VOLUME IV
PUBLIC and INTERAGENCY COMMENTS
Final Environmental Impact Statement
SITING
of
'EWATER
TREATMENT FACILITIES
for
BOSTON HARBOR
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F.K. FEDERAL BUILDING
BOSTON, MASSACHUSETTS O22O3
1985
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VOLUME IV
PUBLIC and INTERAGENCY COMMENTS
Final Environmental Impact Statement
SITING
of
WASTEW&TER
TREATMENT FACILITIES
for
BOSTON HARBOR
Prepared by;
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION I
Technical Assistance by-
THIBAULT/ BUBLY ASSOCIATES
PROVIDENCE. RHODE ISLAND
MICHAEL R. DELAND Date
Regions] Administrator, U.S. EPA, Region I
This Final Environmental Impact Statement has been prepared
-f by the U.S. Environmental Protection Agency (EPA) with
v assistance from the General Services Administration as a
* Cooperating Agency under the requirements of the National
" Environmental Policy Act. The FEIS identifies and evaluates
? the environmental impacts of various site options for waste-
««flt& 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
SITING OF WASTEWATER TREATMENT FACILITIES
IN BOSTON HARBOR
VOLUME IV - PUBLIC AND INTERAGENCY COMMENTS
INTRODUCTION
This document, Volume IV 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 III - Public Participation
Volume IV is a record of the public comment made following
the release of the SDEIS. It consists of the following sections:
page
IV-1 LOG OF WRITTEN AND ORAL COMMENTS 1-1
IV-2 COPIES OF LETTERS/COMMENTS 2-1
IV-3 STATEMENT ON THE AVAILABILITY OF HEARING
TRANSCRIPTS 3-1
-------
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ACTION:
SITING OF WASTEWATER TREATMENT FACILITIES IN BOSTON
HARBOR
LOCATION:
BOSTON, MASSACHUSETTS
DATE:
DECEMBER, 1985
SUMMARY OF ACTION:
This FEIS considers the environmental acceptability of
alternative locations for the construction of new
wastewater treatment facilities for Boston Harbor. The
FEIS recommends the construction of a secondary
wastewater treatment facility at Deer Island.
VOLUMES:
I. COMPREHENSIVE SUMMARY
II. TECHNICAL EVALUATIONS
III. PUBLIC PARTICIPATION and RESPONSE TO COMMENTS
IV. PUBLIC and INTERAGENCY COMMENTS
LEAD AGENCY:
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION I
J.F.K. Federal Building, Boston, Massachusetts 02203
COOPERATING AGENCY:
GENERAL SERVICES ADMINISTRATION
TECHNICAL CONSULTANT:
THIBAULT/BUBLY ASSOCIATES
235 Promenade Street, Providence, Rhode Island 02908
FOR FURTHER INFORMATION:
Mr. Ronald Manfredonia, Water Management Division, U.S.
EPA, Region I, J.F.K. Federal Building, Boston,
Massachusetts, 02203
(617-223-5610)
FINAL DATE BY WHICH
COMMENTS MUST BE RECEIVED:
-------
SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT STATEMENT (SDEIS)
SITING OF WASTEWATER TREATMENT FACILITIES IN BOSTON HARBOR
PUBLIC HEARINGS ON SDEIS - PUBLIC COMMENT LOG
WRITTEN STATEMENTS
[Note; See last page of this section for key to comment categories]
FEDERAL
Congressman Edward Markey
U.S. House of Reps.
2100 A JFK Bldg.
Boston, MA 02203
Date of written comment: 2/28/85
Hearing: Winthrop, 2/28/85
Sent to: EPA
Comment categories: B,J,K,L.
* * *
Don L. Klima, Chief, Eastern
Division of Project Review
Advisory Council on
Historic Preservation
The Old Post Office Bldg.
1100 Penna. Ave, N.W. #809
Washington, D.C. 20004
Date of written comment: 2/25/85
Sent to: EPA
Comment categories: B,K.
* * *
Vincent A. Scarano
Manager, Planning/Programming
Branch
U.S. Department of Transportation
Federal Aviation Administration
New England Region
12 New England Executive Park
P.O. Box 510
Burlington, MA 01803
Date of written comment: 3/18/85
Sent to: EPA
Comment categories: G.
* * *
Colonel Carl B. Sciple
Army Corps of Engineers
New England Division
424 Trapelo Road
Waltham, MA 02254
Date of written comment: 3/25/85
Comment categories: G,J.
* * *
William Patterson
Regional Environmental Officer
Department of Interior
15 State Street
Boston, MA 02109
Date of written comment: 4/8/85
Comment categories: B,I,N.
* * *
STATE/REGIONAL
William J. Geary, Commissioner
Metropolitan District Commission
20 Somerset Street
Boston, MA 02108
Date of written comments:
3/8/85, 3/14/85 and 3/15/85
Sent to: EOEA
Comment categories: G.
* * *
S. Russell Sylva, Commissioner
EOEA, DEQE
One Winter Street
Boston, MA 02108
Date of written comment: 3/8/85
Sent to: EPA and EOEA
Comment categories: G,I.
* * *
James Hoyte
"Certificate of the Secretary of
Environmental Affairs on Draft
Environmental Impact Report"
EOEA
100 Cambridge Street
Boston, MA 02202
Sent to: EPA
Date of written comment: 3/18/85
Comment categories: F,G,J,L,N.
* * *
1-1
-------
Samuel Mygatt
EOEA
100 Cambridge Street
Boston, MA 02202
Date of written comment: 2/1/85
Sent to: EPA
Comment categories: G.
* * *
Valerie A. Talmage, Exec. Dir.
Massachusetts Historical Commission
80 Boylston Street
Boston, MA 02116
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: A,B.
* * *
Dave Shepardson, Steve Davis,
Nancy Baker, MEPA Unit
EOEA
100 Cambridge Street
Boston, MA 02202
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: F,G,I.
* * *
Senator Michael Lopresti, Jr.
Mass. Senate
State House, Room 213-C
Boston, MA 02133
Date received: 3/21/85
Sent to: EPA
Comment categories: A,B,F,G,J.
* * *
Representative Thomas F. Brownell
Mass. House of Representatives
State House, Room 138
Boston, MA 02133
Date of written comment: 3/6/85
Sent to: EPA
Comment categories: A,B,D,F,J,N.
* * *
Gerald St. Hilaire, Assistant
Secretary
Exec. Office of
Communities and Development
100 Cambridge Street
Boston, MA 02202
Date of written comment: 3/8/85
Sent to: EPA
Comment categories: Z
* * *
James Gutensohn, Commissioner
DEM
100 Cambridge Street
Boston, MA 02202
Date of written comment: 3/11/85
Sent to: EPA
Comment categories: B,G.
* * *
Joel B. Bard
General Counsel
and Assistant Director
Metropolitan Area Planning Council
110 Tremont Street
Boston, MA 02108
Date of written comment: 3/13/85
Sent to: EOEA
Comment categories: F,G,L,N.
WINTHROP
OFFICIALS/BOARDS/DEPARTMENTS
Robert A. DeLeo, Chairman
Winthrop Board of Selectmen
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B,F,G,J,L.
* * *
Ronald V. Vecchia
Winthrop Board of Selectmen
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A,G,J.
* * *
Robert E. Noonan
Winthrop Board of Selectmen
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: G,J.
* * *
1-2
-------
Harlan Doliner
McGregor, Shea & Doliner
27 School Street, Suite 603
Boston, MA 02108
Date of written comment: 3/11/85
Hearing: Winthrop - 2/28/85
Sent to: EOEA
Comment categories: G,K,L.
* * *
S. David Graber, Engineering
Consultant to
Town of Winthrop (Board of
Selectmen) Statement included
article on sludge mngmt.
Town Hall
Winthrop, MA 02152
Date of written comment: 3/6/85
Hearing: Winthrop - 2/28/85
Sent to: EOEA
Comment categories: A,B,E,G,I,J,L.
* * *
Dr. Richard C. Larson, Professor
of Urban Studies, MIT
Co-Director Operations
Research Center, MIT
3 Johnson Terrace
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B,G,K.
* * *
Mary A. Kelly, Chairman
Winthrop Conservation Comm.
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: G,I,N.
* * *
John McGovern
Winthrop Conservation Comm.
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28//S5
Hearing: Winthrop - 2/28/85
Comment categories: A,J.
* * *
Lois Baxter
Winthrop Conservation Comm.
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: D,K.
* * *
WINTHROP
ORGANIZATIONS
Dalrymple, Dawson, Hazlett
Winthrop Board of Health
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A,B,G,I.
* * *
Robert L. Driscoll
Winthrop Planning Board
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: E,G.
* * *
Thomas M. Memmolo
Benevolent and Protective
Order of Elks
Winthrop Lodge No. 1078
191 Washington Avenue
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B,D.
Paul D. Comerford, President
Rotary Club of Winthrop
130 Grovers Avenue
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B,D,E,J.
* * *
1-3
-------
Barbara Gloss
Winthrop CCC
256 River Road
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: D,E.
* * *
Arthur T. Cummings
Winthrop CCC
51 Emerson Road
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B,L.
* * *
Laura A. Pelletier, President
Winthrop High School
Parents Club
Main Street
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B,J.
* * *
Frank Constantino, Chairman
Winthrop Beautification Comm.
Town Hall
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A.
* * *
Beverly Colson, President
Winthrop Emblem Club
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A,B,D,E.
* * *
James M. Matarazzo, President
Winthrop Band Parents Assoc.
Winthrop High School, Main Street
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A,B.
* * *
Ernestine Vecchio
Winthrop Council on Aging ,
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: E,J.
* * *
Ernest E. Hardy, Jr.
Winthrop Rep. Citizens Comm.
229 Woodside Avenue
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: E,G,J.
* * *
Anne C. Porter, Co-Chairperson
Winthrop CCC
50 Pebble Avenue
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: F,G,J,K,L.
* * *
Kathy Lane
Winthrop CCC
260 Main Street
Winthrop, MA 02152
Date of written comment: 2/27/85
Hearing: Cambridge - 2/27/85
Comment categories: F,G,J,K,L.
* * *
Terry Vasquez
Winthrop CCC
59 Nahant Avenue
Winthrop, MA 02152
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: F,G,J,K,L.
* * *
Gary Skomro, Secretary
Winthrop CCC
42 Franklin Street #2
Winthrop, MA 02152
Date of written comment: 3/13/85
Sent to: EPA
Comment categories: G.
* * *
1-4
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WINTHROP
RESIDENTS
Betty Boyer
11 Wave Way Avenue
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: E.
* * *
Tom McNiff, Jr.
118 Grandview Avenue
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B,G,J.
* * *
The Mayos
36 Shore Drive
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: E.
Louise Mcllroy
Address not given
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B.
* * *
Resident of Point Shirley
Address not given
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A.
* * *
The Hines Family
15 Whittier Street
Pt. Shirley, Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A.
* * *
Deborah Mayo
36 Shore Drive
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: B.
* * *
Laurie DeAngelis
9 Crystal Cove Avenue
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: B,D.
* * *
Diane Musi
140 Somerset Avenue
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: D,E,I,J.
* * *
Unidentified citizen
Address unknown
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: E.
* * *
Lola Mayo
36 Shore Drive
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: E.
* * *
Ann L. Viot
122 Grandview Avenue'
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: A,B,D.
* * *
Christopher M. Stevens
One Seal Harbor Road, #802
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories:'A.
* * *
1-5
-------
Ralph Tufo
62 Crystal Cove Avenue
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A,E,I.
* * *
Pearl Sabat
One Pond Street, #9F
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: A.
* * *
L. Fich
132 Shirley Street
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: A,B,N.
* * *
John D. Rogers
7 Siren Street
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: B,G,J.
* * *
Dorothy Sancco
35 Pearl Avenue
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: E.
* * *
Laura Stasio
45 Tafts Avenue
Winthrop, MA 02152
Date of written comment: Not given
Hearing: Winthrop - 2/28/85
Comment categories: A,B.
* * *
Anne McDermott
45 Pebble Avenue
Winthrop, MA 02152
Date of written comment: 2/28/85
Hearing: Winthrop - 2/28/85
Comment categories: A,J.
* * *
George Blaisdell
164 Cottage Park Road
Winthrop, MA 02152
Date of written comment: 3/3/85,
3/20/85
Sent to: EPA
Comment categories:
3/3/85 - B,E,I,J.
3/20/85 - A,B.
* * *
Regina C. Caffrey
158 Highland Avenue
Winthrop, MA 02152
Date of written comment: 3/3/85
Sent to: EPA
Comment categories: B.
* * *
Gertrude Jackman
19 Buckthorn Street
Winthrop, MA 02152
Date of written comment:
Sent to: EPA
Comment categories: B.
* * *
2/25/85
Russell F. Hughes
(Included copy of Winthrop
Sun-Transcript Editorial, 3/6/85)
80 Woodside Avenue
Winthrop, MA 02152
Date of written comment: 3/7/85
Sent to: EPA
Comment categories: B.
* * *
Mr. and Mrs. Robert Wynne
209 River Road
Winthrop, MA 02152
Mr. and Mrs. John Stasio
45 Tafts Avenue
Winthrop, MA 02152
Date of written comment: not given
Sent to: EPA
Comment categories: B,E.
* * *
1-6
-------
L. Stasio
45 Tafts Avenue
Winthrop, MA 02152
M. Wynne
209 River Road
Winthrop, MA 02152
Date of written comment: not given
Sent to: EPA
Comment categories: A.
* * *
Gertrude Flannery
(no address given)
Winthrop, MA
Date of written comment: not given
Comment categories: A.
* * *
Anne Porter
50 Pebble Avenue
Winthrop, MA 02152
Date of written comment: 3/12/85
Sent to: EPA
Comment categories: A.
* * *
Paul N. Anderson
Commissioner
Department of Public Works
City of Quincy
(Included copy of technical
statement prepared by David
Standley)
55 Sea Street
Quincy, MA 02169
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: B,G,H,K.
* * *
Joanne Condon, Councillor Ward 6
City of Quincy
City Hall
Quincy, MA 02169
Date of written comment: 3/7/85
Hearing: Quincy - 3/7/85
Comment categories: I.
* * *
QUINCY
ORGANIZATIONS
QUINCY
OFFICIALS/BOARDS/DEPARTMENTS
Francis X. McCauley, Mayor
City of Quincy
City Hall
Quincy, 02169
Date of written comment: 3/7/85
Hearing: Quincy - 3/7/85
Comment categories: A,B.
* * *
David Standley, Consultant
To City of Quincy
McGrath, Sylva, & Assoc., Inc
15 Court Square, Suite 540
Boston, MA 02108
Date of written comment: 3/11/85
Sent to: EPA
Comment categories: F,G,H,J,K,L,N.
* * *
Patricia Ridlen, Director
Hough's Neck Comm. Center
91 Rock Island—Road
Quincy, MA 02169
Date of written comment: Not given
Hearing: Quincy - 3/7/85
Comment categories: C.
* * *
Jack Walsh, Chairman
Nut island CAC
63 Sea Avenue
Quincy, MA 02169
Date of written comment: 3/7/85
Hearing: Quincy - 3/7/85
Comment categories: C,E,G,L,M.
* * *
Daniel A. Bythrow, President
Houghs Neck Community Center
1193 Sea Street
Quincy, MA 02169
Date of written comment: 3/7/85
Hearing: Quincy - 3/7/85
Comment categories: C.
* * *
1-7
-------
Ann-Marie Noyes, Chairperson
Community Issues
Roger Haskins, Chairman
Germantown Neighborhood Council
333 Palmer Street
Quincy, MA 02169
Date of written comment: 3/7/85
Sent to: EPA
Comment categories: N.
* * *
Frederick C. Dolgin, M.D.
Medical Director
Manet Community Health Center, Inc.
1193 Sea Street
Quincy, MA 02169
Date of written comment: 3/11/85
Sent to: EOEA
Comment categories: E.
* * *
Rona W. Goodman, V.P.
Squantum Community Assoc.
422 Washington Street
Quincy, .MA 02169
Date of written comment: 3/8/85
Sent to: EPA
Hearing: Quincy - 3/7/85
Comment categories: B,C.
* * *
Maureen Mazrimas, President
Save Our Shores, Inc.
P.O. Box 103
North Quincy, MA 02171
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: B,I,L,N.
* * *
Peter O'Connell,
President
Terry Fancher, Manager of Business
and Transportation
South Shore Chamber of Commerce
36 Miller Stile Road
Quincy, MA 02169
Date of written comment: 3/7/85
Sent to: EPA
Comment categories: A.
* * *
Harvey's Salt Water Fishing Club,
Inc.
1269 Sea Street
Houghs Neck
Quincy, MA 02169
Date of written comment: 3/20/85
Sent to: EOEA
Comment categories: C,N.
* * *
QUINCY
RESIDENTS
Kevin B. Davis
226 Rock Island Road
Quincy, MA 02169
Date of written comment: Not given
Hearing: Quincy - 3/7/85
Comment categories: C,N.
* * *
Grace Saphir, Founder
Save Our Shores, Inc.
Date of written comment: 3/7/85
Hearing: Quincy - 3/7/85
Comment categories: N.
* * *
Barbara -McGo-n-v i 11 e
29 Chickatabot Road
Quincy, MA 02169
Date of written comment: Not given
Hearing: Quincy - 3/7/85
Comment categories: H,N.
* * *
Gary J. Cunniff
132 Elliot Avenue
Quincy, MA 02171
Date of written comment: 3/7/85
Sent to: EPA and EOEA
Comment categories: B,E,H,L.
* * *
Jens E. Thornton
14 Orchard Street
Quincy, MA 02171
Date of written comment: 3/18/85
Sent to: EPA
Comment categories: H,I,N.
* * *
1-8
-------
Philip Johnson
99 Bayside Road
Squantum, MA 02171
Date of written comment: 3/7/85
Sent to: EPA
Comment categories: B.
* * *
Mary C. Blood
40 Bloomfield Street
Squantum, MA 02171
Date of written comment:
Sent to: EPA
Comment categories: A,N.
* * *
3/8/85
James B. Freel
21 Bell Street
Quincy, MA 02169
Date of written comment: Not given
Sent to: EPA
Comment categories: A,C.
* * *
Judith Goodman
68 Sea Avenue
Quincy, MA 02169
Date of written comment:
Sent to: EPA
Comment categories: C,D.
* * *
3/11/85
Barbara Menzler
99 Bayside Road
Squantum, MA 02171
Date of written comment: 3/8/85
Sent to: EPA
Comment categories: B.
* * *
Sally K. Wainwright
179 Lansdowne Street
Squantum, MA 02171
Date of written comment: 3/12/85
Sent to: EPA
Comment categories: A,B,D,N.
* * *
Janice L. Foster
74 Ashworth Road
North Quincy, MA 02171
Date of written comment: 3/8/85
Sent to: EPA
Comment categories: B,N.
* * *
Timothy and Lynn Galligan
106 Island Avenue
Quincy, MA 02169
Date of written comment: 3/8/85
Sent to: EPA
Comment categories: C.
* * *
Warren E. Houghton
26 Bellevue Road
Squantum, MA 02171
Date of written comment: 3/6/85
Sent to: EPA
Comment categories: N.
* * *
John A. Washington III
25 Island Avenue
Quincy, MA 02169
Date of written comment: received
3/18/85
Sent to: EPA
Comment categories: A,B,C,N.
* * *
Jean Green
(included letter to
the Editor from Quincy Patriot
Ledger)
211 Parke Avenue
Squantum, MA 02171
Date of written comment: 3/7/85
Sent to: EPA
Comment categories: I,M,N.
* * *
Gertrude M. Peter
7 Allerton Street
Quincy MA 02169
Date of written comment: 3/16/85
Sent to: EPA
Comment categories: I,L,N.
* * *
Martha C. Chase
143 Sea Avenue
Quincy, MA 02169
Date of written comment: 3/13/85
Sent to: EPA
Comment categories: C,P.>
1-9
-------
Tim Galligan
106 Island Avenue
Quincy, MA 02169
Date of written comment: 3/10/85
Sent to: EPA
Comment categories: A,N.
* * *
Mary Ann Lencki
10 Homer Road
Quincy, MA 02169
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: H,L,N,P.
* * *
Peter Nielsen
Susan Lewis
21 Nut Islaand Avenue
Quincy, MA 02169
Date on Written Comment;
Sent to: EPA
Comment categories: C.
3/12/85
* * *
Carol K..Hallet
125 Sea Avenue
Quincy, MA 02169
Date f written comment: 3/14/85
Hearing: Quincy - 3/7/85
Sent to: EPA
Comment categories: C.
* * *
Douglas A. Randall
155 Crabtree Road
Squantum, MA 02171
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: B,L.
* * *
Letters received from Quincy
Students: approximately 57
(4th Grade, Atherton School)
Comment categories: A,C,I.
* * *
BOSTON
OFFICIALS/BOARDS/DEPARTMENTS
Mayor Raymond L. Flynn
City of Boston
Boston City Hall
One City Hall Plaza
Boston, MA 02201
Date of written comment:
Sent to: DEM, EOEA
Comment categories: B.
2/22/85
* * *
Mayor Raymond L. Flynn
"Cleaning up Boston Harbor,
A Comprehensive Equitable
Approach."
City of Boston
Boston City Hall
One City Hall Plaza
Boston, MA 02201
Date of written comment: 2/27/85
Sent to: EPA
Comment categories: B,F,H,K,L,0.
* * *
Mayor Raymond L, Flynn
City of Boston
Boston City Hall
One City Hall Plaza
Boston, MA 02201
Date of written comment: 3/18/85
Sent to: EPA
Comment categories: B,F,L.
* * *
Francis W. Gens, Exec. Director
Boston Water and Sewer Commission
10 Post Office Square
Boston, MA 02109
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: B,F,H,L.
* * *
Stephen Coyle, Director
Boston Redevelopment Authority
One City Hall Square
Boston, MA 02201
Date of written comment: 3/15/85
Sent to: EPA
Comment categories: B.
* * *
1-10
-------
Councillor Albert L. O'Neil
City of Boston
Boston City Hall
One City Hall Plaza
Boston, MA 02201
Date of written comment: 3/6/85
Hearing: Quincy, 3/7/85
Comment categories: A,B.
* * *
BOSTON RESIDENTS
Eugenie Beal
35 Mount Vernon Street
Boston, MA 02108
Date of written comment: 3/11/85
Sent to: EPA
Comment categories: G,K,L.
* * *
Frederick H. Pfeil Jr.
North Shore Frogmen's Club, Inc.
P.O. Box 3604
Peabody, MA 01960
Date of written comment: 3/6/85
Sent to: EPA
Comment categories: I.
* * *
Sarah L. Warner
Tufts University
115 West Emerson Street
Melrose, MA 02176
Date of written comment: 2/26/85
Sent to: EOEA
Comment categories: C,F,G,H,I,J.
* * *
John F. Healy
45 Woodruff Road
Walpole, MA 02081
Date of written comment: 3/8/85
Sent to: EPA
Comment categories: I,N.
