revealed that the current plants are
a major point source of pollution in Boston Harbor
and are urgently in need of replacement. The
assumption was made that all sources would be
controlled in time and EPA in no way wishes to
diminish the importance of other sources.
The dry weather overflow data contained in the SDEIS is
outdated.
The SDEIS used 1981 data, developed by the
MDC as part of the Inner Harbor CSO Project. This
data is considered the most complete information
available.
The scope of the biological work done for the SDEIS is too
limited. No sampling was done near the proposed outfall and
no baseline studies were conducted outside of the inner
harbor.
EPA relied on biological work done for the
301(h) waiver application to describe overall water
quality baseline conditions and acknowledges that
the biological data base on Boston Harbor is
limited. However it should be noted that
biological studies done for the 301(h) waiver by
the applicant (MDC/MWRA) analyzed several
monitoring stations throughout the Harbor,
including sites near the proposed outfall and in
the outer Harbor.
The FEIS includes a water quality evaluation
of four outfall sites (See Volume II, Section
II-7). MWRA will conduct further analyses as part
of the Facilities Plan to determine the optimal
outfall location for secondary effluent.
Insufficient site-specific detailed comparative information
was presented, particularly concerning terrestrial and marine
ecosystems.
See previous comment.
Ambiguity of toxics measured in MDC effluent was of concern.
In order to project future effluent toxic
levels, EPA examined both 301(h) data and MDC's
report entitled "Trend Analysis of Historical
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Metals Data for the Nut and Deer Island Wastewater
Treatment Facilities". Where inconsistencies
existed, EPA made its best estimate of reasonable
levels in order to assess water quality impacts.
The new NPDES permit, to be issued to the MWRA,
will require monitoring of toxics. This is
expected to provide an up-to-date effluent data
base.
o Further information is needed on dissolved oxygen depletion.
See Volume II, Section II-7.
o According to one commentor, the coliform discussion should
compare chronic dilution required versus average dilution.
The term "chronic" is not applied to the
evaluation of coliform levels.
- Water quality impact analysis
o Several commentors said that a comparison should be made of
the financial and environmental costs and benefits of primary
versus secondary treatment. This comparison should include
an estimate of the effects of secondary effluent on harbor
water quality, projections of "down time" for secondary
treatment facilities, projected changes in water quality if
facilities do not reach the median treatment efficiencies
outlined in the SDEIS.
The tentative decision to require secondary
treatment was made as part of the separate 301(h)
waiver process, a summary of which is included in
the FEIS, Volume II, Section 11-16. It was made
according to a Congressional mandate to base the
decision solely on the biological and chemical
impacts of the proposed discharge.
An estimate of the effects of secondary
effluent discharged to the Presidents Roads
location was provided in the SDEIS. Modifications
and additions to this analysis were made
subsequently and are summarized in Volume II,
Section II-7. As previously mentioned, the MWRA
will be required to do further analysis of possible
secondary discharge locations during the facilities
planning process. MWRA facilities will be required
to meet the discharge limits set forth in the new
NPDES permit, to be issued to the MWRA. These
limits are based on water quality standards as well
as secondary treatment standards.
EPA believes that its modeling effort presents
a reasonable case regarding dilution of secondary
effluent.
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The implied removal rates of toxics by secondary treatment
was questioned.
The implied removal rates were based upon the
best information available as documented in the EPA
publication "Fate of Priority Pollutants in
POTW's".
One commentor stated that the SDEIS considers the protection
and propagation of aquatic life, but fails to consider
carcinogenic chemicals which are hazardous to humans through
the consumption of finfish and shellfish.
This issue will be addressed by the new NPDES
permit, to be issued to the MWRA. For EPA's
tentative approach, see the Fact Sheet on the Draft
NPDES Permit, Volume II, Section II-7.
According to several commentors, water quality impacts of
chlorine used as a disinfectant are inadequately addressed.
in particular, cholorine residuals in chlorinated secondary
effluent have been underestimated and alternative
disinfection techniques have not been assessed.
As a result of concern about residual chlorine
toxicity, the new NPDES permit to be issued to the
MWRA will require toxicity testing. Residual
chlorine levels will be limited to non-toxic
levels. In addition, The MWRA studied the issue in
the FEIR, Volume I, and will study alternative
disinfection techniques further as part of its
Facilities Plan.
Information is needed on the impacts on marine life of dredge
spoils disposal. A comparison should be made between
pipeline and tunnel contruction.
An analysis of this issue appears in the FEIR,
Volume I. A comparison of methods will be done as
part of MWRA's Facility Plan and will include an
environmental review of the available options.
Many commentors requested further information on water
quality impacts of priority pollutants and toxics. Specific
information should be provided on pollutants which will
exceed water quality criteria and remedies or control
mechanism which exist. Reasonable background levels should
be proposed and used for secondary outfall evaluations.
Criteria for such direct poisons as cadmium and mercury
should be addressed.
As a result of these concerns, EPA initiated a
water quality modeling effort as part of the FEIS.
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Results of this study are shown in Volume II,
Section II-7. In addition, the monitoring that
will be required by the new NPDES permit to be
issued to the MWRA is expected to greatly improve
the effluent data base. EPA recommends that the
MWRA undertake a comprehensive data acquisition and
modeling program. Since the permit is reissued
every five years, data obtained can be used to
impose more stringent requirements if needed.
o The FEIS should clarify whether the new wastewater treatment
plant will require an emergency bypass outfall.
Bypassing is prohibited by federal regulations
except under specified, very limited conditions.
See 40 C.F.R. Section 122.41(M).
o EPA should discuss the limitations of the desktop version of
"MERGE", the computer model used to predict water quality
impacts.