* * *
OTHER
OFF1CIALS/BOARDS/DEPARTMENTS
ORGANIZATIONS
RESIDENTS
Arthur T. Clasby
7 Johnson Road
Avon, MA 02322
Date of written comment: 3/13/85
Sent to: EPA
Comment categories: H,I.
* * *
Polly Bradley, Chairman
SWIM
33 Summer Street
Nahant, MA 01908
Date of written comment: 2/28/85
Hearing: Winthrop, 2/28/85
Comment categories: G,I,L.
* * *
Ellen Tohn, Ann Weeks,
Eric Ruder, Boston Chapter
Conservation Comm.
Appalachian Mt. Club
5 Joy Street
Boston, MA 02108
Date of written comment: Not given
Hearing: Cambridge - 2/27/85
Comment categories: B,F,K.
* * *
Nancy McCormack, Philip Doherty,
Pierre Erville
Citizen Participation
Civic Education Foundation
Lincoln Filene Center
Medford, MA 02155
Date of written comment: received
3/12/85
Sent to:
Comment
: EPA
categories:
B,G,H,K,L,M.
* * *
Jan P. Smith
COAST
Coalition on Alternative Sewage
Treatment
9 Harding Lane
Marblehead, MA 01945
Date of written comment: 3/7/85
Sent to: EPA
Comment categories: I,L.
* * *
1-11
-------
Sierra Club
New England Chapter
3 Joy Street, Rm. 12
Boston, MA 02108
Date of written comment: 3/18/85
Sent to: EPA
Comment categories: F,G,L.
* * *
Diane Greaney
Member, Bd. of Directors
Friends of the Boston
Harbor Islands
15 Sellers Street
Cambridge, MA 02139
Date of written comment: 3/14/85
Sent to: EPA and EOEA
Comment categories: B,N.
* * *
Peter Shelley
Senior Counsel
Conservation Law Foundation
of New England
3 Joy Street
Boston, MA 02108-1497
Date of written comment: 3/18/85
Sent to: EPA
Comment categories: A,B,F,G.
* * *
Fabian J. Lionetti
349 Central Avenue
Milton, MA 02186
Date of written comment: 3/7/85
Sent to: EPA
Comment categories: H,I.
* * *
R. Geist, M. Kass, D. Newton,
J. Pepsi
Tufts University
Medford, MA 02155
Date of written comment: 3/13/85
Sent to: EPA
Comment categories: G,K.
* * *
KEY TO COMMENT CATEGORIES
A - SUITABILITY OF DEER ISLAND AS
TREATMENT SITE
B - SUITABILITY OF LONG ISLAND AS
TREATMENT PLANT SITE
C - SUITABILTY OF NUT ISLAND AS
TREATMENT SITE
D - NEIGHBORHOOD IMPACTS (Note:
most listed under individual site)
E - HEALTH AND SAFETY
F - MITIGATION AND COMPENSATION
G - OMISSIONS/INADEQUACY OF SDEIS
H - LEVEL OF TREATMENT (and 301(h)
issues)
I - WATER QUALITY ISSUES
J - EQUITABLE DISTRIBUTION OF
REGIONAL FACILITIES ("FAIRNESS")
K - DECISION CRITERIA
L - RELATED POLLUTION
ISSUES/SEGMENTATION ISSUE (Sludge,
I/I, CSO's, etc.)
M - GROWTH OF SYSTEM
N - SATELLITE (SUBREGIONAL)
TREATMENT
0 - MWRA
P - PUBLIC PARTICIPATION
Z - OTHER
John J. Healey
Address unknown
Date of written comment: received
3/7/85
Sent to: EOEA
Comment categories: F,G.
* * *
1-12
-------
PETITIONS RECEIVED
Students of Willis School
approximately 126 signatures
* * *
Squantum/North Quincy residents
approximately 150 signatures
* * *
Winthrop Middle School
approximately 140
signatures
* * *
Employees of Long Island
Hospital approximately 252
signatures
* * *
Winthrop CCC
approximately
2,160 signatures
* * *
Seal Harbor Residents
approximately
122 signatures
* * *
Winthrop CCC/
Winthrop Chamber of
Commerce/
Winthrop-Board of Selectmen
sponsored postcards
2810 postcards received by EPA
* * *
Citizens of Quincy
approximately
1,350 form letters
* * *
Noise/Odor Survey
Submitted by Winthop CCC
* * *
REGISTRATION AT BOSTON HARBOR
HEARINGS
Cambridge - 2/27/85
Approximately 120
* * *
Winthrop - 2/28/85
Approximately 640
* * *
Quincy - 3/7/85
Approximately 760
ORAL STATEMENTS
Cambridge Hearing - 2/27/85
Michael Morrissey
State Representative, Quincy
57 Holyoke Street
Quincy, MA 02171
Rep. Thomas F. Brownell
State Rep.
15 Moreland Road
Quincy, MA 02171
Roy Johnson
137 Sea Ave.
Quincy, MA 02169
Paul Harold
State Senate
31 Riverside Avenue
Quincy, MA 02169
Kathy Lane
Winthrop Concerned
Citizens Committee
260 Main Street
Winthrop, MA 02152
Mayor Francis X. McCauley
City of Quincy
1305 Hancock Street
Quincy, MA 02169
Martin H. Gordon
Citizen
315 Rock Island Road
Quincy, MA 02169
1-13
-------
Richard J. Koch Jr.
Quincy City Council
Hancock Street
Quincy, MA 02169
Martin Pillsbury
MAPC
110 Tremont Street
Boston, MA 02108
Joseph A. MacRitchie
Chairman, Mayor's Water
Pollution Task Force
City of Quincy
1305 Hancock Street
Quincy, MA 02169
Mike Cheney
Quincy City
Councillor, Ward I
Diane G. Lysy
Winthrop Concerned Citizens
226 Cottage Park Road
Winthrop, MA 02152
Robert F. Daylor
President, Quincy
Shores Association
33 Sea Avenue
Quincy, MA 02169
Leo J. Kelly
City of Quincy
lT3~Spring Street
Quincy, MA 01269
Donald McCarthy Sr.
11 Thomas Street
Quincy, MA 02169
Patricia M. Toland
Quincy City Councillor-
at-Large-
82 Cedar Street
Quincy, MA 02170
Thomas P. Koch
241 Newbury Avenue
Quincy, MA 02171
Merwin E. Durgin
Indiv. Home owner
288 Rock Island Road
Quincy, MA 02169
Mary Ann Lencki
10 Homer Road
Quincy, MA 02169
Ann Brewster-Weeks
Appalachian Mt. Club
13 Holly Avenue
Cambridge, MA 02138
Joanne Condon
City Councillor
City of Quincy, Ward 6
City Hall
Quincy, MA 02169
Edward M. Suwaizdis
198 Rock Island Road
Quincy, MA 02169
Louis Mazzini
Merrymount Assoc.
Quincy, MA 02169
Senator William Golden
State House
Boston, MA 02203
Paul A. Caruccio
76 Ingleside Avenue
Winthrop, MA 02152
Lillian Austin
605 Sea Street
Quincy, MA 02169
Mike Cotter
807 Sea Street
Quincy, MA 02169
Michael P. Manning
SWIM/Nahant Engineering
38 Spring Road
Nahant, MA 01908
Harold Goodman, MD
40 Crabtree Road
Quincy, MA 02169
Maureen Mazrimas
Save Our Shores
49 Bayberry Road
Quincy, MA 02171
1-14
-------
Paul Anderson
City of Quincy DPW
55 Sea Street
Quincy, MA 02169
Lois A. Murphy
Nut Island CAC
135 Sea Avenue
Quincy, MA 02169
Arthur T. Cummings
Concerned Citizens Comm.
51 Emerson Road
Winthrop, MA 02152
Rona W. Goodman
Squantum Community Association
40 Crabtree Road
Quincy, MA 02171
Jens E. Thornton
Save Our Shores, Inc.
14 Orchard Street
Quincy, MA 02171
Robert Michaelson
316 Grove Street
Randolph, MA 02368
Kevin B. Davis
226 Rock Island Road
Quincy, MA 02169
Winthrop Hearing - 2/28/85
Robert A. Deleo
Chairman
Winthrop Board of Selectmen
Edward J. Markey
Congressman
U.S. House of Representatives
Michael Lopresti, Jr.
Senator
MA State Senate
Alfred E. Saggese, Jr.
Representative
MA General Court
Robert E. Noonan
Selectman
Winthrop Board of Selectmen
Ronald V. Vecchia
Selectman
Winthrop Board of Selectmen
Represented by,
Marie Turner
Secretary
Winthrop Board of Selectmen
Harlan Doliner,
Legal Consultant
Winthrop Board of Selectmen
S. David Graber
Consulting Engineer
Winthrop Board of Selectmen
Anne Porter
Co-Chairperson
Winthrop CCC
James H. Marr
President
Winthrop Chamber of
Commerce
Jerome E. Falbo
Member
Winthrop Planning Board
Barbara Gloss
Winthrop CCC
256 Riber Road
Winthrop, MA 02152
Terry Vasquez
Steering Committee
Winthrop CCC
Diane Musi
Student
Winthrop High School
Robert Driscoll
Member
Winthrop Planning Board
Marie Wynne
Winthrop CCC
209 River Road
Winthrop, MA 02152
1-15
-------
Joseph V. Ferrino, Jr.
Steering Committee
Winthrop CCC
Paul Comerford
President
Winthrop Rotary
Paul F. Dawson
Chairman
Winthrop Board of Health
Kathy Lane
Winthrop CCC
260 Main Street
Winthrop, MA 02152
Arthur Cummings
Winthrop CCC
Member Steering Committee
Michael Defelice
Student
Winthrop Middle School
Ruth Niblet
Student--
Winthrop Middle School
Thomas E. Reilly, Sr.
Member
Selectmen's Rep. Citizens Comm.
Benjamin Moore
960 Shirley Street
Winthrop, MA 02152
Thomas McNiff
Member
Winthrop CCC
Thomas Memmolo
Chairman
Winthrop Lodge of Elks
Government Relations Comm.
Charles Flanagan
Chief
Winthrop Fire Dept.
David C. Rice
Chief
Winthrop Police Dept.
Mary Mahoney
Member
Winthrop CCC
James Matarazzo
President
Winthrop Band Association
Joseph A. Langone III
Represented by
Joseph Franzese
Member
Governor's Council
Laura Stasio
45 Tafts Avenue
Winthrop, MA 02152
Dr. John H. Crandon
Member
Winthrop CCC
Beverly Colson (represented)
President
Winthrop Emblem Club
Richard Larson
Member
Selectmen's Representative
Citizens Committee
Lee Fitch
Winthrop, MA 02152
Elvira Pixie Palladino
Land Use Council
759 Bennington Street
East Boston, MA
Richard D. Dimes
Member
Winthrop CCC
Frank Constantino
Chairman
Winthrop Beautification Commitee
John Rogers
Member
Winthrop CCC
Laura Pe lie tier
President
Winthrop High School
Parents Club
1-16
-------
John McGovern for
himself and Mary Kelley
Member
Winthrop Conservation Commission
Lois Baxter
Chairman
Winthrop Conservation Commission
Emile Demento
Member
Winthrop CCC
Anna Defonzo
Chairman
East Boston Land Use Council
Frederick Gillis
Chairman
Winthrop Advisory Board
Ralph Tufo
62 Crystal Cove Avenue
Winthrop, MA 02152
Polly Bradley
SWIM (Nahant Citizens Committee to
Seek
Water Improvement Measures)
33 Summer Street
Nahant, MA 01908
Kevin B. Davis
226 Rock Island Road
Quincy, MA 02169
Dorothy Sannco
35 Pearl Avenue
Winthrop, MA 02152
Quincy Hearing - 3/7/85
Brian Donnelly
Congressman
Michael Morrissey
State Rep
Holyoke Street
Quincy, MA 02171
Senator William Golden
Gertrude Peter
7 Allerton Street
Quincy, MA 02169
Senator Paul D. Harold
State Senator
31 Riverside Avenue
Quincy, MA 02169
Robert Waterman
Legislative Aide to
Rep Robert A. Cerasoli
54 Russell Park
Quincy, MA 02169
Peter L. Eeley
Gov. Council
State House
Boston, MA
John J. Walsh
Concerned Citizen
36 Surfside Lane
No. Quincy, MA
Mayor Francis X. McCauley
City of Quincy
210 Manet Avenue
Quincy, MA 02169
Rep. Thomas Brownell
State House, Rm. 138
Boston, MA 02133
Lorraine M. Downey
Representing
Mayor Raymond L. Flynn
Clifford N. Pamplin
11 Riverside Avenue
Quincy, MA 02169
Jim Sheets
President, Quincy City Council
926 Furnace Brook Pkwy
Quincy, MA 02169
Ted DeCristofaro
Quincy City Council
1-17
-------
Michael T. Cheney
Quincy City Council
94 Rock Island Road
Quincy, MA 02169
Albert L. O'Neil
Boston City Councillor
City Hall
Boston, MA 02201
Richard Koch Jr.
City Councillor
Quincy, MA 02169
V. G. Whyte
60 Otica Street
Quincy, MA 02169
Leo J. Kelly
City of Quincy
143 Spring Street
Quincy, MA 02169
Andrew J. Ayer
Shellfish Constable
108 Taylor Street
Quincy, MA 02170
Andrea Sault
136 Sea Avenue
Quincy, MA 02169
Ron Goodman
Quincy Shores Association
Robert F. Baylor, President
Quincy Shores Assoc.
33 Sea Avenue
Quincy, MA 02169
Lois Murphy
Quincy Shores Assoc.
Jack Walsh
Quincy Shores Assoc.
Kevin Davis
Quincy Shores Assoc.
Joanne Condon
City Councillor, Ward 6
City Hall
Quincy, MA 02171
Stephen McGrath
Quincy City Council
City Hall
Quincy, MA 02169
Paul Anderson
City of Quincy DPW
55 Sea Street
Quincy, MA 02169
Joseph J. LaRaia
City Councillor at Large
54 Grogan Avenue
Quincy, MA 02169
Patricia M. Toland
Quincy City Council
82 Cedar Street
Quincy, MA 02170
Peter F. O'Connell, President
South Shore Chamber of Commerce
36 Miller Stile Road
Quincy, MA 02169
Sally Wainwright
Squantum Community Assoc.
179 Lansdowne Street
Squantum, MA 02171
Barbara McConville
29 Chickatabot Road
Quincy, MA 02169
Joseph A. MacRitchie
Assistant City Solicitor
Mayor's Water Pollution Task Force
1305 Hancock Street
Quincy, MA 02169
James B. Freel
Nut Island CAC
21 Bell Street
Quincy, MA 02169
Ann-Marie Noyes
Germantown Neighborhood Council
100 Bicknell Street
Quincy, MA 02169
John Lydon
Quincy City Councillor
40 Adams Circle
Quincy, MA 02169
1-18
-------
Bob Michelson
316 Grove Street
Randolph, MA 02768
Terry N. Fancher
South Shore Chamber of Commerce
36 Miller Stile Road
Quincy, MA 02169
William Grabowski
164 Crabtree Road
Quincy, MA 02171
Arthur M. Chandler
Quincy Citizens Assoc.
320 Belmont Street
Wollaston, MA 02170
Martha Chase
143 Sea Avenue
Quincy, MA 02169
Clara Yeomans
League of Women Voters of Quincy
115 Winthrop Avenue
Quincy, MA 02170
Rev. Frederick L. Barr Jr.
Priest of the Archdiocese of Boston
Our Lady of Good Counsel
Roman Catholic Church
227 Sea Street
Quincy, MA 02169
Carol Hallett
125 Sea Avenue
Quincy, MA
Grace Saphir
Save Our Shores Assoc.
Box 208
East Sandwich, MA 02537
Robert L. Johnston
46 Bayview Avenue
Quincy, MA 02169
Thomas Nutley
Atlantic Neighbrohood Assoc.
235 Billings Street
Quincy, MA 02171
Bernice C. Mader
108 Connell Street
Quincy, MA 02169
Rona W. Goodman
Squantum Community Assoc,
40 Crabtree Road
Squantum, MA
Lawrence Haletky
9 Homestead Street
Quincy, MA 02169
Gail Freel
Hough's Neck CAC
21 Bell Street
Quincy, MA 02169
Mary Gougian
Squantum Community
13 Hillcrest Road
Squantum, MA 02171
Assoc
Patricia Ridlen
Director, Houghs Neck
Community Center
1193 Sea Street
Quincy, MA 02169
Maureen Mazrimas
Save our Shores,
Squantum Community Assoc.
49 Bayberry Road
Quincy, MA 02171
Lawrence Kerzner
57 Wedgewood Street
Quincy, MA 02171
Louis Mazzini
President, Merrymount Assoc,
Quincy, MA 02169
Ron lacobucci
59 Andrews Road
Quincy, MA 02170
Stephen E. Magee (student)
Quincy High School
22 Chorks Street
Quincy, MA 02169
1-19
-------
Daniel Bythrow
President, Hough's Neck
Community Council
945 Sea Street
Quincy, MA 02169
Silas W. Porter
Janitor
173 Huckins Avenue
Quincy, MA 02171
Judith Colson for
Ellen Hafer
Manet Community Health Center
1193 Sea Street
Quincy, MA 02130
Ann Lencki
10 Homer Road
Quincy, MA 02169
Jens E. Thornton
Save Our Shores, Inc.
14 Orchard Street
Quincy, MA 02171
Joseph M. Clasby
Squantum Yacht Club
Quincy Shore Drive
Quincy, MA 02169
1-20
-------
FEDERAL COMMENTS
2-1
-------
KOWARO J. MARKCY
0 IMVUT1OATIONS
Congre** o( tfje ®niteb £>tate*
$oo*t of Btprttftntatitit*
20913
to
I
to
February 28,198S
Mr. Michael Deland
Director, Region I
Environmental Protection Agency
JFK Federal Building
Boston, MA
Dear Mike:
Thank you for the opportunity to address your group in Winthrop. In addition, to my
personal statement, I ask you to consider the attached comments on the Report.
Thank you for your consideration of these comments.
With best wishes,
Sincerely,
EJM/gjw
Edward J. Markey
Member of Congress
STATEMENT OF CONGRESSMAN EDWARD J. MARKEY
Public Hearing on Siting of Wastewoter Treatment
Facilities for boston Harbor
February 28, 1985
I APPRECIATE THIS OPPORTUNITY TO COMMENT ON THE SUPPLEMENTAL bilAFT
ENVIRONMENTAL IMPACT STATEMENT/REPORT ON SITING OF iv A5TEWATER
TREATMENT FACILITIES FOR BOSTON HARBOR. 1 FOUND THE REPORT
THOROUGH, ENCOMPASSING AND WELL STATED. IN GENERAL, I AM IMPRESSED
BY THE AMOUNT OF WORK PUT INTO TilIS EFFORT, AND I HOPE THAT THE
DECISION-MAKING PROCESS REFLECTS THIS EFFORT.
THE ISSUE OF BOSTON HARBOR'S WATER QUALITY HAS BEEN OF .MUCii CONCERN
TO ME FOR MANY YEARS. NO ONE CAN DENY THE DETERIORATING STATE OF
BOSTON HARBOR WATER. THAT CONTINUED OPERATION OF TREATMENT
FACILITIES ON NUT AND DEER ISLAND UNDER CURRENT CONDITION'S
REPRESENTS A CLEAR AND PRESENT DANGER TO THE 1IEALT1: AND OUALITY OF
THE HARBOR IS ABUNDANTLY CLEAR. NUT AND DEEIl ISLAND TOGETHER
DISCHARGE ABOUT 75 TONS OF DIGESTED SLUDGE SOLIDS AND 130 TONS OF
EFFLUENT SOLIDS DAILY INTO THE HARBOR. OVER FIFTY LOCATIONS
DISCHARGE HAW SEWAGE DURING \\ ET WEATHER, DUE TO THE STOK.'UYATEI!
PROBLEM WHICH OVERLOADS I'hE SYSTEM AND FORCES THE ..IOC TO VAINLY
HOLD ITS FINGERS IN THE DIKE WHILE THE WATER SPILLS OVER TllE TOP.
THE EFFECT OF THIS RAMPANT POLLUTION HAS BEEN FELT BY TIICSE V. ANTING
TO S'.vlM AND FIND BEACHES POSTED; IT HAS BEEN FELT BY THOSE USING TliE
2000 SHELLFISH BEDS IN BOSTON HARBOR THAT HAVE BEEN CLOSED OR
RESTRICTED DUE TO HIGH LEVELS OF POLLUTION IN THE WATER; AND IT HAS
BEEN FELT BY THE ENTIRE BOSTON COMMUNITY iVHO KNOW THAT Till; ilARFiOK
IS MUCH LESS THAN IT COULD BE DUE TO OOP. WILLFUL USE OF ITS I. ATL.'tS AS A
CESSPOOL.
IN MY ESTIMATION, BOSTON HARBOR REPRESENTS THE C&MT.iON COMMUNITY uF
GREATER BOSTON AND PLAYS A LARGE ROLE IN THE DAILY LIFE OF OUli
CITIZENS. TliE ONE HUNDRED AND EIGHTY MILES OF SHORELAND Til AT ITS
IVATERS WASH ENCOMPASSES MUCH OF GREATER BOSTON, AND ITS
I:ECREATIONAL FACILITIES COULD BE ENJOYED EASILY BY MOST OF THE THRKL
VILLION PEOPLE •VHO LIVE WITHIN TWENTY-FIVE MILES OF ITS SHORES.
CONSEQUENTLY, I BELIEVE THAT WE HAVE A PROFOUND OBLIGATION TO OLF.AN
UP THE 11ARUOR IN A TIMELY MANNER SO THAT THE TRUE POTENTIAL OF THE
HARBOR CAN BE REALISED BY OUR CITIZENS.
HOWEVER, AS THIS REPORT CLEARLY ILLUSTRATES, THE CLEANING UP OF
dOSTGN HARBOR i.ILL REQUIRE SACRIFICES FROM SOME CO".'iUNI 1'H-S AM)
WILL AFFECT THE FUTURE OF THESE TOWNS AMD CITIES. THE SllbEK VOLUME
OF SEWAGE, INDUSTRIAL WASTES AND URBAN RUNOFF DISCHARGED ANNUALLY
— 5.7 BILLION GALLONS — MAKES IT PLAIN THAT WE HAVE BEFORE US A
HERCULEAN' TAS;i. CLEANING UP BOSTON HARBOR WILL ill! NO EASIEK Tl.A.N
CLEANING UP THE AUGEAN STABLES. BUT IF \VE WORK TOillCTIICi: - THE
ENVIRONMENTAL PROTECTION AGENCY, THE COJiMONWEALTH, TIIL CITY OF
JOSTON, AND THE PEOPLE OF THESE COMMUNITIES - THEN I A.M CONFIDENT
Ti-.AT WE CAN RISE TCI THIS TASK
-------
-2-
-3-
N>
CO
AND RESTORE THE HARUOK TO A CLEAN, ATTRACTIVE AND INTEGRAL PAKT OF
OUU GREAT CITY.