The limitations of this model are described in
Volume II, Section II-7.
o A commentor asked that EPA clarify whether the 301(h) water
quality data shown in the SDEIS Water Quality Impacts
Section was lower than normal due to wet: weather sampling.
The 301(h) data on priority pollutant
concentrations in the existing effluent appeared
lower than normal because, for many of the samples,
only filtrate of the effluent was analyzed.
Cost/financal impacts;
- Capital cost comments
o MDC called into question the cost estimates developed in the
SDEIS. They developed their own estimates, which differed by
21 percent to 68 percent from those contained in the SDEIS.
It must be stressed that cost estimates made
at this stage are approximations and the estimate
of total cost is likely to be more accurate than
that of individual line items. It should also be
mentioned that cost estimation will be greatly
refined during the Facilities Planning process.
Since the release of the SDEIS, EPA and its
consultants have met frequently with MDC (later
MWRA) and its consultants, to resolve the
differences between the agencies' cost estimates.
At these meetings, the agencies reviewed, revised
and agreed upon basic assumptions and developed a
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set of "consensus" cost estimates. Subsequently,
MWRA's consultants have further refined the cost
estimates of the all Deer Island and all Long
Island options, based upon more specific assump-
tions regarding site design. The most recent cost
estimates show no significant cost differences
between the the Deer and Long Island options.
Cost estimates of the preferred option can be
found in Volume I of the FEIS. Specific detailed
information on the cost estimation adjustments made
following release of the SDEIS can be found in the
FEIS Volume II, Section II-8. Information is also
available in the MWRA's FEIR, Volume I.
o The City of Boston found the presentation of costs to be
misleading and the analytical justification for raising
capital cost estimates for primary treatment compared to
previous studies to be unconvincing.
The consensus figures referred to in the
previous response include a reverification of cost
estimates of primary options.
o Costs of lost revenue from the fishing and recreation
industries should be considered in the estimates of secondary
treatment costs.
EPA believes that the provision of secondary
treatment will ultimately benefit both fishing and
recreation industries by improving Harbor water
quality and by substantial removal of toxic
compounds. Further clean up by sludge elimination
and CSO control will create further benefits.
Estimates of such benefits appear in the report
entitled "A Methodological Approach to an Economic
Analysis of the Benefits from Outcomes of Water
Quality Improvements from Sewage Treatment Plant
Upgrading and Combined Sewer Overflow
Controls", prepared for EPA as part of the 301(h)
process.
o Costs of secondary settling tanks should be verified through
comparison with actual construction costs.
Costs of secondary settling tanks have been
verified as part of the consensus figures referred
to above. Further work will be done as part of the
MWRA's Facility Plan.
o A cost comparison of various available secondary treatment
technologies should be provided.
This will be done as part of the MWRA's
Facilities Plan.
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The FEIS should include a cost estimate of an extended
outfall which might be required by subsequent water quality
evaluation.
EPA has evaluated the costs and impacts of
four secondary outfall sites. Further evaluation
of the cost and location of an optimal outfall site
will be done as part of the MWRA's Facilities Plan.
Information was requested on whether site preparation (e.g.
demolition of prison or hospital facilities) and land
acquistion costs were adequately factored into capital cost
estimates for each site option.
Revised cost estimates now include the cost of
demolishing Long Island Hospital. The cost of
demolishing the Deer Island House of Correction is
not included because it was not considered
essential for treatment plant construction. The
most recent cost estimates include detailed
consideration of land acquisition costs at Long
Island, now estimated to be about $25 million.
This information can be found in Volume II, Section
II-8.
More detailed cost estimates were requested for the Long
Island option. For example, information was requested on
pumping and other hydraulic considerations, archaeological
mitigation and pier construction. In addition, it was
suggested that EPA investigate phasing-in construction of
primary tanks at Long Island during the useful service life
of the Deer Island primary tanks as this might reduce the
life-cycle costs of Long Island facilities.
More detailed information on Long Island costs
can be found in the FEIS Volume II, Section I1-8.
Information was requested on whether the Deer Island "fast
track" expenditures have been factored into the costs of the
Deer Island options.
No credit was given to the Deer Island Fast
Track improvements because they have a short (10
year) life span.
Information was requested on whether the Nut Island headworks
option includes cost estimates of pier construction,
chlorination, and odor control measures.
Pier construction costs have not been
determined because no final evaluation has been
made concerning its necessity. It was assumed that
the chlorination building presently under
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construction will handle Nut Island headworks
chlorination. Odor control measures have been
refined in Volume II, Section II-2 and in the FEIR,
Volume I. Further cost details of the Nut Island
headworks option will be developed as part of the
Facilities Plan.
- Household costs
MDC questioned the use of a 50 percent federal share of
construction cost in estimating likely cost to homeowners.
Instead, they recommended development of estimates using
several different percentages to reflect the uncertainty
surrounding the future federal share.
The SDEIS evaluated household costs based upon
a federal share of 10%, 50% and 70% of the total
cost of a hypothetical $800 million facility. In
reality, the percent received will be constrained
by the share of the total federal appropriation
received by Massachusetts, the place of the project
on the priority list and the number of years it
appears on the list.
The City of Boston stated that the calculation of annualized
and per household costs was done with a bias toward narrowing
differences between options. They estimate that the per
household differences between the least and most costly
options is at least 25 percent greater than stated in the
SDEIS and 75 percent greater if capital costs are closer to
original capital estimates.
The reevaluation of capital costs done since the publication
of the SDEIS shows no significan difference between the
options. Per capita costs are now estimated to be even
closer than previous estimates.
Several commentors questioned the elimination of sludge
facility costs from the total. It was stated that the
evaluation of user impact is useless without considering cost
of sludge disposal. If one assumes sludge disposal cost will
be of similar magnitude as waste treatment costs, resulting
user fees will far exceed that of any other cities studied.
The EIS presents only the costs of the
proposed action, construction of wastewater
treatment facilities. EPA is not in a position to
evaluate the cost impacts of such other related
projects as ultimate sludge disposal. These will
be evaluated by MWRA as part of its Residual Solids
Management Plan. User costs will indeed have to
rise to handle these costs and other required
facilities, but this has no bearing on site
location. It should be noted that the cost of
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initial sludge processing (de-watering, digestion
and thickening) is estimated in the FEIR Chapter
III.C.2.
o Presentation of costs must include the entire cost
implications of the total harbor clean-up program. The FEIS
should include a more complete presentation of the costs in
inflated dollars of the years when full rate impact will be
felt (1995 and beyond).
See previous response.
o The FEIS financial analysis should more fully describe
particular financial consequences of revenue bond use to fund
wastewater treatment projects.
EPA is aware of the fact that the reserve fund
required by this type of bonding means that a
portion of the funds raised is unavailable for use.
MWRA will estimate the additional financial burden
posed by this type of funding in the Facilities
Plan.
- Operations/management (O&M) costs
o FEIS should more clearly define replacement costs, estimated
by the MDC at between two and five million dollars per year.
A conservative estimate of replacement costs
is 1-2 percent of capital costs. This estimate
should be made as part of the Facilities Plan.
o O&M costs are skewed by erroneous equipment life-cycle data.
EPA's Facilities Plan cost policy was used to
arrive at the costs presented in the SDEIS. O&M
costs will be more rigorously defined in the
Facilities Plan.
o Further information was requested on development of staffing
costs and costs of chlorine.
Staffing costs will be developed as part of
the MWRA's Facilities Plan. With regard to
chlorine, preliminary work on alternatives to the
use of chlorine has been developed in the FEIR and
will be finalized as part of MWRA's Facilities
Plan.
- Mitigation costs
o Costs of all suggested mitigation measures should be included
in the FEIS to reflect EPA's commitment in this area.
Mitigation cost analyses should differentiate between primary
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and secondary alternatives. Such measures include, but are
not limited to: barging/busing/ferrying; traffic control;
odor/noise control; compensatory payments; fire/police escort
services; infrastructue assessment and repair; and costs of
services to protect the community's interest during planning
and design phases.
Additional work has been done on the estimated
cost of mitigation measures that will be grant
conditions. Approximate cost of barging/busing/
ferrying appears in the FEIS Volume II, Section
II-l. Cost of odor control measures are found in
Volume II, Section II-2. Costs of noise control
measures to be required of MWRA as conditions of
grant receipt can be found in Volume II, Section
II-3. EPA will require MWRA to apply all practical
noise control measures and MWRA has committed to
establishing a noise mitigation program.
Engineering and reliability:
- Engineering
o Commentors noted that the SDEIS contains inconsistent
presentations and treatment of alternatives, especially with
regard to sludge and scum disposal. There is a lack of
detail and inadequate evaluation of treatment processes,
facilities and configurations which makes it impossible to do
a thorough analysis of potential sites, impacts, and
potential mitigation measures. The FEIS should contain a
chapter on plant engineering, including more complete
information on gross plant size, operation, component sizing,
layout, cost, energy needs and proposed energy
generating/supply methods, and the interrelationship of these
factors.
EPA has been working closely with MWRA in
developing further information on potential
configurations of the proposed wastewater treatment
facilities. This information is shown in the FEIS
Volume II, Section II-9- More complete information
will be developed during the facilities planning
and design phases.
o More information is needed concerning the use of rectangular
versus secondary clarifiers.
EPA did an analysis of the issue of
rectangular versus circular clarifiers, which
showed both to have equal reliability. Information
on this analysis is available at EPA's
Environmental Evaluation Section .
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o One commentor asked why construction durations are assumed to
be longer at Long Island.
Long Island construction is estimated to take
longer because of additional site preparation and
construction requirements.
o Additional design effort to support the FEIS should focus on
sizing and layout of the plants to mitigate adverse effects.
Preliminary sizing and layout options were
reviewed in developing studies on visual and noise
mitigation measures. Additional work will be done
during the facilities planning and design phases.
o Information was requested on the effect of proposed CSO and
I/I removal projects on influent levels and treatment plant
capacity and on whether the new plants will be permitted to
treat peak flow at less than secondary levels.
I/I removal is expected to increase the length
of time the plant can operate at or below capacity.
There appears to be no hydraulic effect of CSO
projects on treatment plant capacity. The new
NPDES permit, to be issued to the MWRA, stipulates
that the entire flow will be required to meet the
secondary treatment limits of the permit.
o Information was requested on the need for rip-rapping at Deer
Island and on statutory requirements which would be in effect
in that event.
This information will be developed during the
facilities planning and design phases.
o Location of emergency bypass should be shown on plans, and
designed to avoid near-shore bypasses.
As stated earlier, emergency bypass will be
strictly regulated and allowed only in very unusual
circumstances. Emergency bypass would be through
one of the approved outfalls.
o There is a lack of detailed analysis of secondary outfall
locations.
EPA has performed a modeling effort to predict
the effect of the discharge of secondary effluent
at several locations. This information is
summarized in Volume II, Section II-7.
- Plant reliability
o An analysis of theoretical treatment removal efficiencies is
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required. In addition, similar sized plants should be
evaluated for removal levels of conventional and toxic
pollutants.
Theoretical removal efficiencies, taken from
EPA's "Fate of Priority Pollutants in POTW1s" were
given in the SDEIS. The plant will be required to
meet state water quality standards which are
regulated and enforced through the NPDES and state
permitting processes. The MWRA's facility planning
and design processes will develop further detail on
removal levels and efficiencies.
o The FEIS should identify conditions that lead to greater
plant reliability and establish performance standards that
would ensure such reliable operations at the plant.