FOU DECADES, THE PEOPLE OF WINTI1ROP HAVE PUT UP WITH ONE
ENVIRONMENTAL INSULT AFTER ANOTHER. LOGAN AIRPOUT HANDLES NEARLY
1000 FLIGHTS A DAY, AND ALMOST ONE FLIGHT EVERY SIX .\ilNUTES FLIES JUST
500 FEET ADOVE THE TOWN. THE DEER ISLAND HOUSE OF CORRECTIONS HAS
OVER 4000 VISITORS A YEAR AND SUFFERED TWENTY ESCAPES LAST YEAH. AND
A SEWAGE TREATMENT FACILITY HAS BEEN IN OPERATION ON DEER ISLAND FOR
TWENTY YEARS, CAUSING NOXIOUS AIR PROBLEMS AND HAVING A DETRIMENTAL
EFFECT ON LOCAL LAND VALUES.
THE NET EFFECT OF THESE DEER ISLAND FACILITIES ON \\INTI1KUP iiAS Ut£K
TRAFFIC CONGESTION, AIR POLLUTION, HOUSE-TO-HOUSE SEARCHES AND
LOIVER LAND VALUES. CLEARLY, THESE FACILITIES HAVE EXTRACTED A HIGH
PRICE FROM THIS COMMUNITY.
NOW, ANOTHER ENVIRONMENTAL INSULT IS UE1NG PROPOSED FOR DEER
ISLAND. I FIND THIS DEVELOPMENT MOST DISTURBING. ALREADY, DEEU ISLAND
SERVES AS A PRISON FOR BOSTON, A SEWAGE TREATMENT CENTER FOR UO3I ~N,
AND A LANDING STRIP FOR BOSTON. IS THAT NOT ENOUGH?
THE PROBLEM OF BOSTON HARBOR IS SERIOUS AND IT DEMANDS A WORKABLE
SOLUTION. I WANT TO WORK WITH YOU TOWARD THAT SOLUTION. MOW I WOULu
LIKE TO COMMENT ON VARIOUS ELEMENTS OF THE KEPORT, ANLt I HOPE THAT
YOU CONSIDER THESE COMMENTS IN MAKING YOUR DECISION ON THE SITING OF
FUTURE WASTEWATER TREATMENT FACILITIES.
PRIMARY TREATMENT OPTIONS
THE REPORT STATES THAT THERE ARE NOiV SEVEN OPTIONS FOu
CONSIDERATION, THREE FOX PRI.MARY TREATMENT AND FOL'K FoK SLCONDAllY
TREATMENT. IF THE WAIVER FOU SECONDARY TREATMENT KEOUtSTED DY THE
,MDC IS GRANTED, THEN A DECISION' '..ILL HAVE TO BE MADE ON TiiE SITING OF A
PRIMARY TREATMENT FACILITY. IN MAKING THAT DECISION, 1 .VOULD LIKE YOU
TO CONSIDER TI;E FOLLOWING COMMENTS.
PRIMARY TREATMENT ALTERNATIVES;
1. ALL PKIMARY DEER ISLAND. TlilS OPTION IS TOTALLY UNACCEPTABLE. THE
PEOPLE OF WINTIIKOP CANNOT TAKE CONSTRUCTION OF A C2-ACRE PRIMAKY
TREATMENT FACILITY, AND SHOULD NOT DE ASKED TU TAKE THIS INSULT ON
TOP OF ALL THE OTHER ENVIRONMENTAL INSULTS THEY HAVE SUFFERED IN THE
PAST.
2. SPLIT PRIMARY DEER ISLAND AND NUT ISLAND, i
3. SPLIT PRIMARY DEER ISLAND AND LONG ISLAND. IN MY ESTIMATION, THESE
OPTIONS ARE VERY SIMILAR SINCE THEIR EFFECT ON DEER ISLAND AND
WINTHROP WOULD BE TIIE SAME. THESE PLANS WOULD BOTH ENTAIL
CONSTRUCTION ON DEER ISLAND OF A FACILITY TWICE THE SIZE OF THE
CURRENT PLANT. THEREFORE, I FIND BOTH OF TilESE OPTIONS AS ONLY
EQUALLY UNACCEPTABLE. CONSEQUENTLY. I BELIEVE THAT TIIE ALL PKIIWAKY
LONG ISLAND OPTION SHOULD BE CONSIDERED.
THE REPORT STATES AT PAGE 2-6, VOL. 1.TI1AT "DURING Till: PREPARATION Or
THIS SDE1S. ANALYSIS OF THE DATA REVEALED THAT ONE OF THE FOUR
PRIMARY TREATMENT ALTERNATIVES — ALL PRIMAitY LONG ISLAND —
SUFFERED FROM CO.VIPELLING DISADVANTAGES WHEN COMPARED WITH OTilEK
PRIMARY TREATMENT ALTERNATIVES. THEREFORE, THE ALL PRIAMIiY LONG
ISLAND ALTERNATIVE IS NO LONGER UNDER ACTIVE CONSIDERATION." YOU
FURTHER STATE THAT "TIIE PUBLIC MAY STILL f ISII TO COMMENT llM TliE ALL
PRIMARY LONG ISLAND ALTERNATIVE."
I WOULD LIKE TO STATE IN THE STRONGEST TERA1S MY OBJECTION TO THE
REMOVAL OF THE ALL PRIMARY LONG ISLAND ALTERNATIVE. MY PKINClPLi:
OBJECTION TO THIS DELETION IS THE INCONSISTENCY PATENTLY EVIDENT IN
THE REPORT. THE SECONDARY SITING OPTIONS INCLUDE ALL SECONDARY
LONG ISLAND AS A VIABLE OPTION, AND I FIND THAT NOTEWORTHY. WHAT
DISTURBS ME IS THAT LONG ISLAND WAS DELETED AS A PRIMARY OPTION AFTER
THE OPTIONS WERE COMPILED. THAT ALL LONG ISLAND SECONDARY STOOD UP
TO SCRUTINY TO MAKE THE FINAL CUT, AND WAS THEN DELETED MAKES ME
QUESTION SERIOUSLY THE INTEGRITY OF TIIE PROCESS. IT APPEARS TO »:E
THAT ALL THE SOUND REASONS WHY LONG ISLAND QUALIFIES AS A SECONDARY
TREATMENT OPTION APPLY TO PRIMARY TREATMENT CONSIDERATIONS.
ACCORDINGLY, I STRONGLY URGE YOU TO RECONSIDER THIS DECISION AND TO
SERIOUSLY EXAMINE LONG ISLAND AS A PRIMARY TREATMENT OPTION.
FURTHERMORE, I FIND TIIE REASONS STATED IN THE REPORT UNPERSUASIVE.
NOW LET ME ADDRESS SOmE OF THE RESONS YOU CITED FOR THE DELETION OF
LONG ISLAND AS AN OPTION.
f I. "THE ACREAGE NEEDED FO-t A CONSOLIDATED PRKiiAKY Ti:EAT;.,E.Vr
PLANT IS AVAILABLE AT DEER ISLAND .VITII MUCH LESS CONFLICT THAN WITii
OTHER EXISTING OH PLANNED I'UBLJC USES OR RESOURCES, MOKE
OPPORTUNITIES FOR SIGNIFICANT ..iITIGATION, AND FEWER SKRIOUS LEGAL AND
INSTITUTIONAL OBSTACLES. TliE SITING OF A 52-ACRE PiUMAHY TULAT.nL.iT
PLANT CAN BE ACCOMPLISHED WITHOUT SIGNIFICANT ADVEHSE I..IPACT I'M
.VINTHROP, PROVIDED THAT MAJOR MITIGATION MEASURES UEQUIKED JY El'A
AII£ EMPLOYED."
THIS ARGUMENT KESEMULES A CASE FOR "Ei»VIKO.\?.iENTAL ZONING", A3
IF WINTHKOP IS ALREADY CLASSIFIED A3 "OKAY TO TREAT SEWAGE THERE" AND
LG.\G ISLAND IS LABELLED "PRISTINE," AND TnIS SITUATION SHOULD NOT Ui:
CHANGED. I CANNOT ACCEPT Tills Pl'.E'.ilSE. NINTH HOP SHOULD NCrULYIiL
SEWAGE CENTER OF BOSTON, AND JUST BECAUSE IT -1-
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-4-
-5-
to
I
HAS SOME FACILITIES NOW, THAT DOES NOT MAKE IT AUTOMATICALLY EL1G1ULE
FOR FUTURE WASTE SITES. V\'C CANNOT CONTINUE TO INSULT THE
ENVIRONMENT OF WINTHROP. WE MUST SHARE THE BURDEN'.
»3. A LARGE PRIMARY TREATMENT PLANT ON LONG ISLAND WOULD UAVE
ADVERSE IMPACT ON THE STATE PARK NO.V PLANNED BY ..lASSACill'SETTS DE. I
FOR THAT ISLAND.
WE SHOULD NOT BE ARGUING AUOUT FUTURE PLANS FOK PARKS, WE AKE
TALKING ABOUT THE DIRECT, IMMEDIATE, AND EVERY-DAY I?.!PACT ON THE
PEOPLE OF WINTHROP. WHILE I DO NOT INTEND TO COMMENT AGAINST THE
HARBOU PARK SYSTEM, I FEEL COMPELLED TO FRAME THIS ISSUE IN THE
FAIREST LIGHT TO THOSE PEOPLE WHO HAVE TO LIVE WITil THE PROBLEM. TI:E
PARK SYSTEM SHOULD BE PROMOTED, I1UT I FEAR THAT TilE PARK SYSTEM IS
BEING USED AS SHORT-HAND FOR THE ELIMINATION OF LONG ISLAND AS A
VIABLE OPTION. AS I STATE LATER IN THIS COMMENT, THE PARK SYSTEM
SHOULD BE CONSIDERED IN A PROPER PERSPECTIVE.
»5. A LARGE PRIMARY TREATMENT FACILITY ON LONG ISLAND WOULD
IMPACT THE SENSITIVE POPULATION OF THE ADJACENT CHRONIC DISEASE
HOSPITAL.
I FIND THIS POINT INCONSISTENT WITH SU3SEc}UENT STATEMENTS IN Tilt
REPORT WHICH SUGGEST THAT THE HOSPITAL COULD BE MOVED WITHOUT
CAUSING SERIOUS PROBLEMS. IN ADDITION, THE CUKRENT FACILITY ON DEUR
ISLAND HAS A SUBSTANTIAL NEGATIVE EFFECT ON THE RESIDENTS OF DEER
ISLAND AND THE RESIDENTS OF WINTHROP.
»6. THE LOCATION OF THE HOSPITAL NEAR THE TREATMENT PLANT SITE
WOULD IMPOSE ADDITIONAL CONSTRAINTS ON CONSTRUCTION.
EACH SITE HAS ITS LIMITS AND ITS DRAWBACKS. HOWEVER, IF THE
HOSPITAL IS GOING TO BE MOVED (SEE COMMENTS ABOVE) THEN THIS POINT KG
LONGER STANDS.
*7. A LARGE PRIMARY TREATMENT PLANT ON LONG ISLAND WOULD 1SE
$56 MILLION TO $120 MILLION MORE EXPENSIVE TO CONSTRUCT THAN Tilt
OTliEK THREE PRIMARY OL'TIONS BlilKG CONSIDERED.
AS I HAVE SAID BEFORE, THE SITING DECISION MUST UE UA3ED ON Til REE
FACTORS: 1) WHAT IS BEST FOR THE ENVIRONMENT AND TliE HAP.BGIl ; 2)
iVHAT IS BEST FOR THE COMMUNITIES CONCERNED AND HOW CAM WE MINIMIZE
TI.E IMPACT ON THESE COMMUNITIES ; AND 3) THE COST OF TliE PROJECT.
NONE OF THESE FACTORS ALONE SHOULD BE DETERMINATIVE; WE MUST
EXAMINE ALL THE ASPECTS OF A SITING DECISION BEFORE ..iGVING FOR'.VACD.
I REALIZE THAT THE LONG ISLAND OPTION WOULD TAKE A GKEAT DEAL OF
'.YORK IN ORDER TO REMOVE SOME OF THE REGULATORY OBSTACLES. HUT I A'..
COMMITTED TO WORKING WITH TilE ENVIRONMENTAL PROTECTION AGENCY, -j-
SECONDARY TREATMENT OPTIONS
IF THE MDC WAIVER APPLICATION IS DENIED, THEN A DECISION WILL HAVE TO BE
MADE ON THE SITING OF A SECONDARY TREATMENT FACILITY. I HAVi£ TliE
FOLLOWING COMMENTS ABOUT THE VARIOUS OPTIONS PRESENTED IN THE
REPORT.
FOUR SECONDARY TREATMENT ALTERNATIVES;
1. ALL SECONDARY DEER ISLAND. OBVIOUSLY, I FIND THIS OPTION THE MOST
UNPALATABLE. TO PLACE A lli-ACRE PRIMARY AND SECONDARY TREATMENT
FACILITY ON DEER ISLAND WOULD BE GROSSLY UNFAIR ANU AN INSULT TO Tilt
PEOPLE OF WINTHROP. THE CONSTRUCTION ItEQUIRED TO BUILD SUCH A SITE
WOULD PLACE A TREMENDOUS BURDEN ON THE TOWN OF iVINTHKOP AND
WOULD DISRUPT SIGNIFICANTLY THE DAILY LIFE OF WINTHROP.
2. SPLIT SECONDARY DEER AND NUT ISLAND. THIS OPTION, WHICH V.OULD
CONVERT THE DEEIl ISLAND TREATMENT PLANT TO A 115-ACRE CONSOLIDATED
SECONDARY TREATMENT PLANT WOULD 3E ALMOST AS DAMAGING. .VKILL THIS
PROPOSAL ENTAILS A LARGER PRIMARY TREATMENT PLANT ON NUT ISLAND, I
STILL SEE THIS OPTION AS AN INSULT TO THE PEOPLE OF WINT1IROP, AND FIND
THE ABOVE COMMENTS PERTAINING TO CONSTRUCTION EQUALLY APPLICABLE.
3. ALL SECONDARY LONG ISLAND. THIS OPTION IS CLEARLY ..iY CilCICE SINCE
IT INCLUDES A NEW CONSOLIDATED PRIMARY AND SECONDARY TREATMENT
PLANT OF AbOUT Siti ACRES ON LONG ISLAND. THIS OPTION WOULD. STILL LEAVE
A PUMP STATION ON DEER ISLAND, AND THEREFORE WOULD NOT TAICE DEER
ISLAND OUT OF THE PICTURE. THIS OPTION IS CLEARLY FAVORABLE SINCE IT
CAUSES THE LEAST IMMEDIATE AND DIRECT IMPACT ON THE HARUOK
COMMUNITIES.
4. SPLIT SECONDARY DEER ISLAND AND LONG ISLAND. TliIS OPTION, WiilLL
PR£FERABL£ TO ALL SECONDARY DEER ISLAND. STILL ivOULD AltAfJ AN
EXPANSION OF THE EXISTING 2U-ACRE DEER ISLAND PLANT TO A 52-ACRE
EXPANDED PRIMARY TREATMENT PLANT. .MY ORIGINAL GOAL IN THIS PROCESS
REMAINS: STOP MOiiE SEWER CONSTRUCTION ON DEL'K ISLAND. NO.VETliELi.Sb,
I THINK THAT THE PROPOSAL TO BUILD AN 82-ACRE PRIMARY TREATMENT
PLA.JT ON LONG ISLAND DE.VONSTKATES A COMMITMENT To SHARING TliE
SEWER UURDEN, AND THEREFORE IS A STEP IN THE RIGHT DIRKCTION.
TiiL CGMAiONWEALTH AND THE CITY OF UOSTON TO MEET TliiJSE CiiALL£NGES:
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-6-
SLUDGE MANAGEMENT
-7-
ro
AFTER DISCUSSING THE SEVEN OPTIONS, THE REPORT DISCUSSES THE ROLE THAT
SLUUGE MANAGEMENT PLAYS ON THE SITING DECISION. TiiE REPORT STATES
THAT SLUDGE MANAGEMENT DECISIONS AKE NOT RIPE FOii DECISION AMD TilAT
SLUDGE MANAGEMENT SHOULD NOT AFFECT THE SITING OPTION. I TAKE
STHONG EXCEPTION TO THIS POSITION AND URGE YOU TO RECONSIDER Tills
STANCE.
I BELIEVE THAT TIIE SLUDGE ISSUE HAS TO BE ADDRESSED IN CONJUNCTION
WITH TIIE SITING ISSUE. IT IS CLEAR THAT IF TIIE MDC WAIVER IS DENIED, THEN
WE WILL HAVE TO HANDLE ABOUT 300 DRY TONS OF SLUDGE PEK DAY. TIlE
FOUR OPTIONS CURRENTLY BEING STUDIED (PROCESSING SLUDGE INTO
COMPOST, UURIAL AT SEA, INCINERATION, ANb LANDFILLS) HAVE VARYING
DEGREES OF MERIT BUT ALL WOULD REQUIRE SIGNIFICANT AMOUNTS OF LAND.
I HAVE SERIOUS CONCERNS THAT THE SLUDGE SITE DECISION ivILL Bii 1'UT OFF
AND THEN ALL TIIE PARTIES CANNOT BARGAIN WITH FULL KNOW LEDGE. IN MY
OPINION, IT IS IMPORTANT THAT ALL PARTIES AGREE ON THE FUTUi'.E OF
SEWAGE TREATMENT IN BOSTON, NOT JUST ON PHASE I AND II OF A THREE-PART
PROGRAM.
THE REPORT STATES THAT THE SLUDGE DECISION WOULD NOT AFFECT THE
SITING DECISION SINCE THE OPTION OF OFF-SITE TREATMENT EXISTS. IF THERL
IS A SINCERE COMMITMENT TO OFF-SITE SLUUGE TREATMENT, THEN I .VOULD
WELCOME AN EXPLICIT AGREEMENT ON TIIE OFF-SITE LOCATION OF SLUDGE
TREATMENT FACILITIES.
SELECTION DECISION PROCESS
THE REPORT IDENTIFIES THREE STEPS IN THE SELECTION DECISION
PROCESS. THEY AKE:
1). ADEQUACY OF THE DECISION CRITERIA.
2). HOW EACH OPTION SHOULD BE RATED AGAINST THE DECISION CRITERIA.
3). HOW EACH DECISION CRITERIA SHOULD iiE .VEIGIiTED.
DUE TO THE COMPLEX NATURE OF EACH STEP, I WILL ADDRESS EACH OF THESE
POINTS SEPEitATELY AND THEN IN THE AGGREGATE AS HART CF TI.E DECISION
PROCESS.
ADEQUACY OF THE DEC'ISION CRITERIA.
SIX DECISION CUITEltIA ilAVL BEEN IDENTIFIED. TliE IIEPOIIT INVITES CO..." iL.NT
ON THE ADEQUACY OF EACil CRITERIA AND iiOiv EAC:i SilOULii HE •.VEIGIITEI).
A). iiAiiiioii I..;II.\::CL..:KNT. »THL I/SJECTIVI:, Ti:Eiii:FuHE, is. TO SELECT
FINAL SITING OPTIONS THAT AF.E CONSISTENT V.ITIi AM), IF PGSSIIILi:, PMJ'.,UTi:
THE FULFILLMENT OF TIIE PROP.ilSE OF HOSTON HAKUOR." THIS CI'.ITEHIA SEEKS
TO HARMONIZE THE SITING OF A TREATMENT FACILITY WITil TIIE FUTURE
PLANS FOR BOSTON HARBOR, INCLUDING RECREATION, FISHING, AND
ECONOMIC DEVELOPMENT. TllE REPORT FURTHER STATES TilAT "CENTRAL TO
THEM ALL, HOWEVER, IS AN EFFORT TO AiAKE A CLcAN HARBOR A VITAL PART
OF TIIE EXPERIENCE AND DAILY LIFE OF TIIE COAi.VIUIJITY."
I AGREE FULLY TliAT A CLEAN HARBOR SHOULD UE OUR DRIVING CONCERN,
SINCE A HEALTHY HARBOR WILL SPUR RECREATION', ECONOMIC DEVELOPMENT
AND THE OTHER GOALS OUTLINED FOil TIIE HARBOR. NEVERTHELESS, I TAKE
EXCEPTION WITH THE COMBINED EFFECT OF TIIE COMMONWEALTH'S GOALS
STATED IN TIIE REPORT AND URGE YOU NOT TO ADOPT ALL OF THESE GOALS AS
YOUR OWN.
1 SHAKE YOUR CONVICTION THAT ECONOMIC DEVELOPMENT OF TliE INNER
HARBOR AND IMPROVEMENTS TO RECREATION FACILITIES I, ILL IMPROVE
SIGNIFICANTLY THE liOSTON ECONOMY AND OUU COMMUNITY. DEVELOP:,ENT
OF TIIE HARBOR ISLAND STATE PARK SYSTEM, A3 CURRENTLY ENVISIONED UY
THE COMMONWEALTH, HOWEVER, SHOULD NOT LIE ON TI:E SA:\iE PLANE V.ITII
THESE OTHER GOALS. A PARK SYSTEM IN BOSTON HARBOR IVILL ADD MUCH TO
TIIE COMMUNITY, BUT I DO NOT ACCEPT TIIE COMMONWEALTH'S ASSERTION
THAT LONG ISLAND IS AN INTRINSIC PART OF THAT PLAN. THEREFORE, TliE
GOAL OF DEVELOPING A BOSTON HARBOR PARK SYSTEM SHOULD CAP.KY t'.O
MORE WEIGHT THAN THE EFFECTS ON NEIGHBORS CRITERIA. AND PltOLABLl
SHOULD BE GIVEN LESS WEIGHT DUE TO THE ALTERNATIVES AVAILABLE TO TliE
DEVELOPERS OF TliE PARK SYSTEM. IN SHORT, TIIE GOAL OF DEVELOPING A
PARK SYSTEM SHOULD BE SECONDARY TO OTHER DECISION CRITERIA AND MUST
NOT BECOME SHORT-HAND FOR KEEPING LONG ISLAND PRISTINE AND KEEPING
DEER ISLAND A DUMPING GROUND FOR BOSTON'S PROBLEMS.
B). IMPLE.VENTABILITY. "THE OBJECTIVE IS TO SELECT FINAL SITING
OPTIONS THAT CAN BE IMPLEMENTED IN A TIMELY AND PREDICTABLE M Ail NET.."
THIS DECISION CRITERIA STANDS UP TO CLOSE SCRUTINY AND SHOULD ill:
ADOPTED AS IS. THE PROBLEMS PLAGUING BOSTON IIARBOH HAVE EXISTED FOi;
A LONG TIME AND THEREFORE, OUR GOAL SHOULD BE TO IMPLEMENT A SOUND
PLAN AS QUICKLY AS POSSIBLE CONSISTENT WITH T1!E OTHER fiuALS.