The new NPDES permit, to be issued to the
MWRA, is considered the standard by which the plant
will be measured. Strict enforcement of the permit
limitations is considered a top priority of EPA and
DWPC. The MWRA has stated that its goal is to
operate a well run and efficient treatment plant.
The FEIR, Volume I, outlines the Authority's
approach to the attainment of this goal, including
its commitment to proper operation and maintenance
of the facility.
Historic and Archaeological Resource Issues:
o The FEIS should contain more detailed information on Deec
Island's architectural and historical significance,
especially the drumlin and old Pump House and potential for
nomination to the National Register of Historic Places.
As part of the FEIR, the MWRA has conducted a
more detailed archeological study of parts of Deer
Island (particularly the pump house, the prison and
sections of the drumlin). This evaluation appears
in Vol. II, Section 11-10.
o The FEIS should contain a further explanation of plans to
nominate Long Island to the National Register of Historic
Places.
The Massachusetts Historical Commission has
stated its intention to nominate Long Island to the
National Register of Historical Places.
Property values:
o The SDEIS contained insufficient data on the effect of
treatment plant construction on property values. The FEIS
should include a more thorough analysis, including a
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description of methodology and an objective quantification of
property value impact during the construction period and
after operations begin.
EPA's consultants commissioned a study from
Abt Associates, Inc. on the effect of treatment
plant construction on property values. The study
consisted of a literature review and is outlined in
detail in Volume II, Section 11-14. Little
information is available on the effect of "noxious"
public facilities on residential property values
and none specifically on property value impacts of
wastewater treatment facilities. The available
information (mainly based upon airport noise)
indicates that the more a particular environmental
impact can be detected, the more will be the loss
in value. This finding implies that effective
noise and odor control measures (to be made grant
conditions) will mitigate property value impacts.
In addition, EPA prepared a report on property
value impacts of EPA-funded wastewater treatment
facilities. The report, outlined in Volume II,
Section 11-14, discussed the difficulties of
objectively determining property value impacts. It
cautioned against basing decisions on the results
of such statistical methods as multivariate
regression analysis.
o EPA should consider obtaining property value information by
using a well developed opinion survey of a panel of real
estate experts.
EPA is satisfied with the level of effort
being made to study this issue at this time. See
Volume II, Section 11-14 .for further details.
o EPA should consider contacting other regions in which large
treatment plants are sited near residential areas to
determine whether property values have been effected.
EPA officials have visited and/or contacted
operators of several large wastewater treatment
facilities. Information they have received
indicates that property values have not been
affected by a well-designed, properly operating
plant.
Other;
o Several commentors said that the SDEIS is a document biased
in favor of use of Deer Island. It is not "value neutral"
though it purports to be a fair evaluation of options. It
was charged that even the photographs contained in the
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document are biased. For example, the photo of Nut Island is
angled to show the proximity of the plant to homes, while
that of Deer Island is angled away from Winthrop.
EPA considers the SDEIS to be a fair and
unbiased evaluation of the effects of the options
considered. However, the many written and oral
comments made concerning the document convinced EPA
that further work was required in several areas
before a site decision could be made. This work,
which appears in Volume II, clarified or re-
evaluated many areas of contention. EPA feels that
sufficient information now exists upon which to
base its decision on the most environmentally
preferable site for wastewater treatment
facilities.
o The SDEIS did not consider a sufficient number of options and
is not a comprehensive analysis of all feasible alternatives.
EPA believes that the SDEIS is a comprehensive
analysis of all feasible alternatives. EPA began
the EIS process by initiation of a lengthy scoping
process designed to generate all feasible
alternatives for study. This process included
participation by federal, state and local
governments as well as environmental, business and
neighborhood interest groups. The scoping process
generated twenty-two alternatives, which were then
studied and screened down to eight in the SDEIS.
As mentioned in the previous response, EPA
undertook substantial additional work before making
its final siting decision.
o The legal and institutional analysis is inadequate because it
does not consider the existence and implication of local
permits and regulations.
EPA believes these analyses are comprehensive.
With specific regard to local permits and regula-
tions, EPA judged that the project proponent could
meet specifications of pertinent local
requirements.
o The SDEIS should be revised to take into consideration likely
changes in the federal role. In addition, the effect on
siting of the Massachusetts Water Resources Authority should
be analyzed.
Changes in the federal role are very difficult
to predict with any degree of certainty. Possible
variations in federal funding have been considered
and appear in the cost information shown in Volume
II of the SDEIS.
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o Satellite treatment facilities should be studied in greater
detail.
The SDEIS performed an analysis of the
feasibility of satellite treatment facilities. EPA
has recommended that MWRA continue study of the
feasibility of satellite treatment facilities.
Further discussion of that position can be found in
Section N of this document.
o The "No Action" alternative should be displayed and analyzed.
See Volume I, No Action Alternative section.
o There is insufficient data to begin "404" and "103"
regulatory review required by the Army Corps of Engineers.
This information will be developed by the MWRA
as part of their Facilities Plan.
o Federal Aviation Agency requires additional information to
ensure that treatment facilities do not impede flights.
EPA has reviewed FAA requirements and
determined that the wastewater treatment plant will
not interfere with flight paths from Logan Airport.