THEREFORE, I FIND 'TIMELY AND PREDICTABLE" TO BE APPROPRIATE SIGM'uSTS
IN OUR CJUESTTO DEVELOP A LONG-TERM SOLUTION FOR TIIE IIAIiBO!!.
C). EFFECTS ON JElfiliaORS. "TllE OBJECTIVE, TilEi.EFOKE, IS TO SELECT
FINAL SITING OPTION'S THAT MINIMIZE THE ADVERSE IMPACTS OK TilE FACILITIES
ON TilE NEIGHBORS, TAKING INTO CONSIDERATION EXISTING CG.NiJlTIONS,
FACILITY SITING IMPACTS AND AIITIGATION MEASURES."
TlilS DECISION CRITERIA I FIND MOST CG.MPELLING, AND I CGM.UJMJ YOU FCF.
RECOGNIZING T.IE NOXIOUS EFFECT OF EXISTING CONDITIONS ON
COMMUNITIES. 1 QUOTE APPROVINGLY THE REPORT'S DISCUSSION OF TI.IS
DECISION cr.lTERIA: "AN IMPORTANT FACTOR THAT MUST HE WEIGHED IN THE
EFFECTS ON NEIGHBORS DECISION CRITERIA IS THE AD\ EliSE uNVIi'.ON '..ENTAL
AMD SOCIAL IMPACTS TO WHICH NEIGHBORS AUE ALREADY SUlIJECT." THE
;;EIMI:T FU::TIIEK STATLS: "IMPACTS OF OTI.EH MAJOR FACILITIES — IN
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-3-
-9-
PART1CULAR, LOGAN AIKPORT AND T1IL DEER ISLAND HOUSE OF CORRECTION
- SHOULD ALSO BE WEIGHED. THE PRINCIPAL IMPACT FROM THE AIRPORT IS
iNOISEj THE IMPACTS OF TliE HOUSE OF CORRECTION1 INVOLVE TRAFFIC, VISUAL
DUALITY, AND SOCIAL/ PSYCHOLOGICAL DISRUPTION FRO.M ESCAPES OK THE
REASONABLE FEAR THEREOF." CLEARLY, EXISTING CONDITIONS EXTRACT A
HIGH PRICE FROM THE W1NTI1ROP COMMUNITY. I URGE YOU TO WEIGH HEAVILY
THESE CONSIDERATIONS AND IMPLORE YOU TO GIVE SERIOUS ATTENTION TO
OTHEK ALTERNATIVES BEFORE CONTEMPLATING THE ADDITION OF ANOTHER
FACILITY DETRIMENTAL TO THE PEOPLE OF KINTHUOP.
CRITERIA COULD WEIGH ENOUGH IN THE AGGREGATE TO DETERMINE THE
OUTCOME, BUT WOULD NOT TIP THE UALANCE STANDING ALONE.
FIRST CLASS;
EFFECTS ON NEIGHBORS
IIAHUOi; ENHANCEMENT
NJ
I
a\
D). EFFECTS ON NATURAL AND CULTURAL RESOURCES. "THE OUJECTIVE,
THEREFORE, IS TO SELECT FINAL SITING OPTIONS THAT .•.ilNIV.IZE THE IMPACTS
OF THE FACILITIES ON NATURAL AND CULTURAL RESOURCES."
I SUPPORT THIS CRITERIA TO THE EXTENT THAT IT SERVES TO PROTECT
CRITICAL NATURAL RESOURCES SUCH AS WETLANDS, FLOOD PLAINS AND
BARRIER BEACHES.
E). COSTS. "TliE OBJECTIVE, THEREFORE, IS TO SELECT FINAL SITING OPTIONS
THAT CAN BE BUILT AND OPERATED AT A MOST SEASONABLE COST."
I FIND THIS CRITERIA OVERLY RESTRICTIVE SINCE IT SUGGESTS THAT THE LEAST
EXPENSIVE OPTION, OR THE ONE VERY CLOSE TO THAT AIAHK, rt'OULU BE
PREFERABLE. I AM NOT SUGGESTING THAT COSTS SHOULD BE IGNORED, O?.
THAT THE MOST EXPENSIVE OPTION IS AUTOMATICALLY THE BEST. OUR OBJECT,
HOWEVER, SHOULD BE TO BUILD AND OPERATE TREATMENT PLANTS AT A
"REASONABLE COST," NOT THE "MOST REASONABLE COST." I FIND THIS CHANGE
SIGNIFICANT SINCE I UELJEVE THAT THE REQUIREMENT OF "MG3T REASONABLE"
WOULD TILT THE DECISION PROCESS TOWARD THE LEAST EXPENSIVE OPTION.
F). RELIABILITY. "THE OBJECTIVE, THEREFORE, IS TO SELECT FINAL SITING
OPTIONS THAT MAXI .1IZE THE RELIABILITY OF THE ENTIRE TREATMENT
SYSTEM."
-9-
1 FIND LITTLE PROBLEM WITH THIS OBJECTIVE, EXCEPT TO COA...IENT THAT
SPLITTING THE FACILITIES MINIMIZES THE IMPACT ON EACH PROPOSED SITL,
AND THEREFORE SilOULD BE CONSIDERED PREFERABLE TO PLACING TliE
ENTIRE BURDEN ON ONE COMMUNITY.
RANKING OF DECISION CRITERIA
IN LIGHT OF THE ABOVE COMMENTS, I PROPOSE THE FOLLOWING BANKING
SYSTE.-.I FOR THE DECISION CRITERIA:
IN MY OPINION, TI.E CRITERIA FALL INTO TWO DISTINCT CLASSES, AMJ C/u\ .'P.
FURTHER MANKED WITHIN THOSE CLASSES. THE FIRST CLASS CONTAINS TliE
PRIME AND FUNDAMENTAL CRITERIA WHICH t:U3TI>E ASSIDLOl'SLY ADDRESSED
AND ..EKill HEAVILY ON THE FINAL DECISION. THE SECOND CLAaS INCLUDES
THE I'.E.'.iAIMNc; CRITERIA illilCil ALL MERIT THOROUGH uEVIEV.. TiiE3E
SECOND CLASS;
1. EFFECTS ON NATURAL AND CULTURAL RESOURCES
2. COSTS
3. IMPLEMENT-ABILITY
4. RELIABILITY
AFTER REVIEWING THESE CRITERIA AND APPLYING THE CLASSIFICATION SYSTE;,,
ABOVE, I AM CONFIDENT THAT YOU WILL SHARE .MY VIE* THAT ALL DEER
ISLAND, PRIMARY OH SECONDARY, IS TLE .MOST UNACCEPTABLE OPTION. iVITIl
REGARD TO THE PRIMARY TREATMENT FACILITY, I ALREADY HAVE STATED MY
PREFERENCE FOR LONG ISLAND'S INCLUSION AS AN OPTION. AU3ENT TIRS
OPTION, WHICH I STRONGLY BELIEVE SHOULD BE INCLUDED, I FIND THE SPLIT
DEER ISLAND-LONG ISLAND ALTERNATIVE TO BE LESS OFFENSIVE THAN
IMPOSING TliE FULL BURDEN ON DEER ISLAND.
REGARDLESS OF THE DECISION MADE, I ENCOURAGE YOU TO PURSUE THE
MITIGATION EFFORTS OUTLINED lii THE REPORT. IN ADDITION, I ALSO URGE
YOU TO TAKE CONCRETE STEPS TO INSURE THAT THE OVERALL EFFECT OF A
NEW FACILITY COMMUNITY IS MANAGEABLE AND IS COUNTERBALANCED BY
OTHER CONSIDERATIONS.
IN CONCLUSION, I FIND THIS REPORT AN EXCELLENT STARTING POINT FOR OUT:
DISCUSSIONS ON THIS SERIOUS QUESTION. I WOULD HOPE THAT YOU REVIEW
THESE COMMENTS CAREFULLY AND CONSIDER THEM MTU DUE DILIGENCE. IF
THERE IS COOPERATION AMONG THE COMMONWEALTH, THE CITY OF UOSTON
AND YOUR AGENCY, AND IF ALL OF THESE GROUPS ADDRESS THE ISSUE
HONESTLY AND FORTH RIGHTLY, THEN I AM CONFIDENT THAT WE CAN FIND A
SOLUTION ACCEPTABLE TO ALL THE PEOPLE OF BOSTON AND ONE THAT V.ILL
SOLVE THE PROBLEMS FACING THE HARBOR.
THAI
: YOU FOR YOUR ATTENTIION TO THESE COMMENTS.
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Advisory
Council On
Historic
Preservation
Ttu> Old Posl Office Building
1100 Puuuylvuiia Avonuo. NW. *809
V&shingtan. DC 20004
FEB25I985 <*?..
*c
Mr. Michael R. Deland
Regional Administrator ...' /
U.S. Environmental Protection Agency
J.F. Kennedy Federal Building
Boston, MA 02203
Dear Mr. Deland:
On February 11, 1985, we received the Supplemental Draft Environmental
Impact Statement/Report on Siting of Uastewater Treatment Facilities for
Boston Harbor. Thank you for forwarding this document. After reviewing
the DEIS, we would like to offer general comments on the proposed
alternatives as they affect historic properties.
The alternatives which consolidate facilities on Long Island or split
facilities between Deer Island and Long Island are the least desirable. As
the DEIS points out, significant archeologlcal resources have been located
on Long Island, and the Long Island Chronic Disease Hospital may be
eligible for the National Register of Historic Places. As proposed,
construction of treatment facilities on Long Island would have an adverse
effect on these historic properties.
The alternatives which consolidate facilities on Deer Island or split
facilities between Deer Island and Nut Island would have significantly less
Impact on historic properties. Information In Section 12.10 of the DEIS
suggests that prior ground disturbance has greatly lessened the
archeologlcal sensitivity of the area. The DEIS also maintains that
above-ground resources may not be eligible for the National Register.
These properties, Including Fort Dawes, the sewerage pumping station, and
the Deer Island House of Correction, should be carefully evaluated by both
EPA and the Massachusetts State Historic Preservation Officer to determine
If they may meet the criteria for listing In the National Register of
Historic Places.
We appreciate this opportunity to provide Input during the selection of a
preferred alternative. If you have any questions, please call Druscllla J.
Null at (202) 786-0605. Thank you for your cooperation.
oject
tern Division
Review
RECEIVED-FPA
PF/i '2 '6 ¥35
WiltPi QUAliVV DE.'.'.'CH
-------
U.S. Department *~ew<*>°»
of Transportation
Federal Aviation
Admlnlitratlon
March IB, 1985
Mr. Michael R. Deland
Regional Administrator
U.S. Environmental Protection Agency
Region 1
J.F. K. Federal Building
Boston, MA 02203
Dear Mr. Deland:
.. We have reviewed the Supplemental Draft Environmental Impact
I Statement (SDEIS) on the alting of Wastevater Treatment Facilities
QQ In Boston Harbor. Our review has been with respect to potential
impacts on traffic operations of the Boston- Logan Airport and we
offer the follolwng comment:
In the location and construction of the facility, it must be assured
that no penetration of the FAR Part 77 imaginary surfaces occurs. For
this purpose the project proponent will have to complete and file FAA
Form 7460-1 for our review. This item should be Included in the list
of Permits Checklist (Section 11.1, Volume 2).
Our preliminary review Indicates that the height limitation for structures
on Deer Island would be 170 MSL and on Long Island, it would be 350 MSL.
We appreciate the opportunity afforded us for the review of the SDEIS.
For any further information, our contact person is Mr. Ashraf Jan,
(Telephone: (617) 273-7060).
Sincerely,
Vincent A. Scarano
Manager, Planning/Programming Branch
cc: Mr. Samuel Mygatt, MEPA Unit
f:-::\
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DEPARTMENT OF THE ARMY
Planning Division
If.ipact Analysis Hranch
-2-
NJ
I
::r. Michael R. Dcland
Regional Administrator
U.S. Environmental Protection Agency
llegion I
J.F.K. Building
Boston. Ilassachusetts 02203
Dear '.Ir. Dcland:
We have reviewed the Supplemental Draft Environmental Ir.ipact r.tatcncr.t
(SDEIS) for Siting of l.'asteuater Treatment Facilities for Boston harbor.
The report consider! 7 alternatives: 4 secondary treatment (local
outfall) anJ 3 prinary treatnent (long outfall) alternatives. T'.iey arc:
1. All Secondary Deer Island.
2. Split Secondary Deer Island and Hut Island.
3. All Secondary Long Island.
4. Split Secondary Deer Island and Long Island.
5. All Priuary Deer Island.
S. Split Prirury Deer Island and .'ut Island.
7. Split Primary Deer Island and Long Island.
H?A iias chosen to recommend no preferred alternative in this document,
but does indicate that "Federal regulations require the ST-HIS to rigorously
explore all reasonable alternatives for tiie siting of uastewatcr treatment
and disposal facilities serving Metropolitan Boston" (P.2-1). *!o assunc that
"PA is referring to Peculations for Ir.nlcucntin". the 1'rocedural Provisions of
the "lational r.nviromiental ?olicv Act or 1%9 (40 err. Parts 1500-151.1,
"ovotibor 29, 197Pi), which state in part, that the Altcrnativ3s section oi an
7.IP. "should present the environmental i:.ipacts or the proposal and the
alternatives in comparative foru, thus sharply defining the issues and
providing a clear basis for choice aniong options by the dccisiont:al:er anu t'.iu
public. In this section agencies shall:
a) rigorously explore and objectively evaluate all reasonable
alternatives..."
and b) "Devote substantial treatment to each alternative considered in
detail including the proposed action so that reviewers ::av evaluate ti'eir
coii.>arative merits " (1502.1'.).
'./o do not find sufficient detailed comparative information in the ."D::iC,
for adequate tiEPA consideration, concerning the affected envirom^cnt and
environmental impacts of the various alternatives, particularly as regards
the terrestrial and oarino ecoaysteas. Inadequate site-specific
consideration is given concerning terrestrial and marine inpacts of
construction and operation of the trcatrient facilities, conduits and
outfalls, including the composition of any dredged materials and potential
disposal strategies. In addition, the "no action" alternative is not
displayed and analyzed in the SDF.IS, as is required. Specific co;c.x-nt3
resulting from our revieu are attached.
A Department of the Arny perait uill be required for tiiis project in
accordance with Cection 10 of the .livers and"!tarbors Act of 11)59, licet ion 40V
of the Clean Water Act, and Section 103 of the l.'arine Protection, Research
and Sanctuaries Act of 1972. "e find that the SDEIS document uoes not fully
assess the alternatives and impacts in the detail that ue uould require 1'or
our regulatory review. Further, since a Section 434(b)(l) evaluation woulu
aave to be developed prior to'a permit decision, ue would strongly surest
that it be included as an integral part of the SDEIS docunent. \'ith the
currently existing documentation, we uould not consider an application for a
perait to be complete, and therefore ue would not be able to cocnence our
regulatory process.
!?e uould be pleased to continue in our role of cooperating agency.
Should you have any questions concerning this letter, please -eel free to
contact ae at ?TS 330-7220, or either ;ir. Joseph !U>rouitz of t'.ie I..;>act
Analysis Branch (£39-7513) or !!r. Ralph Atl'.inson of the P.e;;ulatory Branch
(E39-7497).
Sincerely,
Carl 3. Sciple
Colonel, Corps of Engineers
Division rngineer
-------
Specific Corments on SDEIS for
Siting'of '.lastowater Treatment Facilities
for BoBton Harbor
1. P.3-16 - Pr
desirable.
lion of conplete wind roaes, if available, would be
2. The section entitled "Federal and State Permits and Regulations
Checklist" (11.1) should be revised. The entries are too often nonspecific
and not well referenced. For example. Section 404 permit requirenents are
merely referenced, seemingly as an afterthought, under item 4., which deals
with a "DEQE Division of Waterways Permit", by stating (4.C.) "U.S. Arny
Corps of Engineers Permit is also required".
3. lie cannot agree with EPA's decision to avoid site specific marine-related
analyses by the statement on page 11.2-2 which assumes:
A) That "the types of marine construction impacts with all the sites
appear to be similar (except for possible filling at Hut Island)"
and B) "The likelihood that all of the marine construction sites are
characterized by similarly contaminated sediments which are common in Boston
Harbor"; and cites that "in the past these contaminated conditions have not
precluded previous harbor projects." EPA, in fact, refutes its own decision
in the next paragraph, in discussing the PCB problems in Dorchester Bay and
Uinthrop Harbor.
4. Page 11.2-1 - third paragraph: Disposal of these sediments beyond the
territorial sea should be chsnged to beyond the baseline. Also, the
following should be added: Disposal inside the baseline would require a
Section 404 permit.
5. Page 11.2-6 - first paragraph, second line: change beyond the three nile
territorial sea boundary to beyond the baseline.
6. Page 11.2-7 - Replace the entire second portion of the first paragraph
that starts: "Dredged material exemptions" with the following:
Dredged material exemptions from certain environmental inpact evaluations
are itemized under 40 CFR 227.13: "Dredjed Materials".
7. Page 11.2-17 - Use the correct nane of the disposal site you refer to as
the Boston Dump Site. It is the "Foul Area". The same name should be used
throughout the report.
3. The baseline information and impact discussions located in Section 12
(within the Appendices) should be considered for use in the body of the EIS.
9. With regard to the Corps responsibilities concerning the Federal deep
draft navigation project in Boston Harbor: All of the SDEIS alternatives
call for flows to be routed between Deer and Hut Islands via an underwater
conduit which would cross the Federal deep draft navigation project.
Additionally, local and long outfalls may be located within the Federal
navigation project. The exact location of these works has not yet been
determined. Therefore, the following should be kept in mind:
A) Deep draft navigation projects require that any conduits to be placed
within the project must be at least six feet below the authorized depth of
the project and that this extent be comprised of ordinary cover material.
This requirement extends laterally from the project boundariea (channel or
anchorage line) a diatance of 1.5 times the project depth at any given
location.
B) The Corps of Engineers is studying the feasibility of improving the
Federal navigation project. No depths lower than 40 feet MLU in the inner
harbor (inside of the MBTA tunnel) are being considered, because of the
impact on the three existing tunnels in the harbor (Sooner, Callahan and
MBTA). However, portions of the Main Waterfront in East Boston and South
Boston, the Reserved Channel, President Roads Anchorage and Broad Sound could
be deepened below 40 feet HLU and are alternatives to be considered in our
Boston Harbor Navigation Improvement Study. Potential conflicts between
these possibilities and the location of wastewater facility conduits or
outfalls should be considered.
C) The location of outfalls resulting from any wastewater improvements
may impact on the quality of the navigation project sediments to be
aaintenance-dredged by the Corps, and result in problems for the dredging and
disposal operations. The navigation improvement project could be similarly
affected.
D) Construction of underwater conduits and outfalls would likely have
short-term impacts on existing navigation, possibly restricting deep draft
traffic for a period of time.
E) As noted above, all of the SDEIS alternatives may affect existing
navigation, maintenance of the Federal navigation project and any
improvements to the Federal navigation project. Uhile it does not address
these potentisl concerns, the SDEIS does note that a Corps Section 10 permit
will be required. The SDEIS aa well as the permit application should clearly
address navigation-related concerns.
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
Office of Environmental Project Review
1500 Custom House
165 Slate Street
Boston Massachusetts 02109
SDEI3, Siting of Hastewater Treatment
Facilities for Boston. MA (ER 65/393)
April 8, 1385
Hr. Michael R. Del and
Regional Administrator
U.S. Er.viror.aer.tal Protection Agency
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. Del and:
Thank you for the opportunity to comment upon the Supplemental Drcf*.
Environmental Impact Statement for Siting of Hasteuater Treatment Facilities
In Boston Harbor. Although there are significant differences in the impacts
associated with the alternatives with regard to the quality of effluent
resulting from primary and secondary treatment, our comaents here are
restricted to the impacts associated with siting. Earlier comments to you
from the Fish and Wildlife Service regarding the impacts of the two treatment
levels eipressed our significant concern that primary treatment of wastewater
would not provide for the protection of the fish and wildlife resources of
Boston Harbor and Massachusetts Bay. Those concerns remain, and should not be
considered to have lessened because they are not reiterated hers.
Only one of the reviewing agencies within DOI received both volumes of the
SDEIS, resulting in some understandably tentative comments regarding the
proposal, especially decisions concerning the scope of alternatives
considered.
Our review of the incomplete set of documents finds that consideration was not
given to the feasibility and impact of using inland satellite treatment
plants. Consideration of these and the documented alternatives should include
analysis of the effects on groundwater recharge, and address concerns
regarding the effects of proposed future increases in the expoi t of fresh
water to Boston Haibor.
Regarding specific sites, the Department of the Interior h?.s significant
concern for the cultural, geological and biological resources on Long Island.
Construction or. Long Island, regardless of which alternative is cnosen, would
cause some form of impact to cultural resources. To ensure the protection of
cultural resources, we recommend continued coordination srd consultation with
the Jtate Historic Preservation Officer (SHPO), and that alligation be a port
of that process. The fir.sl EI3 shoulo document =orcurrcncc from the S'.if > -
Ms. Valerie Talmage, Massachusetts Historical Commission, 30 Boy1=tor Street,
uoston, Massachusetts 02116.
-2-
We recouend similar coordination and documentatior. regarding recreational
resources with State, county and other officials with recreational interests.
The State Liaison Officer is Hr. James S. Hoyte, Secretary of Environmental
Affairs, 100 Cambridge Street, Boston, Massachusetts 02202.
We concur with the SDEIS' contention that other sites or. Long Island are not
suitable because of their environmentally sensitive nature. Those areas
contain wetlands and a barrier beach which provide important wildlife habitat.
We would likely recommend against issuance of any Corps of Engineers' permits
required to built in any of these resources. Further, because the barrier
beach/wetland identified in tha document is part of the West Head Beach Ur.it
(C01C) of the Coastal Barrier Resource System, any decision to impact these
resources would require consultation with the-Fish and Wildlife Service, as
required under the Coastal Barrier Resources Act.
Of the sites considered in the SDEIS, DOI prefers the Deer Island site
because It would have the least Impact or. cultural and biological resources.
Sincerely yours,
William Patterson
Regional Environmental Officer
-------
STATE/REGIONAL COMMENTS
2-12
-------
If WIHAGC 01.
to
I
RECZ:VL:D
Marcrt 8, 1985
James S. Hoyte, Secretary
Executive Office of Environmental Affairs
100 Cambridge St.
Boston, Ha. 02202
MS* 1 i
OFFICE OF THE
..- ..... ~ ..... r
.»iRS
Subject:
Draft E1S/EIR on Wastewater Treatment Plant
Siting In Boston Harbor
Dear Secretary Hoyte,
In-addition to comments made by Metropolitan District
Commission staff during preparation by the Environmental
Protection Agency of the draft EIS/EIR, we would like to offer
the attached report. This report has been prepared by H.O.C's
Engineering Management consultant in order to gain more
Information relative to the cost data submitted In the DEIS/EIR.