H - Level of Treatment
Many people commented on the preferred level of treatment and
on the 301(h) waiver process. Several people objected to making
the siting decision before the waiver decision, saying that it
was impossible to determine impacts realistically without knowing
the level of treatment required. The majority of comments were
in favor of the waiver and opposed to the use of secondary
treatment for the following reasons: Primary treatment is the
easiest to implement; secondary treatment is unnecessary from a
water quality standpoint; it is much more costly to operate; it
requires much more space (thus needlessly complicating the siting
decision); its use would mean expending all available resources
while more significant pollution problems remain unaddressed. It
was also stated that secondary treatment with a local outfall
will be less effective than primary with a deep ocean outfall
because any breakdown would fill the Harbor with raw sewage. One
person requested evidence that a secondary treatment plant of
this size will work.
Several other people expressed disapproval of primary
treatment with a deep ocean outfall, saying that such a system
simply places the problem further out of sight and may have a
negative impact on the rich fishing grounds in the area. Another
said that such a costly, time-consuming program as construction
of new wastewater treatment facilities should work towards
adherence to the most stringent requirements.
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Agency Response: The tentative decision to require
secondary treatment was made as part of the separate
301(h) waiver process, a summary of which is included in
the FEIS, Volume II, Section 11-16. As required by
Congress, the decison was based solely on the biological
and chemical impacts of the proposed discharge.
The principal advantages of secondary treatment
are: better effluent disinfection; significantly greater
reduction of the wastewater's BOD and suspended solids;
additional removal of toxics; and compliance with basic
requirements of the Federal Clean Water Act. Since the
treatment plant represents the largest volumetric point
source of suspended solids to the Harbor, secondary
treatment will provide significant benefits.
I - Water Quality Issues
Many people remain unconvinced that wastewater treatment
expansion or improvements will significantly improve Harbor water
quality, marine life and public health. One person decried the
lack of a detailed discussion of the significance of various
pollution sources. No quantification of impacts and their
environmental costs has been prepared for comparison by sources
and, therefore, the significance of each source can only be
subjectively deduced. Another person pointed out that no overall
improvement can be expected because, in the year 2010, the
loading of solids into coastal waters would equal or exceed the
present level from the existing treatment plant. One commentor
urged that all beaches from Gloucester to Plymouth be closed
until it is shown that it is safe to use the water.
A great deal of concern was expressed about the level of
toxics in Boston Harbor. Several comments focused on the poor
water quality in the Harbor and its effect on shellfish and
flounder. The ambiguity of measurements of toxic concentration
in MDC's wastewater and effluent was noted and the implied
removal of toxics by secondary treatment was questioned. The
lack of information on PCB's was also a subject of concern. More
information was requested to resolve whether effluent solids or
sludge solids contribute most to high metal concentrations in
Boston Harbor.
A number of commentors focused on the adequacy of the
outfall. Several commentors noted that the predicted water
quality impacts for selected toxics could be exceeded on occasion
at the Presidents Roads outfall site.
Finally, it was stated that the water quality impacts of
pipeline construction versus tunnelling must be assessed as part
of the SDEIS and the effects on water quality and marine related
impacts of dredged materials need to be resolved.
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Agency Response: The EIS on Siting of Wastewater
Facilities for Boston Harbor is based upon the fact that
the existing plants are a major point source of
pollution in Boston Harbor that must be corrected to
eliminate violations to the Federal Clean Water Act.
The treatment plants are the single largest point source
of BOD and suspended solids to the Harbor and the annual
flow from the treatment plant exceeds the flow the
Harbor receives from the region's three major rivers.
In addition, it has been found that the treatment plant
effluent is a significant source of toxics entering
Boston Harbor.
EPA believes that secondary treatment will remove
85-90 percent of both suspended solids and BOD, and
significantly improve harbor water quality, marine life
and public health, particularly in the Middle and Outer
Harbor areas surrounding the Boston Harbor Islands State
Park. Secondary treatment will result in significant
reductions of solids loading into the Harbor.
Additional improvements will also result from
elimination of the sludge discharge from the Harbor and
from implementation of a CSO control program.
The EIS relied on 301(h) data supplied by the MDC
to determine baseline conditions in the Harbor. As a
result of questions and comments regarding the assumed
secondary outfall made during the review of the SDEIS,
EPA initiated additional water quality modeling work to
evaluate the water quality impacts of three additional
outfall locations. This analysis showed that there is
potential for an acceptable secondary outfall location.
Results of the analysis can be found in the FEIS, Volume
II, Section II-7.
EPA projections on toxics levels are based upon an
analysis of both 301(h) data and MDC's report entitled
"Trend Analysis of Historical Metals Data for the Nut
and Deer Island Wastewater Treatment Facilities", which
EPA considers to be the best available data. The
effluent data base is expected to be improved by
monitoring programs to be required by the new NPDES
permit. As shown in the SDEIS Table 11.3-3, a secondary
treatment plant can be designed and operated to
substantially reduce the level of toxics entering the
Harbor. In addition, EPA believes that MWRA must
stringently enforce its industrial pre-treatment program
to further reduce influent toxics.
The water quality impacts of pipeline and/or tunnel
construction will be evaluated by MWRA as part of their
Facilities Plan.
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J - Equitable Distribution of Regional Facilities ("Fairness"
Issue)
A great deal of comment was focused on the concentration of
regional facilities in a single community. This was of greatest
concern to Winthrop residents and officials, who said that the
town had borne the brunt of adverse conditions brought about by
such regional facilities as the Deer Island treatment plant,
House of Correction and Logan Airport. They cited traffic
congestion, air and noise pollution, house-to-house searches for
excaped prisoners and lower land values as several of the many
impacts felt by Winthrop residents. In addition, Winthrop has
had to pay increased municipal costs for traffic control, police
escort service and fire service because of these facilities.
Concern was also expressed at the tendency of regional facilities
to grow, thus resulting in impacts dramatically increased beyond
those of the original facility.
They stressed that the small community of Winthrop has borne
the burden of the current treatment facility long enough, and
others should now take responsibility, particularly the City of
Boston which has encouraged a building boom with little regard
for adequate facilities to handle the waste generated. In their
view, basic "fairness" would dictate that Winthrop be spared any
further obligation to shoulder regional burdens and that another
site, preferably Long Island, be selected for wastewater
treatment facilities.
Several commentors said that fairness should be specifically
factored into the decision process, either as a separate decision
criteria or in the effects on neighbors criteria.
This argument was refuted by others, who countered that it is
not "fair" to require any one community to be the sole site of
regional waste facilities and that it makes no sense to require
Quincy residents to "share the misery" with Winthrop. Another
comraentor questioned the "fairness" of requiring the City of
Quincy and users of the Harbor Islands State Park facilities to
pay a price for the fact that other entities (e.g. Massport)
have, through their activities, imposed burdens on the residents
of Winthrop. One person noted that the residents of Winthrop
knew of the presence of the wastewater treatment facility,
prison, and Logan Airport when they moved to the area, whereas
residents of North Quincy and Squantum had no such knowledge. In
this view, changing that situation is unfair.
Agency Response; After due consideration of public
comment on the issue of fairness, EPA decided to retain
its six original decision criteria and factor fairness
into the "Effects on Neighbors" criteria. The Agency
systematically evaluated its entire data base using the
six decision criteria. For more information on EPA's
decision process, please refer to Volume I, Decision
Process section. The MWRA, pursuing an independent
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decision making process under its statutory mandate,
voted to make fairness a separate decision criteria.
K - Decision Criteria
Comments on the decision criteria to be used to evaluate the
remaining options were focused on three areas: the utility of
such a mechanism for aiding in decision-making, the addition of
other criteria, and the weight which should be assigned to the
individual criteria.
Several people criticized the use of the decision criteria.
One person said that [the STEEPLI methodology] limits public
accessibility to and understanding of the siting decision.
Another said that the failure to use a more specific, quanti-
fiable approach resulted in such vague valuation of impacts as to
make any attempt to aggregate impacts of given options impos-
sible. The writer suggested using a system which rates impacts
on a scale of 1-10 rather than Severe, Moderate and Minimal as
was done in the SDEIS. In addition, the writer felt there should
have been a ranking system for the sub-categories, each of which
might have a different impact on a different site.
Several questioned the objectivity of the proposed weighting
and ranking of alternatives and said that the FEIS should
document the results of the weighting and ranking process.
Another asked whether EPA will accept whichever sited is chosen
by MWRA since there is no clearly environmentally acceptable
alternative.
Additional decision criteria were suggested by some
commentors. Equity or fairness (consideration of cumulative
impacts of other regional facilities) was the most frequently
cited addition. Many Winthrop residents felt that its inclusion
would most adequately inject its concerns into the decision
process. Others suggested that the inclusion of fairness could
provide a framework for developing a more decentralized waste-
water management program including sub-regional treatment
facilities and off-site or inland sludge management facilities.
Others suggested such additional criteria as risk to human
life; time required to build the facilities; and prioritization
of projects, or weighing the advantages of those alternatives
whose implementation provides the earliest payback in improved
Harbor water quality. One person suggested that "recreation"
should appear as an explicit criteria and not simply be subsumed
in other criteria.
With regard to the weight assigned to criteria, many
commentors argued that "effects on neighbors" should be weighted
most heavily. One Winthrop commentor stated that the SDEIS too
often called impacts on Long Island's wildlife, vegetation, and
gravesites "severe", while dismissing as "nuisances" impacts on
Winthrop residents. Another complained that the priority given
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by the Citizens Advisory Committee to social impacts was inverted
by EPA, thus ignoring early citizen's input. One commentor urged
EPA to make a clear distinction between the construction and
operation phases when evaluating the "effects on neighbors"
criteria.
Cost was another criteria which was the subject of much
comment. One person felt that not enough attention had been paid
to the cost and resulting financial impacts of alternatives.
Another urged the protection of rate payers (especially low and
moderate income households) by selection of the least cost
alternative.
Reliability was also frequently mentioned as a priority
criteria, given the harsh, salty environment in which the
facilities must operate. Reliability was called of utmost concern
to users of area swimming beaches.
Preservation of natural and cultural resources and harbor
enhancement were sited as high priority by some commentors.
Agency response: As noted in the previous section, EPA
reviewed in detail the comments made concerning the
proposed use of decision criteria to assist in the site
selection process. The Agency decided to keep intact
its six decision criteria and use the rating and
weighting process as an analytical tool to organize and
evaluate each piece of data. The process followed is
described in detail in Volume I, Decision Process
section.
L - Segmentation Issue/Related Pollution Issues (Sludge, I/I,
CSO's, etc)
Many commentors sought to place the siting of treatment
facilities within the larger context of overall Harbor pollution
issues. In their view, the SDEIS is defective because it deals
with only the treatment facility siting "segment" of the Harbor
problem and does not consider such issues as sludge management,
CSO's, industrial pre-treatment, reduction of infiltration and
inflow (I/I), and management and staffing of facilities. Several
said that a balanced plan must be developed which includes
clearly established harbor clean-up priorities placed within a
context of relative costs and importance. Commentors said that
no one decision should be made in isolation, since a decision on
the level of treatment required, the location of the treatment
plant/s, or the methods of sludge handling affects the evaluation
of options for the remaining two issues.
Issues receiving attention:
Sludge; The largest number of comments focused specifically on
the sludge management issue, the exclusion of which was said to
call into question the legality, adequacy and usefulness of the
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SDEIS. Several people claimed that sludge and siting decisions
are intertwined and must logically be made together. Many felt
that it is not possible to judge the possible impacts on proposed
treatment plant sites without knowing which method of sludge
disposal will be used. Others mentioned that failure to include
some indication of the implications of each site option for
future choices of sludge management options and the likely
environmental impacts and costs of sludge management at each site
could be a "fatal flaw" in the EIS process.