Since the dollar figures in this report vary significantly from
those offered in the DEIS/EIR, we feel It mandatory that more
effort be expended to develop acceptable cost estimates for the
final EIS/EIR.
The attached document represents the concerns of existing
M.O.C. staff and our consultant, but may not identify all the
issues which may concern the recently developed Massachusetts
Water Resources Authority. It is assumed that members of the new
authority board will be reviewing the siting Issues as soon as
possible and will make further comments as appropriate.
Very truly yours.
^s;>^. .<*.••
-IfflHam J. Geary
'Commissioner
JMH/gab
attachment
SOE1S REVIEW CflUHEHTS
GENERAL ANALYTICAL APPROACH
The SOEIS has segmented much of the planning In an attempt to focus on
the Issues surrounding the siting of the facilities. The SOEIS provides
decision makers with a limited perspective on the overall Impacts of the
presented alternatives. In addition, there are several . broad
Assumptions made as part of the SDEIS. These assumptions are fully
explained In the appendicies, but they are not quantified in the summary
documents. Examples of this follow:
The SOEIS, estimating the costs of various primary alterna-
tives, has provided for processing of sludges through to
anaerobic digestion. No such processing of secondary sludge
is provided, although certain site plans show units for
processing secondary sludge to this level. It Is recognized
that It Is not the Intent of the SOEIS to make comparisons
between levels of treatment. Eventually, such comparisons
will be made, and the alternatives presented should bring
various options to common end points.
For the purpose of analysis, the SOEIS assumes that SOI
matching grants w11l be available, and discusses to some
degree the likelihood of such a decision. While it 1s
Impossible to predict the actual level of future funding, it
should be' noted that this project alone would consume
virtually all of the Commonwealth's federal construction grant
allocation—leaving little federal monies- -for other HOC
projects or other communities in the state. We believe that
the sternary tables should reflect ranges in likely costs to
homeowners, representing reasonable assumptions on levels of
grant funding, and other indeterminate factors.' This would,
at the least, provide decision makers with some idea of the
range of likely costs under various scenarios, and the factors
Influencing these ranges.
-------
to
I
Examples of the Impacts of this Issue of limited perspective are
presented in the following sections.
CAPITAL COST ESTIMATES
Independent cost estio«tes of various system components have been
prepared by Camp Dresser 1 McKee Inc. (COM) for the SOEIS alternatives.
The estimates are different from the SOEIS estimates, with the
differences ranging between $400-n111ion to S4SO-m111ion for the
secondary alternatives, and between $115-011 lion and 1175-milllon for
the primary treatment alternatives. Table 1 depicts the differences
between alternatives.
COM has estimated the capital cost of the secondary sludge processing
facilities mentioned above at approximately (35-millfon. The costs
associated with siting only (exclusive of the level of treatment) have
been developed and are also presented in Table 1.
TABLE 1
SUMMARY COMPARISON OF ESTIMATED
PROBABLE CONSTRUCTION COSTS
(MILLIONS)
TOTAL CONSTRUCTION COSTS
OPTION
SDEIS
COM
DOLLAR PER-
0INFERENCE CENTAGE
1*2
Ib2
2bl
2b3
4*2
4b2
3*2
393.04
630.40
703.99
738.33
731.99
799.91"
816.23
992.17
1093.30
1113.20
1133.40
867.08
968.14
989.20
397.13
443.10
409.21
417.07
113.09'
163.23
172.97
67S
6S%
38S
S6K
13,'J
21JS
21S
FINANCIAL IMPACTS
Section 12,5 presents various assumptions used in developing user rate
Impacts of a hypothetical $800-ml 111 on project. The cumulative
amortization schedule (Table 12.5.3) appears to neglect the fact that
the authority will Issue revenue bonds, as oppossed to general
obligation bonds. Under a revenue bond issue, certain reserves,
contingency accounts, and Issue costs are normally capitalized. The
result is that only about 801 of the proceeds of an Issue are available
for use. Therefore, a S200-million construction cost could require a
bond Issue as large as S250-m1111on. This should be included in the
analysis. None of these costs have been factored as grant eligible.
Annual operating costs (O.M, and R) do not appear to .include an
allowance for R (replacenent)--as defined by EPA. We have estimated the
Increment In cost for replacement to be S2-mil1ion per year for primary
treatment alternatives and S5-m11Hon per year for secondary treatment
alternatives. Both figures are exclusive of conditioning', dewatering
and disposal of residues.
-2-
SITE COSTS' ONLY
OPTION
SDEIS
COM
DIFFERENCE
1*2
152
2bl
253
4a2
4b2
S»2
134.93
183.39
186.97
190.39
107.66
131.64
129.39
172.66
223.12
212.20
213.82
145.3?
1?4.76
186.73
37.73
37.73
'25.23
23.23
37.73
43.12
57.34
23S
207:
13K
13S
3f-'.
28:-,
44K
-3-
-------
NJ
I
H«
(Jl
T-hc SOEIS presents annual homeowner costs based upon the SOEIS capital
estimates; an assumed level of grant funding; financing as presented in
the SDEIS; and, DIM costs as presented In the SDEIS. All of these costs
are In current dollars. In order to provide a range of potential costs
to the homeowner, estimates have been made using the SDEIS numbers
Inflated to the first year of operation, at the presumed level of
funding, and at a level of no grant participation, and for the COM cost
estimated at SO. and 01 grant funding. The resultant homeowner costs
are shown in Table 2 for options Ia2 and 4a2 (secondary and primary
treatment, respectively).
This analysis suggests that homeowner costs (in 1995) could range from
approximately S170 to $335 per year, depending on the underlying
assumptions. For this reason, the variability of the underlying
Assumptions should be displayed In all sunmary documents.
MISCELLANEOUS
The construction activity and sequence table (Table 12'.2-2) located In
the SOEIS has been reviewed and compared with the Site Option Study.
Table 12.2-2 of the SOEIS states the quantity of excavation and/or
demolition materials to be moved requires five barges per day for
secondary treatment and four barges per day for primary treatment.
ESTIMATED HOMEOWNER COSTS
barges per day. The
site layout has been reviewed, and we beleive the SOEIS table to. be
Incorrect. • •
-------
uieaufr ep*.
30.'/»mrMtt 'Jtffft. .
•CWCNACI OIVKION
March 14. 1985
i."'"" r: if. MTV
rs)
I
M
CT»
Executive Office of Environmental Affairs
100 Cambridge Street
Boston, Massachusetts 02202 ' •"'•'"•'•'• •''•'•••'
Attention: Sam Mygatt, MEPA Unit
Subject: Comments on Draft E1S/E1R on Uastewater
Treatment Plant Siting
Dear Mr. Mygatt,
Attached is the back-up information on construction costs for the Draft EIS/E1R
as requested. Please attach this Information to the comments submitted to
your office March 8, 1985.
/ s —
"Noel* D. Baratta. P.E.
Director & Chief Engineer
JMH/ve
Attachment
Ia2
SCEIS con
SKIS cm
SIMMY carousai or ESTIMATED recettu CCNSTRUCTICN COSTS
i PrtchloriAatioa
1 ScrttA i DMT It
1 Influent Punino
PMMIV SatiliA)
Gra>i» ThickaniA)
Anatrobic Dilution
Gat Staraoi
Secondary StitliA)
AtratioA
91n»r Biildin)
ChlarinatioA
IPiiri
TuAAtlt
OuifalU
Channali ( Oiktt
Powai ta Sita
Dculition
fteMva Untui tables
Gtnaratori 1 8uildin;t
Adaiaittration Building
Effluent °uuinj
Miscellaneous Civil
Earth Fill
Foundattont
1 Land
1 Odor Control
1 ScjB Incinerator
V.al ."i»:i
Stcondarv Solidt
Floatation Triidmiart
Ooitrotiic Digestion
Toiil n ta rilattd
COSti
Ia2
SKIS cm
4.90 4.30
11.80 11.80
29.68 29.68
30.03 117.03
3.51 3.87
22.06 19.36
3.15 4.25
116.38 31S.JO
80.32 181.32
44.74 11.29
17.11 23.10
11.81 11.81
82.82 120.33
47.72 47.72
3.42 3.42
1.77 1.77
2.84 2.84
27.33 27.33
8.15 8.13
7.36 7.36
10.00 10.00
0.76 0.76
0.00
0.00
2.08 2.08
17.31 17.31
7.23 7.23
S9S.S4 332.17
7.005
15.559
134. fi U2.it,
Ib2
SKIS C»l
4.90 4.30
11.80 11.80
32.67 29.68
35.95 172.67
4.09 5.77
12.92 10.76
3.13 4.23
116.33 313.90
80.32 181.32
44.74 11.29
17.11 23.10
24.30 24.30
82.82 120.33
47.72 47.72
9.44 9.44
1.97 1.97
1.38 1.33
26.31 26.31
7.62 7.62
11.06 11.06
10.00 10.00
0.71 0.71
2.44 2.44
13.73 13.73
2.08 2.08
34.88 34.88
7.31 7.31
6M.4 1CSJ.3
7.005
15.533
133.39 223.12
2bl
SKIS cm
4.34 4.30
11.30 11.80
27.31 10.43
45.08 172.67
4.68 (.03
33.09 30.84
3.13 4.23
116.38 313.90
30.32 181.32
44.74 11.29
17.11 23.10
13.93 13.33
114.62 139.83
91. 86 91.36
12.04 12.04
1.77 1.77
9.43 9.43
2.23 2.23
8.13 8.13
8.98 8.38
10.00 10.00
0.63 0.63
4.68 4.68
11.36 11.36
2.43 2.45
18.03 18.03
7.25 7.25
753.. '3 1113.2
7.005
13.359
136.37 212.2
2b3
SKIS cm
4.90 4.90
11. SO 11.80
54.47 37.39
35.93 172.67
3.51 5.77
25.84 20.38
(.30 8.51
116.38 313.30
80.32 181.32
44.74 11.23
17.11 23.10
23.74 25.74
114.62 133.85
31.86 91.86
12.66 12.66
1.77 1.77
2.84 2.84
2.43 2.43
6.93 6.33
8.38 8.98
10.00 10.00
1.04 1.04
2.01 2.01
11.36 11.36
2.33 2.38
34.38 34.38
7.51 7.51
733.33 1155. *
7.;33
13.359
130.59 215.32
4a2
SDEIS cm
4.90 4.90
11.80 11.80
29.68 29.33
30.05 117.05
3.51 3.37
22.06 20.91
3.15 4.25
0.00 0.00
0.00 0.00
0.00 0.00
10.19 0.00
11.81 11.81
82.82 120.55
479.50 479.50
1.80 1.80
4.13 4.13
2.84 2.34
2.19 2.19
8.13 8.13
(.62 (.62
10.30 10.30
0.33 0.33
0.00
o.go
0.34 0.34
17.81 17.31
7.23 7.25
-l.«? =67.03
1
'
10?.io '.».})
4b2.
SOE1S
4.90
11.80
32.67
33.93
3.31
12.92
3.13
0.00
0.00
0.00
9.39
24.30
77.43
479.30
7.36
4.13
1.38
1.36
7.62
10.11
10.30
d.16
2.44
13.73
C.61
•4.38
r.si
^3.3!
131.64
NOTES: Tor Heat •art*d uitft *a iiiffik no indcotndant CCfl tsnn«t* "** t«*n
Sitt rtUud costs are **rk#d -itn w «*cl»auon ooiot.
-------
1.33
K>
cm
4.90
11.30
29.93
172.67
5.77
10.29
4.23
0.00
0.00
0.00
0.00
24.30
120.33
479.30
7.56
4.13
1.58
l.X
7.42
10.11
10.30
0.16
2.44
15.73
0.61
34.33
7.51
(*>***»«
?C3.14
0
0
3i2
S8E1S Ctrl
4.90 4.90
11.80 11.80
40.11 40.11
35.95 172.67
3.51 3.77
25.84 20.38
6.30 8.51
0.00 0.00
0.00 0.00
0.00 0.00
9.39 0.00
25.74 23.74
32.51 139.83
479.50 479.50
2.79 2.79
4.13 4.13
2.34 2.34
1.83 S.83
8.13 8.13
12.29 12.29
10.50 0.90
0.33 0.35
1.00 1.00
2.33 2.33
1.14 1.14
34.88 34. S3
7.31 7.51
uxsza szzssi
816.23 989.20
0
0
WIU.1AM J. OEARV
!J4.7. 129.3) 136.73
March 15, 1983
Mr. Michael R. Deland
Regional Administrator
Environmental Protection Agency
JFK Building
Boston. MA 02203
Dear Mr. Deland:
Please be advised that all reference made to the rotary formerly known
as Columbus Circle should be changed to Koeciuarko Circle. A map detailing
the exact location of Kosciuszko Circle In South Boston is attached.
This circle waa dedicated to the memory of Thaddeua Kosciuacko in 1934
and was formalized by an act of the Massachusetts Scace Legislature In
1963.
Please update any naps, slgnage or correspondence to this effect. Thank
you in advance for your cooperation;.
-------
I
M
09
-------
*sne
(KnniA'vt fffio* cf &«M
of
S. RUSSELL SYLVA
ottos
to
I
i->
UD
Michael Dclvid.
Regional Administrator
Environmental Protection Agency
JFK Building
Boston, HA 02203
March 8. 1985
Re: Supplemental Draft Environmental
lopact Statement/Report on
Siting of Wastewater Treatment
Facilities for Boston Harbor
James S. Hoyte. Secretary
Executive Office of Environmental Affairs
100 Cambridge Street
Boston. MA 02202 .
Gentlemen:
In accordance »lth the public consent and review requirements for this
SDEIS/EIR the Department of Environmental Quality Engineering (OEQE) for-
mally submits its review comments to both the EPA and MEPA. These cerements
are a compilation of Issues raised by various sections within the
Department and are Intended to be In addition to the written preliminary
comments from EOEA Agencies transmitted to EPA on February 1, 1985. by
Samuel Mygatt.
Specific Comnents froa OEQE Divisions
(1) Table 1-1 and te»t within Chapter 1:
The data regarding Dry Heather Overflows (DWO's) Is outdated and pro-
vides the reader with a false idea of existing environmental conditions
within the harbor. This comment has been previously made to EPA and C.E.
Magulre during our review of the draft chapters.' We again suggest that
this information be updated by obtaining additional Information from the
Boston Water and Sewer Commission and the HOC.
(2) Figure 4-8 and tot of Chapter 4:
There are inconslstences among the various options regarding the
extent and nature of sludge and scum processing being included on site
layouts, area! needs and cost analyses. All options should be based upon a
consistent method of sludge and scua processing and all corollary aspects
such as energy needs and solids content should be clearly defined.
-2-
All site layouts Indicate a scum Incinerator will be a component of
the treatment facilities. The scum Incinerator has been temporarily
removed from the Deer Island Fast-track program pending the results of the
three-month Interim residuals study being performed by Stone I Webster for
the HOC. The proposal for a scum Incinerator has been a major area of
disagreement between the HOC and the Town of Wlnthrop and no decision has
been made regarding Its Inclusion Into any Interim or long-term facilities.
Further, no environmental analysis has been performed within this EIS/EIR
for its potential Impacts. Therefore, all references to it on the site
layouts and cost tables should be removed or an analysts of Its Impacts
Included In the Final EIS.
(3) Chapter 4. Traffic Analysis:
The necessity to rebuild the Long Island bridge Is being assumed In
the EIS. but a traffic analysis of the additional construction work for
this bridge Is not Included within the report.
DEQE's Division of Air Quality Control has the following three major
comments.
(a) Additional ambient noise studies should be performed at all three
• potential sites so that a reliable ambient data base can be deve-
loped. This additional field study should Include both daytime
and nighttime measurements so that the LJO, LSQ, Lgo ""1 l-eq noise
levels can be defined.
(b) Given the lengthy construction periods at various sites. It Is
Imperative that all feasible and reasonable measures must be
instituted to mitigate noise Impacts. Statements to that effect
should be specifically included In the Final EIS.
(c) The proposed Oeer Island Fast-track program for reconstruction of
the Power and Pumping Facilities will reduce odor and noise con-
ditions currently existing on Deer Island. This information
should receive greater emphasis in the report.
General Comments from the Division of Water'Pollution Control
(1) The Division has not allowed rectangular secondary clarlfiers In its
wastewater treatment facilities for a number of years due to their history
of poor performance. This Issue was previously raised by the Division in
prior review meetings. This Issue should be addressed by EPA along with
the potential ramifications of utilizing circular final clarlfiers at the
facilities (eg. area! needs, costs, operational consistency, etc.)
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(2) Financial Impact Analysis The SDEIS analysis appears to Imply that the
cost per household of the treatment"plants would increase by J91-J111 for
secondary and by J74-J82 for primary fro* an estimated existing cost tn
Boston of 180. The J80 figure was, however, an estimate of the total
sewerage systeo bill for an average household In Boston. Only part of that
cost can actually be attributed to the existing HOC treatment plants. A
more accurate statement would seen to be that the cost of the new treatment
plants to an average HOC household Mill be J91-1111 for secondary and -
J74-J82 for primary.
(3) A number of system.design and cost issues have been raised and
discussed at various meetings between the Commonwealth, EPA and its con-
sultants. A brief summary of those issues were provided to EPA in early
February via a Memorandum from Samuel Mygatt and were subsequently
discussed at a meeting on February 10 between EOEA and EPA. Those aspects
of particular importance to OEQE are restated below:
(a) Verification of the Netcalf I Eddy/C.E. Magulre site layouts and areal
needs should be obtained. Such an analysis should be expanded to include
the temporary land requirements needed during the construction phase and
corallary permanent areas (roadways, parking, etc.) so that environmental
impacts can better be defined. .
(b) Project costs, particularly capital costs, have been an item In conten-
tion and disagreement throughout the document development phase. A
recently completed analysis by COIN for the HOC (described in MDC's SDEIS
comment letter) adds greater importance to this issue. A further analysis
should be performed to narrow these significant cost differences.
(c) An analysis of the theoretical treatment removal efficiencies deli-
neated In the report for secondary treatment facilities should be per-
formed. The potential size, extensive system pumping and flow
characteristics for this particular treatment system should be factored
into such an analysis and a national review of removal efficiencies from
similar treatment facilities, if any exist, should be obtained. This ana-
lysis should not only analyze conventional pollutant removals but also
toxics since various assumption in this regard have been made by C.E.
Magulre In the report.
(d) The wastewater treatment facilities are being sized to treat a peak
flow of 1240 MGD, 310 from the SNSD and 930 from the NHSO. The Division
agrees that the 930 peak flows from the NHSO are consistent with the
available transmission systems but a larger Issue which needs to be
addressed is a determination of the level of treatment for this peak flow.
As has been mentioned to EPA by representatives from the Division on various
occasions, a decision must be made as to how much of this 930 peak flow
should be processed through the secondary facilities. The prior I/I and
CSO studies performed by CDtM for the HOC Indicate a peak sewage generation
including peak infiltration of 810 MGD, while the additional 120 MGD (930 -
810) would be Inflow from combined sewers tn the NMSD. Therefore, it must
be determined what the level of treatment should be for this additional 120
MGD; secondary or only screening and chlortnatlon as required for the other
CSO discharges. This issue could significantly affect the cost and areal
extent of the treatment facilities.
If you have any questions regarding this correspondence feel free to
contact Steven Lipman of my staff at 292-5698.
Very truly yours
SRS/SGL/bd
cc: Thomas C. HcMahon. OWPC
Bruce Mai Met, DAQC
Samuel Mygatt. HEPA
£7S. Russell Sylva.
Commissioner
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JAMES 5. MOYTE
SCCNCTAMV
March 18. 1985
CERTIFICATE OF THE SECRETARY OF ENVIRONMENTAL AFFAIRS
ON
DRAFT ENVIRONMENTAL IMPACT REPORT
PROJECT NAME
PROJECT LOCATION
EOEA NUMBER
PROJECT PROPONENT
Sice Option Study
Boston and Qutncy, Massachusetts
4911
Metropolitan District Coomisslon
DATE NOTICED IN MONITOR : February 8, 1985
The Secretary of Environmental Affairs herein issues a statement
that the Draft Environmental Impact Report for the Siting of Wastewater
Treatment Facilities in Boston Harbor adequately and properly complies
with Massachusetts General Laws, Chapter 30* Section 62 through 62H,
inclusive, and with the regulations Implementing the Massachusetts
Environmental'Policy Act.
This determination is based on a thorough staff review of the
complete SDEIS/DEIR document and all supporting documents, consideration
of the comments made at three public hearings held by the U.S.
Environmental Protection Agency, and review of all w
alt ted to me on the document. This review has demon
additional information is required In a number of ar
Final EIR. the framework for a decision on the sltln
The following sections provide Individual discussion
Itten comment sub**
trated that, while
as for an adequate
question Is provided.
of the adequacy of
the SDEIS/DEIR, the question of segmentation, the requirements for an
acceptable Final EIR, and the decision model and process. Detailed staff
comments on the technical appendices and the text of the SDEIS/DEIR are
attached, as are the numerous written comments received.
EOEA i
SITZ E
PACE 2
1.0
ADEQUACY OF THE DEIR
The adequacy of the SDEIS/DEIR as a Draft Environmental Impact
Report under the provisions of the Massachusetts Environmental Policy
Act oust be determined by comparison CO the requirements set in the
Scop* for the EIR, issued by me as Che Certificate on the Environmental
Notification Form (December 6, 1983). Thla discussion parallels, in
large pare, the structure of the original Scope.
1.1
Treatment of Alternative*
In Che Scope, it we* anticipated that the treatment of alternatives
would provide design Information at a level suitable for decision
making, that screening would be used Co Halt the alternatives to be
considered in the Draft EIR, and that specific information would be pro-
vided on satellite treatment, the use of Long Island, and the effects of
both primary and secondary treatment alternatives. The SDEIS/DEIR has
generally met my expectations la chess; area*.
Conceptual design of standard secondary and primary treatment plants
has been presented at a level of detail eufficlent to .support the siting
decision. It 'has been demonstrated chat conservatively sized plants can
fit on Long Island, Deer Island, and (for south system primary only, sub-
ject Co severe environmental Impacts) on Hue Island. Refinements to these
designs, either in terms of technology or layout, aay reduce the net
impacts of any alternative, but cannot be expected to differentially affect
the suitability of one alternative site over another. Thus, additional
dealgn effort to support the Final EIR should focus on sizing and layout of
Che planes to limit and mitigate adverse effects.
Screening of alternatives, treated In Volume II of the SDEIS/DEIR, has
shown chat major wastewater treatment facilities will be needed at the
water side in Boston Harbor. As a result of.the screening, consideration
is now limited to the location of facilities on Deer Island, Long Island,
and Nut Island. It Is not necessary In Che Final EIR to reopen the uni-
verse of potential alternatives considered historically and In the
screening process from 22 to 8 alternatives.
Satellite treatment plants were extensively considered in the
screening process and In a separate evaluation, as was requested In the
Scope. This assessment demonstrates that satellite plants have a unique
and complex set of location problems of their own, that satellite plants
cannot replace a substantial treatment facility at the water edge, and that
utilization of satellite plants cannot materially reduce the size of
required facilities. While such plants have a definite place In the long
range planning for any expansions to the sewage system, they do not contri-
bute to the solution of the existing problems in Boston Harbor nor do they
eliminate the need for the siting decision now facing us.
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A 14911
E OPTION STUDY
,*v.E 3
Level of treatment !• handled In th* SDEIS/DEIR by providing a set
of three siting alternatives (or primary treatment and four alternatives
for secondary treataent. Thus, the decision process can and should
proceed regardless of the outcome of the 301(h) Waiver decision. While
that decision, due presently, will add focus to the siting decision, the
potential for legal challenge to that decision fron a broad spectrum of
Interested persons still warrants the selection of a preferred alter-
native for primary treataent and a separate preferred alternative for
secondary treataent. '
Finally, It la ay opinion that the SDEIS/DEIR document aakes a
taclc case for the restriction of the Final EIR to only two potential
sites: Long Island and Deer Island. Though the document, largely at
state urging, does not consider All Primary Long Island as a viable
alternative, I oust yield to the arguments of the many commenters who
point out that All Primary Long Island is ss cooperatively viable as All
Secondary Long Island. It is slso clear that the data in the SDEIS/DEIR
compelllngly disfavors any alternative using Nut Island as part of a
split treatment scheme* The island is too small to support substantial
expanalon of the existing treatment facility, the size reduction worked
in facilities st the other islands is inconsequential, and the costs of
the split alternatives using Nut Island are excessive. Thus, I recom-
mend (but do not require) that the Final EIR recognize these realities
and deal with the Deer* Island/Long Island choice clearly for both pri-
mary and secondary treataent.
1.2
Sludge Hanageaent
The scope for the EIR Indicated that, "At the least, the Site
Options EIR should discuss compatibility of the various alternatives
with both primary and secondary sludge dispossl options." While the
SDEIS/DEIR Indicates that sludge disposal decisions will not drive
the siting decision, this Issue does need further consideration.
Several comments Indicate that the coating and layout of sludge pro-
cessing Is not consistent among options. This should certainly be rec-
tified. In addition, the Scope requlrementa warrant that the Final EIR
account for sludge processing up to the point of Interface with sludge
transport or treatment facilities. Other issues raised I will discuss
below, under Segmentation.
1.3
Generic Issues
The scope called for extensive treatment of worker and material
barging, chlorine delivery, and odor control. The SDEIS/DEIR demonstra-
tes the absolute necessity of barging of materials and busing of
workers to avoid extreme and unacceptable traffic Impacts during
construction, discusses on-slte chlorine generstlon as an alternative to
barging of chlorine, and commits to odor controls. These discussions
-JCA 14911
SITE OPTION STUDY
PAGE 4
1 require expansion upon in the Final EIR. As discussed in the
Technical Contents, a much stronger assurance of the implementation of
barging must be made, since the unmitigated Impacts of truck transport
U.«T be sufficiently severe as to render all alternatives unfeasible.
Likewise, the frequent transport 'of chlorine through residential streets
Is highly undesirable and should be eliminated from each alternative
either through a verifiable ability to deliver chlorine by barge or by a
commitment to onslte chlorine generation* Finally, details of proposed
odor control technologies should be provided and the Influence on coat
should be reexamlned.
1.4 State Regulatory Issues
While some comments were received on various state and local regu-
latory Issues, the SDEIS/DEIR provides s sufficiently detailed
understanding of the regulatory framework to support sound decision
staking. All three of the islands considered are subject to numerous
regulatory cootralnts. In all cases, however, while these constraints
have an Important effect on siting, in my judgment none pose an abso-
lute bar to an option.
l.S
Miscellaneous
I pointed out In the Scope that the relocation of the Deer Island
House of Correction is not within the scope of the Site Options EIR. I
reaffirm that decision and extend it to the Long Island Chronic Disease
Hospital, as well. Alternatives on Long Island may warrant the reloca-
tion of the Hospital, just as those on Deer Island may warrant the relo-
cation of the House of Correction. This situation has been sufficiently
well identified in the SDEIS/DEIR that it need not be belabored. In
either case, a separate siting and environmental review will be required
following the selection of an alternative requiring relocation of either
of these facilities.
1.6
Determination
Baaed on the foregoing item by Item comparison of the SDEIS/DEIR to
the-scope required in ay Certificate on the ENF, I have reached the
conclusion that the document is adequate as a Draft EIR. Further, it
does provide the foundation and framework for reaching one of the most
important decisions concerning Boston Harbor to be made. It is not the
only decision to be made, as discussed below, but the siting decision
can be made and should be made as a step in the process of cleaning up
the Harbor. If we wait until all decisions can be made simultaneously on
perfect data (a falsely simplistic notion, in a complex and changing
world), no decision will be reeched for years or decades. The remainder of
this Certificate, therefore, deals explicitly with the question of segmen-
tation, describes the requlrementa that must be met for an acceptable Final
EIR, and reviews the decision process still ahead of us. •
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EOEA
SITE OPTION STUDY
PAGE 5
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2.0
The Question of Segmentation
Various coaaenta on cb« DEIR have asserted that It Incorrectly
segments out* and postpones for future examination, laauea which met be
reaolved to make a proper altlng decision. While EPA will rtspend to
thla laaue ae ralaed under federal law (NEPA), I will provide ay
perepectlve on thla laaue aa It la dealt with under the Haasachuaetta
Environmental. Policy Act, which I aa responsible for administering.
The primary policy reaaon egalnat aegaentatlon la that laproper
postponement of certain laauea will leave incomplete the assessment of
Inpacta of a declalon, or distort decision naklng. GausstIon la the key
factor. Uhere one declalon drlvea another decision, such that the uni-
verse of choice for the second declalon la reatrlcted by the first deci-
sion, then segmentation la disfavored. There are, however, countervailing
considerations. Segmentation can be a rational and neceaaery element of a
declalon Baking process, permitting a wlae ellocatlon of resources by plan-
ners. A logical and appropriate fora of segmentation, for example, la the
segmentation of the siting decision from plant design. Were this not per-
altted, then complete designs would have to have been prepared for each of
the siting options, et greet coat In time and money, even though only one
design would ultimately be used. Indeed, such segmentation permits greater
focus on the dealgn decisions when they ere ready to be made, and thus
increaaea environmental benefits.
Another form of desirable segmentation Is aeen In the preliminary
screening, which reduced 22 options to 8 options* This permitted focus
by the DEIR on more detailed environmental evaluation of a more limited
number of alternatives, and la to be encouraged.
At leaat one comment haa urged that the EIR evaluate, comprehen-
sively and simultaneously, all the actions needed to clean up Boston
Harbor: facility siting. 301(h), combined sewer overflows, dry weather
overflows. Infiltration and Inflow, satellite treatment, and sludge.
While such a comprehensive approach haa a certain global appeal. In
application it would render the process of evaluating and making all
clean up decisions so cumbersome as to cause Immense delay, to the great
detriment of the environment. Again, segmentation Is necessary and
EOEA 14911
BOSTON HARBOR SITE OPTION
PAGE 6
2.1 Sludge
Of all the concerna ralaed about segmentation, the most cogent Is
the belief that sludge treatment'and aitlng decisions ahould be a part
of the wastewater treatment siting decision. The historic baala for the
segaentatlon was noted in ay Scope. Since the Scope waa laaued, the EPA
has decided to prepare a new Sludge BIS (Draft BIS due December 1986),
and it has bccoae evident that new Dreft and Final Sludge EfRs ahould be
submitted, rather than juat a Final EIR, aa an adjunct to the 1976 Draft
EIR. Tola state of affairs relnforcee one argument in favor of con-
tinued segmentation of aludge: that putting the siting declalon on hold
until aludge decisions sre made will add significant further delays to
the siting decision, with consequent environmental hara. In fact,
though it la not cleer at thla point whether ocean dlsperaal of aludge
will be conaldered In the Sludge EIR aa one alternative, proper environ-
mental study of a new alte could take years*
The possibility of delay Is not, however, a conclusive argument for or
against aegmentatlon. If the present siting decision will have a oajor
Influence on the future sludge decision, then re-uniting of the separate
decialona auat be conaidered. Sludge optlona now under consideration
are: incineration, composting, landfllllng, and ocean dlsperaal. Ocean
dlapersal la by definition carried out off-Island, and each island hae
waterfront access suitable for a transfer terminal. Landfllllng must be
done off-site, because no Islands contain aufficlent area for a sludge
landfill, even If the vast environmental obatacles could be overcome.
Ground acceaa limitations would necessitate barging of aludge to a land
transfer terminal. Therefore, neither ocean dispersal nor landfllllng
options are affected by the altlng deciaion now before us.
Incineration has a sufficiently small footprint that It could be
accommodated on numerous sites, with or without the presence of a
waatewater treatment facility. To the extent that waatewater treatment
alting effects, the air quality baseline for licensing of an Incinerator.
It could affect an Incinerator siting decision. However, given the com-
mitment to use state-of-the-art odor control, air quality baseline will not
be significantly affected, and thus incinerator altlng is Independent of
wastewater facility aitlng.
For composting of primary sludge, acreage requirements.are such
that both composting and primary treatment could fit onto either Deer
or Long Island. For secondary treatment, however. It appears that plant
sice and compost volumes are so great that composting and wastewater
treatment could not coexist on either Long or Deer Island. Therefore,
once a waatewater secondary siting decision Is made, a composting option
would clearly have to occur elsewhere. Long and Deer Islands, however,
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PACE 7
are not (he only potential sites Cor ••condary composting, ao the only
aludge declaloa which a aecondary waatewater siting decision dictates Is
preclualoo of aludge composting fro* the Island chosen for the waatewater
facility.
Weighed against the enormous delay which relinking of aludge and
wastewatar siting would engender, the potential environmental coata of this
preclusion are negligible. Therefore, the continued separation of the
aludge and wastewater siting decisions la proper under State environmental
law.
2.2
Off-site Transportation
Coomentors have urged that the location end Impacts of barge ter-
minals oust be established aa part of this EIR, rather than deferred to
fO future design. As already noted, ay Scope has required that particulars
| of any terminal and staging srea be furnished. However. Identification
(sj and evaluation of a terminal alte or sltea are not a precondition to a
£h, siting decision, becauae auch land-side terminals could aerve any of the
altes under consideration - the only difference being In the costs of
variable travel time, which I an confident are so well within the margin
of uncertainty of facility coat estimates aa to make absolutely no dif-
ference In the siting decision. The location of feaaible and environmen-
tally acceptable teminale will undergo separate environmental review aa
design proceede.
3.0
ADDITIONAL REQUIREMENTS FOR THE FINAL EIR
Review of the extensive public comment on the Draft EIR also indicated
several other areaa needing additional attention In the Final EIR. These
Include limits on facility sice, details of and commitment to aaintenance
practices, the use of performance stsndsrds and monitoring, additional
Information on waatewater conveyance, air quality considerations, re-
examination of recreation potential, and engagement with the fairness
issue.
Facility Site
COEA 14911
SITE OPTION STUDY
.oading of the new facilities. The commitment to avoiding this even-
tuality should be discussed In the Final EIR and the techniques to be used
to assure agalnat it should be described. These might Include a mandated
flow reduction program to compenaate for new hook-ups, system-wide
Infiltration and Inflow reduction programs. Inverted block pricing of both
water and aewer service to promote conservation, and the commitment to the
use of satellite plants for any expansions of service beyond the existing
service district or expansion within the service district that cannot be
compensated for by flow manage ate nt practices. These techniques will also
have the additional benefit of reducing current overflow problems
throughout the interceptor sewer system, as 1 have required in the EIR* for
the Uelleeley end Framinghaa Extensions and for the New Neponaet Valley
Interceptor. Finally, soae discussion is needed of the Influence of these
flow management measures, which may increase average flow and decrease peak
flow, on the hydraulic sizing of secondary treatment.
3.2
Maintenance
The maintenance history of the existing plants also caused much public
comment and concern. Many abuttors to the exiatlng plants lack faith that
new plants can be less offensive than the existing plants or that suf-
ficient maintenance will be provided to assure the continued proper func-
tioning of the new plants and of their odor control systems. The Final EIR
should respond to this concern with a dlacuaalon of the maintenance
requirements for modern sewage trestment facilities, including the asso-
ciated coats, and with a firm commitment to a maintenance program.
3.3
Performance Standards
A related technique for aasurlng the; continued functioning of the
planta as designed (and of the proposed construction mitigation program) is
the use of performance standarda and periodic monitoring to provide an
objective measure of Impact and e criteria for initiating response actions.
Varloua commenters suggested both noise and odor performance standards that
might be appropriate for conaideratlon. The Final EIR ahould deal with the
use of performance atandarda, select viable and measurable parameters,
describe action levela for triggering response activity, and describe the
responses to eliminate the causes of noiae and odor events.
3.4 Waetewater Conveyance
While it la understood that the choice of tunnels or pipelines for
Inter-Island wastewater conveyance might not be made in time for full con-
sideration in the Final EIR, the potential for large amounts of spoil from
tunneling will need to be discussed in more detail. Conservatively, It
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EOEA 14911
SITE OPTION STUDY
PAGE 9
should be assumed chat tunneling will be chosen. For thla option, an estl-
•ace of the amounts of apoll should be prepared, along with a plan for
approximate ahaft locatlona and apoll removal routea. Because of the volu-
me • Involved, a demonatratlon almllsr to that for construction tutorial
barging should be made of the feasibility of tunnel construction without
the need for major trucking through the communities at each of the poten-
tial site*.
3.5
Air Quality
While the draft report has some discussion of dust, odors, and noise
which nay belong under an air quality heading, no dlacusslon of the
Illustrated scum Incinerator lapacta were found. What are their stack
heights? What air contaalnants are discharged? Are PCB*a or other toxi-
cants present In the exhaust? Will they be deatroyed at the propoaed
operation temperatures? What la the quality of the aah being produced?
Where would it be disposed of?
3.6
Recreation Potential
Wlnthrop realdenta have pointed out. with some justification, that the
treatment of potential recreation on Deer Island was given short shrift as
compared to the potential on Long Island. This question needs to be
addreased In two fashions In the Final EIR. First, the recreation poten-
tial at Deer Island should be described. Independent of recreation plans.
This will allow an equitable comparison of the two Islands. In this
discussion, both the benefits and the lopacts of recreational use should be
considered, since the use of either Island for a major regional recreation
facility could have adverse traffic Impacts comparable to those of sewage
treatment plant construction and greatly in excess of those of plant
operation. Finally, this discussion must come to grips with realisable
recreation potential, as well as plans. It would be unfortunate, to say
the least, if a decision were baaed on the proposed recrestional use of
Long Island and that use never came to fruition or were replaced by Inten-
sive private use o'f the Island.
3.7
Fairness
Although the question of fairness Is not amenable to quantification.
It Is of the greatest concern to the residents of Wlnthrop. In reaching a
sound and supportable siting decision, the Authority and the EPA must take
cognizance of this question. In the decision process, fairness must be
weighed in interpreting effects on neighbors, since background noise levels
are high In Wlnthrop and sources of community concern are numerous. In
assessing appropriate mitigation commitments, fairness must also be con-
sidered, especially as It might effect linked activities (prison
relocation), commitments on plant size, commitments on plant maintenance,
and questions of direct or indirect compensation to affected communities.
EOEA 14911
SITE OPTION STUDY
PACE 10
Many of the same issues will affect the residents of either community cho-
sen for this major regional facility. Awareness of and sensitivity to this
question may not reduce opposition to a siting decision, but It will repre-
sent a positive step towards limiting the negative effects of the siting
decision.
4.0
THE DECISION MODEL
Soae cotameat was received on the decision process, on the model cho-
sen, and on the weighting of the six decision criteria. It Is my percep-
tion that the weighted ranking or rating approach Is an appropriate
bookkeeping mechanism for the decision process. I stress that the process
is by no swans computerized. Rather, the decision makers rank or rate each
alternative against each criterion and then jointly determine the
appropriate weight to be assigned to each. It Is apparent that this pro-
cess, far from being mechanical, can be very sensitive to the values of the
decision makers and very responsive to the comments on the Draft EIR. I
expect that the debate of the decision makers will be summarised In the
Final EIR, that the weights assigned to each criterion will be explicitly
presented, and that summaries of the rankings or ratings will be prepared.
In addition, the Final EIR should clearly discuss the variations in
rankings, ratings, and weightings and .the sensitivity of the final decision
•easure to changea In both ranking (or rating) and weighting of the cri-
teria. If these data are provided in the Final EIR, then the bookkeeping
function of the system will have been served, the basis for the decision
will be clear, and the effects of other.value judgments will be apparent.
5.0
THE DECISION PROCESS
The foregoing discussion on the SDEIS/DEIR leads to the Important
point, which oust be underscored, that thia Is a siting EIR. It is a deci-
sion document. In the strongest sense. Rather than seeking to justify a
preconceived decision. It seeks to structure a reasoned process for
arriving at a decision of such complexity that It has bedevilled state,
federal, and local officials for over a decade.
Since 1983, this process has been carried out by joint efforts of
state and federal-officials. I have atteotpted to ensure the coordination
of disparate state agencies and interests so that all vlewa and interests
could be properly reflected in the decision which evolved.
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EOEA 14911
SITE OPTION STUDY
PACE 11
The welcome advent of Che Massachusetta Uacer Resources Authority has
Introduced a aejor new actor to the decision arena. Not only haa MURA the
reaourcea that will be needed to enter Into the clean-up efforts. It alao
Injects the eaaentlal element of aunlctpal and Individual volcea Co Che
decialon proceaaB The producclon of Che DE1R cane ac a transition between
Che aiclng efforts of an overburdened HOC and Che onaet of the WRA, and It
ia understandable ChaC MDC Involvement in lea own EIR document waa advi-
sory, not proactive.
Until due notification (301 CMR 10.16) la received, or until July 1.
1985. the MDC remains Che "proponent" of this project under MEPA.
Nonethelesst the responsibility for making a siting decialon la veated prl-
•arlly in the MJRA, subject to conscralnts impoaed by the potential for
federal funding and by the host of federal and state regulatory controls
laid out in the DEIR. The tURA haa not yet reaolved how it will make the
K> siting decision. In the opinion of chla office, however, the decision
| train which waa set in motion by the joint decision to prepare an EIR/EIS,
|NJ baa resulted ac Chls point in a aubatantial defining of issues, and a fra-
CT> mework for dealing with those isauea. By application of the decialon node I
In the DEIR, the Authority can determine for itaelf whaC additional Infor-
mation Is necessary before s decialon can be made, can generate that Infor-
mation (elcher Independently or with EPA), and can proceed Co closure on a
decision. While a altlng declaloo can no doubt be reached via a different
route, I urge upon the MJRA the view chac the proceaa now in motion offers
the best prospects for reaching a sound and early declelon on the siting
issue.
March 18. 1985
DATE ,
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BOSTON HARBOR SITING EIR/EIS
DRAFT MEMO
PAGE 4
BOSTON HARBOR SITING EIR/EIS
V. Odor Control - A separate section should review the technology for
odor control, describe the points in the treatment process where odors are
generated, and explain what fon»(s) of odor control are available for each.
Cost, reliability and any adverse effects should be commented on.
VI. Applicability of the above analysis to the various split configurations.
VII. Traffic Generation
Once the foregoing sections are done, the consultant should review and
confirm the continued applicability of the average and peak labor and material
traffic estimates presented 1n the SOEIS.
2. A less comprehensive, but nonetheless straightforward-and"clear.
to discussion should deal with spoil removal or disposition. You will recall that
I the SDEIS takes the position that all .spoil (excavation, tunnel, drumlln) will
K) either be used In project, redistributed on-slte, or barged off site. It Is
oo Important at .this juncture to determine the magnitude of this task, in order to
determine whether 1t may be left to later design.stages, or will pose costs or
difficulties which could materially affect'the cost and Implementabiltty decision
criteria. This Investigation should-proceed as follows:
1. Estimate for each alternative a likely range of spoil generated,
In three categories: (till, shot rock, clay/fine sediments).
2. Indicate the feasibility of disposing of such quantities on-slte.
Discuss whether this can be done without having to construct the
project on unsuitable or unconsolidated materials.
3. . For material which cannot be utilized or disposed of on-slte,
Indicate whether a ready market off-site, ex barge, exists for such
material. For materials which cannot be marketed, assess the cost
and permlttablllty of land or sea disposal.
3. Noise Levels - The noise monitoring presented In the SDEIS should be
expanded to present current, consistent ambient noise level determination at the
property line and at the nearest residences for each alternative site. Any
revisions to the noise Impact discussions resulting from these data should be
made. Although I cannot yet say whether this Information is essential to the sitii
decision, the Improved analysis should certainly be prepared for the FEIS.
4. Chlorlnation - The FEIS should include a focused evaluation of the -
ramifications of disinfection decisions. My general impression is that, for
treatment of large volumes of wastewater, chlorine gas is the only practical
alternative, and one has the option of manufacture on-slte or trucking to the site.
The U.S. Coast Guard previously advised HOC that barging In chlorine would not
be permitted. Decisions regarding Chlorlnation have potential effects on plant
size, traffic, and 0 t M costs. The following questions should be answered
1. Is water-borne transport of chlorine entirely out of the
question? What authority- does U.S. Coast Guard have to ban
it? What precautions could secure Coast Guard acceptance?
t
2. What volumes of chlorine are needed, at what points In the
treatment process? Do all alternatives require full-time
Chlorlnation (e.g.. night only seasonal Chlorlnation be
necessary for primary discharges?
3. What are the space requirements of chlorine generation on-slte?
• What are traffic requirements? Do the capital ana 0 & H costs
tally with costs in the SDEIS?
4. What are the traffic requirements of trucking in chlorine?
Do the 0 » M costs tally with the SDEIS figures?
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STAFF COMMENTS
COEA #4911 HOC DRAFT EIE-BOSTON HARBOR SITING OPTIONS
MARCH IS, 1985
DAVID SUEPARDSON, STEVE DAVIS. AND NANCY BAKER
EOEA #4911 - MDC DRAFT EIR
BOSTON HARBOR SITING OPTIONS
STAFF COMMENTS
PAGE 2
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Heaters of Che HEPA staff have reviewed Che SDEIS/DEIR document end
•upporctng dociwenta and Identified the following Issues which need to be
addressed la the FEIR.
Outstanding Issues;
A Qua be r of Issues must be evaluated In future KEPA actions unlesa
their discussions are expanded significantly and are found adequate In
the Final EIR. These sreas Include: (1) Selection of discharge loca-
tions and configurations, with water quality predictions for primary
and/or secondary treatment effluent outfaile; (2) Construction impacts of
connector pipelines or tunnels in the ocean between sites, including
the outfall; (3) Construction and dredging Impacts of barging termlnal(a)
as well as land side Impacts; (4) Sludge handling and dlspoaal
Impacts; and (5) Delivery of electrical power to Deer or Long Island,
if by aubaarlne cable.