One commentor said that the selection of sites for the
facility should include potential for accommodating sludge
treatment options in the decision criteria. If one alternative
can incorporate both sludge and wastewater treatment, it should
be considered a preferred site. By contrast, another commentor
said that if the state and EPA really believe siting issues are
separate from sludge management, they should guarantee a policy
that places sludge facilities away from wastewater treatment
facilities, forever eliminating Deer Island as a site for a
sludge management facility.
Infiltration/Inflow: Several commentors urged that the state and
EPA address the I/I problem and develop an enforceable I/I
reduction program as soon as possible. One commentor suggested
that the FEIS include a discussion of the relationship of I/I to
the design flow under consideration. Another commentor suggested
that EPA consider making installation of flow monitoring devices
and reduction of extraneous flow to design capacity grant
conditions. Failure to satisfy this condition would result in
automatic limitations on new flows. Finally, one person urged
the federal government to change its regulations to encourage
correction of I/I.
CSO's; Many commentors stressed the importance of this issue in
the overall Harbor clean-up effort. One commentor questioned the
effect of proposed CSO projects on the influent and asked whether
any possible changes would affect the scale of the treatment
plant.
Pre-treatment; Several people urged that industrial pre-treatment
receive more emphasis in the FEIS. They said that EPA should
indicate how the pre-treatment program will be managed to protect
the biological treatment program. This discussion should include
EPA's recommendation of changes needed to water quality discharge
criteria necessary to attain water quality standards. In
addition, industrial discharge limits should be indicated.
Finally, it was suggested that the FEIS indicate the link between
more effective pre-treatment and sludge management options.
Spoils disposal; Concern was expressed over the disposal of
construction debris and dredged materials. Objection was made to
the use of the Marblehead Foul Area. One commentor asked whether
there would be a separate EIS on disposal of dredged materials.
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Agency Response; EPA agrees that the clean-up of Boston
Harbor will require a coordinated harbor improvement
program, including a series of related and inter-
connected actions in the areas referred to by
commentors. However, it has been determined by EPA that
effluent discharges from the existing wastewater treat-
ment facilities contribute over half of the suspended
solids and oxygen consuming matter discharged to Boston
Harbor and are thus a major source of harbor pollution.
Siting of wastewater treatment facilities is therefore a
necessary step towards the overall clean-up of Boston
Harbor. In addition, it has been determined that none
of the related causes of pollution problems will have a
bearing on the selection of an environmentally accept-
able site for wastewater treatment facilities.
It must be emphasized that the EIS on the Siting of
Wastewater Treatment Facilities in Boston Harbor is not
intended to serve as a comprehensive water quality
management plan. MWRA has put forth such a plan,
entitled "Program for the Boston Harbor Clean-up", which
is currently under EPA review. The program includes a
detailed schedule/timetable for additional planning
and/or implementation of ongoing programs in several of
the areas referred to by commentors including sludge
management, CSO control and I/I removal.
With regard to the separation of siting from sludge
management, EPA determined that none of the sludge
disposal alternatives being considered would foreclose
any facility location, and none of the wastewater
treatment facility options would foreclose a sludge
management solution. It was further determined that a
great deal of analysis was needed before a sludge
management decision could be made. Given these facts
and because of the urgent need to site expanded
wastewater treatment facilities, the decision was made
to proceed separately with the siting EIS. The MWRA has
outlined its approach to the sludge management issue in
the FEIR, Volume I. Included are estimates of likely
on-site initial sludge processing up to the point of
interface with final disposal options. The Authority
will be undertaking a Residual Solids Management Plan
which is expected to be completed by 1987.
With regard to pre-treatment, an existing program
had been in place since 1973, and an EPA-approved
program since 1982. A 1984 audit, published by EPA in
March 1985, found that the MDC inspection and monitoring
procedures were adequate and its available staff
competent. However, the program was found to be
understaffed and underequipped. Since July, 1985, the
MWRA has made significant progress in providing
additional staff and other necessary program support.
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Regarding spoils disposal, debris has to be
analyzed for its level of pollutants. If the material
meets the criteria for ocean disposal, it can be
disposed of at the Marblehead Foul Area, subject to the
Corps of Engineers 404 permit procedure. If the
material does not meet the criteria, it must be disposed
of in a secure landfill.
M - Growth of the System
Many people expressed frustration at the fact that
communities within the MSD have encouraged growth, and hence
increased wastewater flow, without regard to the impact on
downstream communities. Many commentors asked what checks will
be placed on the MSD to avoid future problems to the wastewater
treatment facility. They asked EPA to comment on whether the
facilities currently being planned will eventually need to be
expanded to treat additional flow from expected growth in the
South and North MSD. Several questioned the impact of such
ongoing MDC projects and the Braintree-Weymouth Pump Station,
Wellesley Extension Relief Sewer, new Neponset Valley Sewer and
the Framingham Extension Sewer on the flow and treatment capacity
of the system.
A number of commentors urged the MWRA to institute a sewer
hook-up moratorium to place a "cap" on the amount of flow to the
harbor. Such a cap was seen as a means of ensuring that the new
facilities will operate properly and not violate the discharge
permit. Some felt such a moratorium should be on all hookups,
others said it should be for hotels, office buildings and
condominiums only, and another commented that a moratorium should
be imposed only if a documented and enforceable flow reduction
program is not developed.
It was also suggested that water and sewer rates are
regressive and that the MWRA should initiate stricter
conservation measures.
By contrast, one commentor urged that the site and facility
be large enough to treat any increased volume of wastewater which
may be created in the near future.