Mitigation;
Th* Final EIR. in order to be deemed adequate, should Include a
commitment to mitigation which can b« asaured to be feasible. Failure
to assure these meaaures will nullify any analysea which are restricted
to scenarios which utilise the mitigation assumptlona. An example of
this is the traffic analysis of the drsft EIR which Indicates that
barging and busing hsve some problems, but states that they will be used
to the extent feasible. Without anchoring the mitigation, the traffic
analysis Is flawed. Other major areas to consider for mitigation
Include:
(1) Commitment to meeting water quality and operating
. atandards aa well aa SEIS/DEIR mitigation requirements.
Are EPA, DEQE and the MWRA committed to enforce or
asaure complete compliance with water quality standards
and guidelines as well aa mitigate coomunlty Impacts of
the facilities? This could go a long way In developing
community acceptance of any decision. This should
Include a cap on flowa which will not be exceeded. While
Volume I discusses the future flows of the South System,
no such discussion of the North System was found.
(2) Enforce I/I reduction and stormvater separation to
accomodate future sewage flow increases until new
treatment sites can be developed In the 43 contain!ty
system.
required to pretreat their affluent. The FEIR should
outline the current pretreatment program, discuss the
rate of improvement since HOC inherited the program,
indicate needed changes, and evaluate the changes to be
expected if the recommended program is Implemented.
(4) Make a commitment to initiate planning of satellite
treatment areas for future growth within the 43 community
system. Such AWT plants may need to be small, be located
at some distance from productive well fields and perform
a high level of treatment. Areas with minimal Industrial
contribution may have to be utilised. The facilities
should b« on-line before problems develop at the harbor
facilities.
Hater Quality/Marine Life
The draft report indicates potential water quality impacts based on
the current analysis but fsils to identify and evaluate additional miti-
gation. The report concluded that "...Water Quality criteria for toxi-
canta could be exceeded... under any alternative." This seems to
indlcats that Influent sewage quality, not plant upaets or storm flows.
is expected to cauae exceedancea. The FEIR should elaborate and discuss
the mitigation efforta which would be needed to eliminate or minimize
such sxceedances. The identity of the toxicants or other parameters
which may cause exceedance and their frequency of occurance ahould be
included in the discussion. The following questions should be considered
In this analysis:
(1) Footnote on II on page 11.3-11 suggests that treatment
planta of these sizes may not be able to meet the median
removal rates presented. Should s range be utilized
rather than the median?
(2) Do the projections assume s background concentration of
zero for each contaminant, aa suggested In several areas?
Reasonable background levels should be proposed and used
for harbor and deep ocean sites.
(3) Aasu
352
(3) Was the suggestion that the 301(h) waiver data were lower
than normal for contaminants due to sampling during wet
weather flows considered in the projections? How?
(4) Are there any limitations to the use of the desktop version
of MERGE that we should be aware of? This was the nethology
used in the initial dilution modeling.
mong 812 industries which are
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EOEA #4911 - HOC DRAFT EU
BOSTON HARBOR SITING OPTIONS
STAFF COMMENTS
PAGE 3
Traffic and Access
The Traffic and Access appendix, and by extension the text
of the SDBIS/DEIR, suffers from three shortcomings: a lack of detail In
the analysis technique, a lack of assurance in basis alligation asstrup-
tlonat and a lack of comparable measure* of impacta for each of the
three site access routes.
The prlnary analysis technique chosen for the traffic analy-
sis is a relatively simple description of sccess routes, their existing
traffic loads, and voluae to capacity characteristics of the major links
in each site sccess route* This is sulteble, as fsr as it goes. There
is, however, a need to Identify the najor Intersections and points of
constriction along each route over its entire length froa the regionsl
trsnsportstion networkB and to deteralne the voluae to capacity rela-
tionships at these and the level of service provided. In this fashion,
a note accurate understanding of the contrslnts on traffic flow could be
had. Such an analysis would support a more complete analysis of
iopacts, as discussed below.
The oldgatIon assumptions, discussed in Section 12.2.2, slso
provide cauae for concern. While the ststed Intent to use barging for
construction materials and busing for construction workers is laudable.
the recurrent phrase, "to the maximum extent feasible" does not provide
a level of confidence or certainty In the use of reduced trsfflc
estimates for impact assessment. In addition, while the assessment is
carried out based on the maximum number of construction worker buses to
be required, it uses the sverage dally number of construction material
trucks. For these reasons, several modifications sre needed to the
analysis and to the text of SDEIS/DEIH.
Much the same can be ssld of the analysis of impacts in the appen-
dix. Section 12.2.3 presents s genersl discussion of traffic Impacts,
but does not present those numericsl measures that would aid In quan-
tifying the impscts. Additionally, the impact descriptions are not
directly comparable. Specifically, the analysis would hsve been more
useful if it had presented volume changes and volume to capacity ratios
of the major links and the major intersections and points of constric-
tion along each of th
each site. It could
tors and the length o
Long Island and Nut I
of the relative impac
site access routes from the regional network to
Iso have discussed the number of residential abut-
the access route for Deer Island, as was done for
land. This would have allowed a better comparison
a of esch siting option.
EOEA I4V11 - KDC DRAFT EIR
BOSTON HARBOR SITING OPTIONS
STAFF COMMENTS
PAGE 4
These concerns can be addreaa in the Final EIR in the follwlng
fashion:
(1) Identify the key Intersections and points of constriction
along each site access path and provide existing traffic
data and voluae to capacity calculations for each.
(2) Document the achievable level of materials barging and
worker busing carefully, or analyse the worst case.
conalsting of truck delivery and automobile acceas.
(3) If mitigation Is documented, any analysis should Include
the Impacts of the maximum dally truck volume for those
materials that cannot be delivered by barge, not the
average number, and should take account of simultaneous
truck and bus traffic.
(4) In the Impact analyses, use route length. Impacted
residences, key Intersection level of service, trip
time, and other quantitative measures of Impact in a
comparable fashion for each of the access routes.
These supplemental data will remedy gaps In the analysis, will
assure that the appropriate "worst caae" la analysed, and will provide
comparable, quantified measures of impacts for each site access route.
Chlorine
The report Indicates potential Impacts from the transportation,
use, and discharge of chlorine to the ocean. More work Is needed In the
Final EIR to explore minimal levels of use, alternative control, or
neutralization. These Issues were addressed previously by MOC in the
CSO CIR (EOEA 13773). The Final EIR needs to explore fully alternative
delivery routes to the plants (I.e. barging or on-site generation).
Odor
The Draft EIR does not appears to take proper credit for covering
the facility and utilizing modern odor control, or the odor control
technology planned la not very effective. MDC la planning to use odor
control at Its headworks which should make the Columbus Park Headworka
compatible with the public park land on which the facility is located.
The assumption should be reviewed and the technology explained.
Additionally, the analyses utilise the area wind rose to suggest a
frequency of occurrence. We do not believe that the analysis
accounts for the coastal sea breeze which Is a regular phenomenon
on the harbor.
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EOEA *49H - HOC DRAFT EIR
BOSTON HARBOR SITING OPTIONS
STAFF COMMENTS
PACE 5
Noiae Analysis
The noise analysis, while 1C My not be crucial to Che siting deci-
sion, !• substandard In both Its description of the existing environment
The noise •ooltorlng program described la Section 12.6.1 Is based
on some historic data and soste data collected for the current effort.
These data are not directly comparable, since one set of dsts (that for
Deer Island) la expressed aa single field readings* while the other data
are ssore cooplete nolle statistics. The noise monitoring presented In
the SDEIS/OEIR should be expanded Co present current, consistent ambient
noise level determinations at the property line and at the nearest resi-
dence for each alternative site.
These revised data should then be used to sake any necessary revi-
sions to the noise latpact analysis In Section 12.6 and In the main text.
In addition, estimates should be prepared of the noise exposure of resi-
dents along the major truck access routesf should the results of revisions
to the traffic section show that the worse caae traffic voluaes are
substantially different than those discussed In the SDEIS/DEIR. This last
task could entail significant new work If firm commitments to mitigation
plans cannot be made.
Archaeological and Historical Resources Report and
NHPA Compliance Summary
The Phase I Intensive level archaeological survey adequately Iden-
tifies the likely areas of archaeological/historical sensitivity on Deer
and Long Islands. However, the maps of Long Island should be directly
comparable with match lines Indlcsted and consistent legend markings for
the specific levels of sensitivity.
Technology
We believe the EIS needs to provide for decision-makers fuller
Information on gross plant size, operation, component string, layout,
design alternatives, coat, and the Interelatlonahlp of those factors.
EOEA '4911 - HOC DRAFT EIR
BOSTON HARBOR SITING OPTIONS
STAFF COMMENTS
PACE 6
For example, consider the Issue of total acreage covered by secondary
treatment plant. Bow ouch can one do Co reduce Che acreage requirements
• etforth In Che SDEISt Indeed, are Che H5a D.I. estimate and Che 96a.
L.I. estimate computed using like assumptions? Can components be
shrunken, stacked, or put underground? Uhat does It do to cost? What
does 1C do Co reliability? Does Ic Increaaa potential for odor control?
Does 1C lessen visual impacts? Does Ic lessen impacts on recreational
potential? Docs it make a plane store acceptable to neighbors, and hence
increaae impleoentablllty? Do newer technologies affect plane
efficiencies? Do they Increase capltol or O 4 M coats?
We recognise that the EIS cannot be expected Co design a plane.
However, persons making a siting decision for a plane or plants of this
scsle sust have an understanding of the engineering feasibility of certain
design options. This should be conveyed in Che decision document, the
Final SIR.
Additions! page by page comments
VOLUME I
Fig. 1-2 Which Is Che Deer Island Sludge Discharge?
p. 1-15-20 The following points should be noted on the status of
Che six major projects involving Harbor clean-up.
(1) The 9 mile ocean dlacharge would require a MEPA filing and
an impact report.
(2) Further EIS/EIR actions are needed to resolve che sludge
management issue.
(3) The MDC CSO program has completed HEPA review (EOEA 13773)
except for poaslble project changes. Inclusion of che DEQE
. priority listing for future funding and the HOC construction
schedule might be enlightening.
(4) The status (goal and success) of che MDC pretreatment
program should be discussed.
A feeling for che status of these projects needs to permeate che
remainder of the report(a) aa too often the reader la left with the
Impression that the siting option is the only Boston Harbor clean-up
effort moving forward.
p. 2-23 To confirm the aasumpcion of available off-sice sludge
treatment locations, a brief list of viable potential sites should be
included.
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EO-.A 14911 - HUD DRAFT EIR
Bf.i >N HARBOR SITING OPTIONS
ST.lf ( COMMENTS
FACE 7
p. 3-1 The newly enacted legislation creating end controlling the
Massachusetts Hater Resource Authority euit be deecrlbed In the FEIR.
p. 3-13 The wind patterns Cor the eltee under discussion oust
Include the frequent aea bree»« effect. Thla nay change the potential
for population axposurs froa thac In the Draft. Thla should he carried
forward to all dlecutalona of odor la the documents.
p.3-25 The intersections which can not aecoaaodate additional
traffic efficiently should be Identified for ell options.
p. 3-26 The current preceutions involved In chlorine deliveries
should be discussed, ss well ss any past sccldents.
p. 3-30 The analysis should consider the total Marina Bay project
propoaed previously and filed with MEPA.
pp. 4-1*2 The water quality discussion Is alsleadlng because the
inability to aeet water quality standards and guidelines as discussed
in Vol. II is not carried forward to this discussion nor to the
Suaaary.
p. 4-10 There will be wetland lapacta if piers ere built st Deer
Island and Nut Island.
p. 4-19 Uhat wetland resources (ch. 131 Sec. 40) sre preeent at
the suggested fill sres off Nut Islsnd? Would any alligation be
oeededT
p. 4.20 Identify the extent of the needed buffer on eoae plan.
p. 4-30 The presence of nesting coaaon terns (rsre In Boston) on
the existing delapidated piers should bs noted. Mitigation as at the
Hog Island site aay be desirable. Kill erosion control (rip-rapping the
shoreline) be allowed for a new facility? (ch. 131 Sec 40 and ch. 91)
. p. 4-31 The non-updated 1972 plans should be discussed as well as
any change in. potential If the prlaon or STP were actually aoved.
p. 4-42 Include tern nesting on Long Island piers.
p. 4-79 Include tern nesting on the piers.
p. 4-80 Uhat alligation la available for possible Historic and
Archeologlcal lapacta?
p. 4-85 The Final EIR should have all the proposed altlgatlon sua-
aarlted In one location.
EOEA 14911 - MDC DRAFT EIR
BOSTON HARBOR SITING OPTIONS
STAFF COMMENTS
PACE 8
p. 4-88 Could part of the proposed Lynn pier be used for a staging
area?
p. 4-89 Doea the S.I.P. parking freese at Logan Airport (not to
aentlon severe traffic congestion) Inhibit Is availability for worker
perking?
p. 4-100 Itea 4.4.4 should Include all state regulatory filings,
including ch. 91, DEQE Air, Odor, and Noise regulations. Itea 4.4.3
should Include the Boston Conservation Conalsslon.
p. 4-101 Itea 4.4.4 - All of these lesues should be explored now so they
can be addreaaed If probleas exist.
p. 4-102 How will the energy be supplied? Generated on site?
Subaarine cable? •'
p. 4-102 Uhat type of sludge facility could be placed along side the
treataent facilities?? How auch additional acreage would be utilized?
p. 4-104 Beginning with the first full sentence and the coopletlon of the
paragraph Is a stateaent which should he pare of every suaaary prepared
for this project' until its conclusions change!
p. 5-7 Itea 5.6.2 should have a parallel discussion for the future role,
else..etc., of the North MSD.
Besed on the peek flowe currently experienced by the South MSD, It would
sppear that the next etep in planning for the South Systea should begin todayl
VOLUME II
SECTION 11.3 .- Uater Quality lapacts
pp. 11.3 - 1,2 "However, without further reduction of toxic aetals and
pesticides In the wastewster flowing to the propoaed treataent facilities.
water quality criteria for toxicants could be exceeded on occasion under any
alternative." Does this nean exceedances would occur even If no bypasses or
upsets occurred at the facility? Uhlch criteria would be Involved? This sta-
teaent should carry through all suaaarlesl How nuch reduction of Inflow levels
would be needed? Can the pretreataent prograa be realistically expected to
produce the required changes? How auch effort would be required? Are both the
Nut Island and Deer Island flows Involved?
p. 11.3-3 The Footnote Indicates that effluent solids have 4.8 to 25 ppa
PCB. Do such levels also occur In the ecua? Uhat Is their fate on
Incineration? At what levels?
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EOEA f49U - HOC DRAFT EIB
BOSTON HARBOR SITING OPTIONS
STAFF COMMENTS
PAGE 9
p. 11.3-4 Item 3 Indicate* chat a President Road* dispersal sice la
a lightly preferred due to higher current veloclclea but that the alte would
llolc Che length of any dlffuser. The FEIR ahould continue Che analysis of the
5 secondary sites, present the comparisons, and present a preferred dlsperssl
site.
p. 11.3-5 Will the chlorinatlon affect the harveaclng of ahellflah?
p. 11.3-11 If the HOC facility la not expecced to be able to reach the
•edlan efficiencies of Cable 11.3-3, (aee footnote II) what levels ahould be
expected? UhyT How does this change the projected water quality at the
dlaperaal site? Bow does the statements, page 11.3-12, that "MDC values sre
expected to vary fro* typical values because of the MDC*s high wastewater flow
and the high percentage of that flows which la infiltration and inflow." and
..." COD, total nitrogen and total phosphorus values at existing treatment
plants are based oo very small sample sices and cannot, therefore, be
considered statistically valid*", affect the expected dispersal
concsntratlonsf How does it change the needed mlnlmua dilutions?
p. 11.3-14 Why ia the Boatoa Harbor water asaused to have a background
concentration equal Co ceroT Are che same assumptions used at the 9 mile site?
How do the minima dllutlona change when the background 1 eve la are used In the
analysis?
p. 11.3-15 How are the mlnleua dilutions affected by these low data
reported to be due Co wee weather influences?
p. 11.3-19 Also indicates that Che effluent concentrations may be higher
than the reported data ("baaed oo percentage recovery of control samp lea") How
ahould the expected values be adjusted?
p. 11.3-29 Again states " at times, effluent dischargee at any of the sites
considered will cause ambient water quality to exceed State and/or Federal
water quality, criteria."I Criteria also may be exceeded for inorganic and
peatlclde compounds, particularly copper, cynide, and PCB's. This, I
believe, is based on the assumed sero background levels. How do the
conclusions change when the background levels are considered?
p. 11.3-29-30 The alternative disinfection methods and practices to mini-
mize chlorine's toxic effects on shellfish and the lopacts of chlorinated hydro-
carbon formation should be addressed In the FEIR.
p. 11.3-34 Indicates that limited sampling has found PCB concentrations as
high as 0.8 ppm In edible fish tissues, and that the health risk to humans who
consume local marine life is presently unquantifled. Are the suggested
pretreatoent changes expected to change these conclusions?
EOEA 14911 - MDC DRAFT EIR
BOSTON HARBOR SITING OPTIONS
STAFF COMMENTS
PACE 10
Section 11, Appendix A, last page * How can laboratories be allowed Co uti-
lize laboratory tests with limits of detection exceeding existing or proposed
criterlaf
Section 12.3 - Recreation Reaourcee and Visual Quality
Figure 2 ahould label che sandy beach.
p. 10 Item A.4 - Heating terna on the old piers should be Included. They
are rare In Boston Harbor* occuring ac only 3 aitea.
p. 38 Why will rip-rapping of major portions of che Deer Island shoreline
be required? How is this regulated by ch. 131 sec. 40 and ch. 91?
p. 41 - Why does che aite have to be flat? Couldn't elements be built Into
che existing terrain? What areas of shoreline will need to be rip-rapped?
Uhyf Again, how la this viewed by che agenclea responsible for regulatory
program*?
DS/SD/NB/bk
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S-lATEMENT OP SENATOR MICHAEL 10PRESTI, JR. CCNCERNING SUPPLEMENTAL DRAFT
ENVIROMENIAL IMPACT REPORT CM SITING WASTEWATER TREATMENT FACILITIES FOR
BOSTON HARBOR.
10
I would like to state from the onset that I am adamantly qncnsed and
^2 !„..
irrevocably committed to prevent all further expansion of the sewerage -~~
treatment facilities at Deer Island. Therefore, from the options made
available in the recently released SDEIS, I can only consider supporting
2b.l, the alternative that would require all secondary facilities on Long
Island.
I think it is clear that not everyone involved with the preparation
of the SDEIS shares my opinion due to the fact that the study actually
lays the ground work for further expansion of the Deer Island treatment
facility. The study is biased in favor of preserving the only
alternative site for the plant, Long Island, for other developmental uses
which still are undefined at this time. I am secure in stating this for
the record, when six of the seven .siting options that have been proposed
call for building a new sewerage treatment facility that will at least
double the size of the existing facility on Deer Island.
let us consider the impact of such an expansion on Deer Island to
the surrounding coiminities of Winthrop and East Boston. The present
sewerage treatment facility is located only a few hundreds yards from
Winthrop itself. There is only one access road to Deer Island which runs
directly through the town frcm what is Saratoga Street in East Boston.
Traffic congestion, noise, air pollution and environmental health factors
as a result of the airport and tunnel proximities are already of a great
concern to the residents of East Boston and Winthrop. Impacts from any
construction on Deer Island would realistically only aggravate already
intolerable conditions in Winthrop.
The study places conditions on the alternatives to be considered to
minimize these adverse impacts, the barging of construction materials to
the site in question and the busing of construction workers to the
nmxim.ii extent feasible, have been made a major premise of the study.
Yet, these assurances are hollow ones, indeed, when neither the EPA nor
the Gonmonwealth can at this time make such guarantees of the
implementation of these costly mitigation measures. The SDEIS clearly
states that these measures are necessary because of the 'unacceptable,
adverse and unavoidable site impacts,* but where are the guarantees that
this will be strictly adhered to or enforced? It will no doubt rest with
Winthrop to try to enforce these measures with no penalties set down for
enforcement. Also, where is compensation addressed in the study to the
affected communities for the Increased use of fire and police personnel?
Nowhere! Die cconunlty of Winthrop is already sorely overtaxed by the
need for fire and police personnel to service the Deer Island
Correctional facility and sewerage treatment plant.
Fran my statements thus far, I would not want it to be construed
that I am not concerned with the pollution of our harbor. Boston Harbor
is an economic and esthetic resource that is being continually threatened
due to contamination by both domestic and industrial pollutants, all in
violation of both state and federal law. But, we must prioritize the
steps necessary for a clean and healthy harbor. Would we want this
accomplished at the expense of a whole community; namely, Winthrop? Will
East Boston have to endure yet another health hazard from increased
traffic, air and noise pollution as well. The equities must be balanced
in making such a monuuental decision.
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Wlnthrop has been burdened through no fault of its own by the
sewerage treatment plant with its stench and noise. It must also endure
the ever present threat of the expansion of the number of inmates at the
correctional facility despite the fact the number of these escaping each
year continually rises and the facility is in a state of total disrepair.
Eist Boston and Hlnthrop oust also contend with the constant stream of
airplanes frcra nearby logon Airport. Tb even consider further expansion
of the treatment facility at Deer Island is an insult to the ocranmity of
Hlnthrop. Wlnthrop cannot afford to be burdened by yet another 'regional
problem.*
The issue of situating a treatment facility on long Island has been
clouded by the questions of whether, in fact, the Island is to be
preserved for purely recreational use, and whether the hospital will
remain on Long Island. Tt> address the Issue of the hospital, past and
present city administrations have considered closing the Long Island
ttospital. Hie most recent facility review, conducted in 1984 for the
administration of Boston Mayor Raymond Flynn, examined a 5-year plan to
reorganize the provision of medical and social services to the City's
chronically ill, homeless and elderly (Boston in Transition, A Program
and Policy Analysis, January 20, 1984). This plan proposed closing the
Long Island Hospital In 1989 and consolidating operations with the City's
existing chronic care facilities at the Mattapan Hospital, tto future use
for the hospital facility was Identified, arej further study was
reoonmended.
The prospect of restricting Long Island strictly Cor recreational
use is also questionable. In fact, it has been suggested that luxury
condoninimums are to be built on the site!
How can we, as truly concerned and fair-minded individuals, place
more emphasis on nebulous plans which cater to an unidentified
population, than on the existing needs and concerns.of an established and
vital community such as Wlnthrop?