Agency Response: EPA's statutory obligation is to
enforce the provisions of the Clean Water Act through
the NPDES permitting procedure. The management and
accommodation of system growth is the responsibility of
the MWRA which has addressed these issues in the FEIR,
Volume I. Further I/I reduction activites, agreed to
under the state court procedural order, are progressing.
EPA supports any efforts made by the MWRA to initiate
effective wastewater management programs.
With regard to flow, the FEIR concluded that the
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conservative sizing assumptions used provide reasonable
allowances for future population growth within the
existing service area. Further facility expansion to
accommodate additional wastewater flow is therefore
considered unlikely during the existing service life of
the new plant.
The separate problem of the flows in the South
Metropolitan Sewer System is also being addressed.
Rigorous I/I removal will be required in order to obtain
the plant's projected service life.
The MWRA may choose to implement strategies
designed to control and reduce the level of discharge
into the sewer system if growth of the service area
exceeds the projections which have been made earlier, or
if desirable to lower ongoing maintenance costs, provide
for greater control in wet weather flow or defer any
need for long term service capacity increases. The FEIR
has identified and briefly explored three broad
categories of techniques for management of wastewater
flows: repair of physical plant, pricing strategies and
regulatory controls.
With regard to growth of the system, EPA has no
position on the number of communities served, but
strongly discourages any further expansion of the Harbor
wastewater treatment facilities. EPA recommends that if
additional communities need wastewater treatment
services, MWRA should investigate such alternatives to
treatment plant expansion as sub-regional treatment
facilities. It was noted in the FEIR that any additions
to the service area must receive certain special
approvals.
N - Satellite (Subregional) Treatment
"Make each community responsible for its own wastewater", and
"Treat the waste problem at its source", were frequently heard
comments on the SDEIS. A great deal of attention was paid to the
development of a decentralized wastewater treatment system, both
in the interest of a more equitable distribution of facilities
perceived as unwelcome and in consideration of the likely need
for increased capacity in the future.
Many felt that the SDEIS's examination of the satellite issue
is cursory and several asked for more detail on the post-siting
decision plans to pursue the satellite concept. One commentor
argued that the scale of harbor facilities could be reduced if
aggressive development of subregional treatment facilities was
combined with an equally aggressive I/I removal program.
Further, it was stated that subregional facilities can provide
localized growth capacity when further I/I reductions can no
longer increase system capacity.
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One commentor asked whether satellites might make it possible
to partially or completely segregate household from industrial
waste flows, and whether such a system might result in benefits
in terms of easier, safer and cheaper sludge management.
By contrast, the EOEA's "Certificate of the Secretary of
Environmental Affairs on Draft Environmental Impact Report"
indicated that the SDEIS adequately demonstrates that satellite
treatment plants cannot replace a substantial treatment facility
at the water edge and that utilization of satellite plants cannot
materially reduce the size of the required facilities.
Agency Response; As noted in the SDEIS, Section 5.6.2,
and explained in detail in "Evaluation of Satellite
Advanced Wastewater Treatment Facilities", CE Maguire,
Inc., EPA does not consider inland "satellite" advanced
wastewater treatment facilities appropriate at this
time. Several reasons were given for that conclusion:
1. Development of these facilities would not provide
sufficient flow relief or otherwise reduce the volume of
flows in the MSD southern system to reduce the size of a
harbor facility.
2. All currently planned MDC interceptor relief
projects are downstream of the proposed sites and would
therefore have to be built, resulting in no offsetting
capital outlay savings.
3. The potential water supply/public health dangers
associated with the impacts of discharge to a
wetlands/watershed area are significant.
4. The limited availability of suitable wetlands in
close proximity to the proposed systems suggests that
facilities of such magnitude as proposed would be
difficult to site.
5. The major capital and O&M costs of developing three
AWT facilities do not appear to be justified by the lack
of potential benefits of such facilities relative to the
need to site harbor treatment facilities.
Such facilities may be required sometime in the
future if removal of I/I from the sewer system does not
achieve currently predicted flow reductions.
0 - Massachusetts Water Resources Authority (MWRA)
A great deal of attention was paid to the new MWRA. Most
comments focused on the need to give the Authority input on
decisions it will be required to implement. Mention was made of
the need to provide the MWRA with adequate enforcement powers,
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regulatory backup and funds, so that the new treatment plants
will work more efficiently than under the MDC administration.
Some commentors urged that no action be taken on waiver or
siting decisions until the MRWA Board of Directors and staff have
been given a chance to review issues and provide input on these
decisions .
Agency Response: EPA feels that the legislation
creating the MWRA provides the Authority with adequate
enforcement powers, regulatory backup and funds.
EPA has been working closely with the MWRA Board of
Directors and staff since the Authority's formation in
the spring of 1985. EPA and MWRA consultants have been
working closely since the publication of the SDEIS/EIR
to develop refined cost estimates and other technical
material necessary to reach a final siting decision.
The MWRA voted to prepare a different decision document
because it followed a different decision process.
P - Public Participation
Several complaints were made about the procedures used to
call upon speakers at the public hearings. One person felt that
the general public had to wait too long to be called upon, while
another complained that the three minute time limit was not
enforced adequately.
Agency Response; Due to the large attendance at ^
public hearings, the "ground rules" set for the public
hearings specified that every third speaker would be a
member of the general public. This rule was followed,
but the large number of people wishing to speak meant
that many people had a long wait before being
recognized .
There were a few exceptions made to the three
minute limit, based on special requests. EPA regrets
the inconvenience this may have caused and intends to
enforce time limitations more strictly at future public
hearings.
EPA is extremely pleased with the high level of
public interest shown and hopes that the public will
continue to support its efforts to clean up Boston
Harbor.
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