To utilize option 2b.l would convert the 26-acre Deer Island
treatment plant into a pumping station and headworks of about 5 acres for
north system flows. The 12-acre Hut Island Treatment Plant would become
a 2-acre headworfcs for south system flows. The drumlin on Deer Island
would not be leveled thereby maintaining a prominent topographic feature
of the site and a landmark for the harbor channel. The treatment site
would, therefore, remain screened from nearby residential areas. Tne
visual quality of Nut Island would also improve thereby affording Quincy
residents on Quincy Great Hill some relief. Tne property values would
not decrease and the quality of life oould only improve for these
residents who have been overburdened long enough.
The residents of Wlnthrop can take solace and, yes, pride in the
fact that they have gone well beyond that responsibility. They can do no
more. They can sacrifice no more for the quality of their lives. It is
time Cor other comunlties to make the sacrifices and to fill the void in
environmental responsibility Cor our Conmonwwealth.
•As the Senator who not only represents Winthrop, but Cong Island as
well, my comment concerning this SDEIS is, 'Long Island and not Deer
Island'.-
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t-SAe vMMmo/t&ea&M of t/p£em
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THOMAS F. SHOWNCU.
C-UHMAM NOOM IM STATt HOU*C
COMMiTTM ON JUDICIAL »0«TON MA Oll»
1HO NOft'OLK OtrrHICT QrrtCt . VXt-aJM
)• MOHILANO MOAO
OUINCV. MA OlIU
March 6, 1985
Mr. Michael R. Deland
Regional Administrator
Environmental Protection Agency
JFK Federal Building .
Boston, MA. 02203
Dear Mr. Deland:
As a representative of Quincy, the most severely impacted commnity in
the Metropolitan Sewer District, I appreciate this opportunity to raiment on
the subject of siting wastewater treatment facilities in Boston Harbor.
Let me begin by stating that the overall approach you are now using to
determine where the new facilities will go is a good one. It makes sense
to determine which criteria are most important in regards to making a decision
based on environmental impacts. By and large, the criteria you have adopted are
extremely relevant to this discussion. In my view, by using those criteria,
applying the appropriate weights to each criterion and looking at impacts
as described in the Supplementary Draft Environment Impact Statement (SDEIS),
the inescapable conclusion is that Nut Island should be dropped as a site
option.
I believe that the statement clearly demonstrates that any option involving
Nut Island would severely impact the people and environment of that area while
not providing any significant benefits to Deer Island, its proposed counter-
part in wastewater treatment. As the report states, options involving the
two islands in combination would have effects that are "virtually identical"
to options entailing consolidated treatment at Deer Island, lhat being the
case, it makes absolutely no sense, from any standpoint, to site a treatment
facility in Quincy, regardless of the required level of treatment.
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Options involving Nut Island require either filling in Quincy Bay or
taking ten or more homes by eminent domain. In order to establish a buffer
zone equal to that which can be accomplished at other sites, you would have
to take all of Great Hill. Creating such a buffer zone would, in itself, cause
tremendous hardship and disruption to all of the residents in Houghs Neck. I
ask, on the basis of fairness, can you justify making ten families abandon
their hones, just so that we can treat the'sewerage from such far away towns
as Framingham and Ashland? The answer should be obvious. Not when other
optijons are avail&bXal
Me cumot emphasize enough the demographics of the area and how these
proposals would adversely affect the comuntiy. There are 180 homes within
a half mile of Nut Island and the two lane access road, Sea Street, is lined
with three churches, an elementary school, and numerous other connunity
facilities. Past Sea Street, there is Sea Avenue which is only 22 feet
wide and has an extremely steep grade that will pose enormous, difficulties
to trucks and buses travelling over it. Clearly, the traffic and construction
impacts of options lb.2 and 4b.2 would impose great social, financial and
environmental costs onto the nearby citizens and should be given the highest
consideration.
Using your criteria, the main reason we oppose the Nut Island options is
ho«-jiiiy» of their impacts on the neighborhood of Houghs Neck. This criterion
should be given a weighting above all others. However, filling in the bay
has serious ecological implications as well, therefore, the environmental
impact criterion should also be given strong consideration. Now, it is
not by coincidence that neither of those two actions is possible without
the prior approval of the General Court. Chapter 296, Acts of 1977,
specifically prohibits filling in Quincy Bay. Chapter 272, Acts of 1984,
the Hater and Sewer Authority Act, strictly limits the eminent domain powers
of the new Authority. I sutmit that the Nut Island options are in a practical
sense the most illogical and the most difficult to implement of all the alter-
natives before you.
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K>
From our perspective, the easiest part, and therefore, the next part of
this whole process should be to reduce the muter of options "on the table"
from seven to five by deleting those involving Nut Island in any capacity
other than that of a headworks. As for primary treatment, the report clearly
demonstrates that Deer Island would not benefit by splitting treatment with
Nut Island or Long Island to a degree commensurate with severe adverse impacts
on those other sites. Consequently, I must support consolidated treatment
at Deer Island. In «•«"•"*» of cost, neighborhood impacts, and environmental
impacts, option 4a.2 should be the choice for primary treabnent.
In the case that the MDC is not granted the 301 (h) waiver from secondary
treatment, we are basically faced with consolidating facilities at either
Deer or Long Islands, or splitting treatment between the two. The option
which would place all secondary treatment works on long Island cannot be
supported on the grounds that it would severely impact the Squantun comunity
during and after the construction period. Siting such a huge facility
on Long Island would also preclude the possibility for including it into the
Boston Karhnr State Park system, the aesthetic and recreational values of
Long Island are many and could be enjoyed by hundreds of thousands of visitors
each year. From an overall regional planning perspective, it would be a
poor use of land to place a treatment facility at Long Island.
Just as importantly, it must be realized that the Long Island options
will be extremely difficult to implement, a crucial issue that must be resolved
if we are ever to begin the process of cleaning up Boston Harbor. The City
of Boston owns Long Island and will resist the Conroonwealth's efforts to obtain
it for the purpose of putting a treatment plant on it. The Mater Resource
Authority's lade of power to acquire land by eminent domain applies to Long
Island, as well as to Nut Island. Since Long Island contains wetlands, dunes,
and barrier beaches, the Authority would also have to deal with those very
important ecological issues. The obstacles to placing a treatment plant
on Long Island are valid and should not be discounted in coming to your final
decision.
Finally, one cannot put aside the fact that consolidating treatment at
Deer Island is also the least expensive option. If we are forced into providing
secondary treatment, it would cost from 55 to 145 million dollars more to put
facilities at Nut Island and Long Island. It is my concludion that based on
neighborhood impacts, environmental impacts, and cost, that the preferred options
should be la.2 and 4a.2, consolidated treatment at Deer Island.
Nonetheless, in deference to the citizens of Winthrop, I oust qualify my
support for those alternatives. Many years ago, someone made an extremely poor
and myopic decision to centralize sewerage treatment plants for the metropolitan
district at Deer Island and Nut Island. Me have been told by engineers and
planners that siting a major plant on the Harbor is necessary and unavoidable.
However, in the future we can and must construct satellite treatment plants,
whereby inland communities will have to treat their own sewerage. Our ultimate
goal should be to downgrade the facility at Deer Island. My office is currently
studying this issue and we may file legislation to pave the way for decentralizing
and reducing the size of the Metropolitan Sewer District. That should be of
benefit to all harbor municipalities, including Hinthrop.
I am also in favor of granting any host oamunity a wide and generous amount
of mitigation measures. Winthrop and/or Quincy should be compensated fully
for treating the sewerage of 2S million people. The measures I have in mind
include those that ought to be included in the new plant's design and those
that will relieve the financial burden on the host community. Specifically,
I point to legislation that I have co-sponsored along with Representative
Marrissey that would free a host community from the responsibility of paying
sewer costs. This concept should be expanded further and the Metropolitan
Hater Resource Authority should becone legally obligated to pay host communities
a substantial amount of money in lieu of taxes.
Finally, in regards to the fairness issue, I don't think it makes any sense
or is equitable to require Quincy residents to share the misery of siting a
sewerage treatment plant in their city. Making Quincy a site to spread the
misery simply does not make the siting decision a better one. The unalterable
geographic fact is that the only sensible choice is a consolidated secondary
or primary treatment facility at Deer Island, because it can be built more
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cheaply, in the least mount of time, and with an acceptable level of
economic and environnental impacts.
to
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TOMS P. BRDWffiLL
Chairman
Oooraittee on the Judiciary
TFB/nap
OCi Secretary James S. Hoyte
EXECUTIVE
OFFICE OF
COMMUNITIES &
DEVELOPMENT
MJdad S Dukakis. COWIKH
?' Amy S. Anthony. Sccmaiy
(torch 8, 198S
Mr. Michael R. Deland
n»«j<™»i Administrator
U.S. Ehvironmental Protection Agency
J.F.K. Federal Building
Boston, MA 02203
BE: Boston Harbor Treatment Facility
• Mr. Deland i
tttt Massachusetts State Clearinghouse has received the Draft Qiviron-
nental Inpact Statement on the Siting of Hasteuater Treatment Facilities
in Boston Harbor.
As the Governor's designated State Clearinghouse, a brief sunnary of
this notice/proposal was published in the Review Monitor which is dis-
tributed to over fifty state agencies. Any interested agency was provided
with the opportunity to evaluate this plan for consistency with its par-
ticular policies and objectives.
Thank you for your cooperation during this review.
Sincerely,
Bilaire
Assistant Secretary
Executive Office of Conmjnities
and Development
GStH/jms
100 Cambridge Street
Boston. Maauhusefls 02202
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Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department of Environmental Management
March II. 1985
-2-
100 Cambridge Slmt
Boston
Massachusetts
02202
Office ol the
Commliirnocf
ro
I
to
Michael S.Dukalui
Governor
JamaS Hoylc
Secretory
J«m«* Guicnsohn
Commmioner
Hlchael D«land, Regional Director
Environmental Protection Agency
JFK Building
Boston, ha. 022IJ
Dear Dlrectoj
letter Is In response to the draft Environmental
Impact Statement and draft Environmental Impact Report on
Siting of Wastewater Treatment Facilities In Boston Harbor.
Many questions remain unanswered by this draft EIR/EIS.
Clearly, the decision on siting a plant must take more into
account - such as what kind of treatment Is best for the
Harbor clean-up and for the communities that surround It.
We believe the question of the HOC waiver application must be
answered before a siting decision Is taken and more considera-
tion must be given to the question of sludge disposal. An
Integrated approach to resolving all these issues Is essential
to the clean-up of the Harbor Itself, the well-being of the
communities, and the quality of life for the citizens In the
greater Boston area.
As steward of the Boston Harbor Islands State Park, a
unique natural resource, the Department of Environmental Mange-
ment Is most concerned about the condition of the Harbor, the
quality of its water and the aesthetics of adjoining lands.
The benefit which will be most directly experienced by the
public from the clean-up of the Harbor Is the reclaimed recrea-.
tion resource of the Harbor. But we are poised to ransom a
significant part of the public benefit from this Harbor clean-up.
Long Island -- the largest, most beautiful island in Boston
Harbor, and the only one accessible by car -- is one of two
remaining sites being considered for the sewage plant.
We should be under no illusions. Locating a sewage treat-
ment facility on Long Island will prevent its development into a
major park.
RECEIVED-EPA
MAS 1 o 6,5
WATE3 QU.4.UIY KJ.SCH
And the Implications of this are most significant. It Is clear
from the draft EIR/CIS that the objective of the siting decision is
"to select final siting options that minimize the Impacts of the
facilities on natural and cultural resources.'* Sec. 2.6.k,(P. 2-30)
and that "maximize the reliability of the entire treatment system."
(P. 2-31) The draft EIR/EIS demonstrates both rhetorically and
graphically the importance of Long Island to the overall recreational
viability of the Harbor and to the quality of life In the greater
Boston Metropolitan area.In fact, it Isof great significance and
consequence to the Commonwealth. Today, 71t of our coastline Is
developed for commercial. Industrial and residential use; 22% is
publicly owned;*nd only 6.54 Is undeveloped.
The demand for access to the coast - to water and the recrea-
tional and aesthetic good that comes from this experience - is great
and not likely to diminish. Yet a 1975 study fay the Division of
Coastal Zone Management Indicates that 87$ of the demand for swimming
by Metropolitan Boston residents alone cannot be met. Clearly, the
social Implications of this are not Insignificant. Most Inner-city
children In Boston and the other Harbor communities simply cannot get
to the waterfront in the summer. There are few places to go. Most
are overcrowded. It Is expensive to get there. So the children play
In vacant lots and on asphalt and open hydrants.
Although the Metropolitan District Commission now operates 17
beaches they do not meet demand. They are located in densely populated
and highly congested areas which severely detracts from the quality of
the recreational opportunities they provide and forces city residents
to go elsewhere for recreation. Long Island Is easily accessible by
public transportation and provides 2\k acres of beachfront and open space.
Long Island offers what no other land parcel In greater Boston
can: direct access to the sea and the islands that are unique to the
Massachusetts experience. When developed for recreation, Long Island
can comfortably accommodate 3.500 visitors per day - that Is three
million five hundred thousand men, women and children over the summer
season.
This accommodation is needed - and It Is needed today. Our
peoples' quality of life and that of our children in the future can be
severely compromised by the loss of this opportunity. Being in touch with
nature, having the opportunity to separate ourselves from the man-made
environment to experience the fullness of nature Is essential to man's
sense of well-being and harmony. DEM last year completed a statewide
survey of recreational demands. It showed that swimming, nature walking
and bicycling are the three most popular recreational activities in
Massachusetts - and the opportunities for all of these are severely
limited In the Boston MetropolI tan area. Long Island offers the potential
to further develop them all.
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As you know, Che Department of Environmental Management is
prepared to incorporate Long Island Into the Boston Harbor Islands
State Park and commit resources to develop Its recreational potential.
The City of Boston has Indicated Its desire to see this potential ful-
filled and to continue the hospital and homeless shelter facilities
now on the Island. (See attached letter to me from Mayor Flynn.)
In closing, let me re-state my strong view of the need for an
Integrated solution to the Harbor clean-up question. The recreational
Impacts of siting a facility on Long Island are Indeed severe not only
In and of themselves but as they relate to our reason for cleaning up
the Harbor in the first place. Are we really going to spend $1 billion
to clean up a Harbor and at the same time prevent people from enjoying
It?
JG/J
Enclosure
cc: Secretary James S. Hoyte
S. Hygatt, MEPA
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The Commonwealth of Massachusetts
Office of the Secretary of Stale
Michael Joseph Connolly. Secretary
Massachusetts Historical Commission
Valeric A. Talnufe
£w< unvr Otienor
.V/oif Hnltirn Prritrvalion Olfuer
Mr. Michael Deland
March IS, 1989
Page 2
March 15, 1985
He. Michael Deland
Regional Adminlatration
Environmental Protection Agency
J. T. X. Building
Beaton, MA 02201
BE: Boston Barbor Haetewatar Treatment raeilitlea SDEIS
Dear Mr. Deland:
Staff of the Massachusetts Slstorical Commission have reviewed the
Supplemental Draft EIS/EIR on the altlng of waatewater treatment
facilltlea in Beaton Barbor. Thia review haa been conducted in
compliance with section 106 of the National Biatoric Preaarvatlon Act
(X CfR 800), MEPA, and H.G.L. Ch.9, aa.26C and 27C.
The Deer laland aewer pump atation and the Long laland Bospltal
complex appear to be eligible for nomination to the National Reglater
of Biatoric Place*. The archaeological propertlea located on Long
laland are algnlficant contributing elementa of the Boaton Barbor
Archaeological Dietrict, which alao appeara to be eligible for
noalnation to the National Regiater. The deacrlptlon of the effecta
of the varloua aiting alternatives Included In the SDEIS/EIR appeara
to be adequate.
The alternatives proposed on Hut laland will not affect significant
cultural resources. The propoaala which include Deer laland may
affect the Deer laland aewer pump atation. The alternatives which
Include facilities on Long Island would adversely affect the
archaeological aitea and/or hoapltal complex.
Alternatives which avoid, minimize, or (litigate the effects of the
project on historic and archaeological properties eligible for
Inclusion In the National Reglater should be considered by the EPA In
the selection of the preferred alternative.
The SDEIS unjustifiably describee section 106 review a* an obatructlon
to project development. To the contrary, section 106 review
procedures establiah a consultation proceea whereby the public
benefits of a federal project are carefully weighed. The acceptance
of an adverae effect to significant historic resources may occur If
the public benefits outweigh the loss of the resources.
If you have any questions concerning these comments, pleaae feel free
to contact Brona Simon at thla office.
Sincerely,
Valerie A. Taloage
State Biatoric Preaarvation officer
Executive Director
Maaaachuaette fliatorlcal Commiaalon
James Boyte, COEA, MEPA Onlt
William Geary, HOC
D. Null, ACBP
BS/VAT/mmd
3U Bmbton Slrcct. Boston. Mj»jt:hUM:M>lOI Id IM?t "27
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Metropolitan Area Planning Council
IIP Tremont Street Boilon. MlinchuttlU 02108 (617I-4S1-2770
Serving 101 Cine) A Towns m Metropolitan Boston
March 13. 1985
The Honorable James S. Hoyte. Secretary {Vfft i ';, h3»-
Executlve Office of Environmental Affairs
100 Cambridge Street
Boston. MA 02202 -
ATTN: MEPA Unit
RE: Supplemental Draft Environmental Impact''statement/Report on Siting of
Uastewater Treatment Facilities for Boston Harbor (KAPC ISDEIS-85-21.
received February 4. 1985) EOEA 14895 j
Dear Secretary Hoyte: I
In accordance with the provisions of Chapter 30, Section 62, of the Massachusetts
to General Laws, the Council has reviewed the Supplemental Draft Environmental
I Impact Statement/Report PSDEIS") referenced above and offers the following comments.
^ After many years of delay, the Commonwealth and EPA have embarked on a decision
process which Is designed to bring about the necessary Improvements to the
metropolitan Boston wastewater system and bring the system into compliance
with the Clean Water Act. A central part of this undertaking Is the siting •
of new treatment facilities, and the Council strongly supports such an effort.
Within the confines of the scope established for the SDEIS, the document presents
a thorough analysis of the Impact of the siting options on natural resources
and on neighboring communities. However, given the burden of Impacts on the
potential host communities, the option of satellite treatment plants in upstream
sections of the service area should have received full consideration along
with the harbor locations. Even If technical, environmental, or economic constraint;
would ultimately rule these options out, their advantages and disadvantages
should be clearly compared with those of the harbor-site options in the SDEIS.
This Is necessary in the Interests of equity in distributing potential adverse
Impacts, as well as for building public confidence and support for the decision-
making process and the final recommendations of that process. Accordingly,
the work which was done on satellite plants and published In an Appendix, which
was not widely distributed, should be reformulated and incorporated into the
main body of the Final EIS/EIR, so that this option can be compared on an equal
footing with the harbor site options.
Another source of concern Is the fact that the siting decision Is preceding
1n Isolation from other major system-management and development decisions,
particularly the Issues of level of treatment and methods of disposing of sludge.
This is the result of unfortunate timing rather than by design. Nevertheless,
these two Issues may have a major impact on siting due to the differences in
-2-
envlronmental Impact, alligation, and cost. It would seem reasonable to resolve
these Issues before a final siting decision Is made. In the case of the level -
of-treatment Issue, the | 301 (h) waiver decision will be made before the final
EIS/EIR Is prepared, and the SDEIS considered both primary and secondary options,
either of which can be carried forward Into the final draft. But In the case
of sludge management, the SDEIS declared that this Issues does not affect siting
and therefore can be considered separately. The Council does not concur In
this view, as sludge management Is an Integral part of any treatment system
to be located on any of the proposed sites, and the Impacts will vary greatly
depending on the method of sludge management chosen. Methods currently under
consideration Include composting. Incineration, ocean disposal, and landfill ing.
Incineration In particular would create Impacts which would greatly affect
the public acceptance of a proposed site for the treatment plant. Other sludge
options may also have Impacts, such as truck traffic and odors associated with
them. Further, the Interplay between the waiver and the sludge decisions has
Implications for the siting decision. If secondary treatment Is required.
more than twice as much sludge will be generated.
Whichever site option Is ultimately chosen. It Is Imperative that full mitigation
measures be adopted as a mandatory condition of approval. This should Include,
at a minimum, full barging of materials and busing of construction workers
to the site, coordination of the timing of bus and truck trips to avoid conflict
with the dally commuting of school children, odor control, and, In the case
of the primary treatment option of Deer Island, the siting of facilities south
of the drunlln to Increase the buffering from the comnunity.
If Deer Island Is chosen, further compensatory measures should be actively
pursued, particularly the relocation of the Deer Island prison.
Comments received from Zl MAPC representatives from HOC comnunities are attached.
Sincerely,
B. Bard
General Counsel/Assistant Director
JBB/MP/mlm
cc: Michael R. Del and. U.S. EPA
William J. Geary, HOC
MAPC Representatives from HOC member comnunities
Martin Pillsbury, MAPC
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CO
Metropolitan Area Planning Council
110 Tremont Street Boston, Massachusetts 02108 (617MS1-2770
Serving 101 O'ties & Towns in Metropolitan Botton
February 4.. 1985
DEIR-BS-21
MAR-4B85
Junes E. Lydon
TO: .
JFfll In Nam)
COMMUNITY: Cltv of pulncy. Has*.
inn in coanuntty)
Enclosed Is a description of thi projtct referenced below.
Th« Council requests that you consider whether this report adequately
describes the project's Impact upon your coonunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS DEADLINE. VOUft COMMENTS MUST BE
RECEIVED AT THE HAPC BY March 5. 1985
Metropolitan Area Planning Council
110 Tramont Street Boston. Massachusetts 02108 (617M51-2770
Serving 101 Cities I Towns in Metropolitan Boston
February 4, 1985
DEIR-85-21
TO:
Robert E. Noonan
MAR-5B65
COMMUNITY:
(Fill in Name)
Town of Ulnthrop
(rill in tonnunity)
Enclosed Is a description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your comnunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Uastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS (KADIINE, YflUft COMMENTS .MUST BE
RECEIVED AT THE MAPC BY March 5. 1985
1\ x ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
MERITS FURTHER ENVIRONMENTAL STUDY
NEED MORE INFORMATION
EXPLANATORY COMMENTS:
The Supplementary Draft Environmental Impact Statement completely Ignores
the Impacts sludge and sludge management.
I strongly believe that the whole Issue of sludge 1s a crucial element 1n
emplorlng all alternatives for the siting of wastewater treatment facilities.
Sludge generation and disposal requires an In-depth study so that the
potential Impacts can be determined and.assessed, and should be Incorporated
Into the SOEIS.
I also feel that the Impact of sludge, combined with siting and the request
for a "301(h) waiver application* should all be considered at the same time
to adequately assess the entire environmental Impact.
SIGNATURE:
DATE:
,it*
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
MERITS FURTHER ENVIRONMENTAL STUDY
1\ NEED MORE INFORMATION
EXPLANATORY COMMENTS:
Our review of the SDEIS Indicates that the document merits further
environmental study In a number of areas. Including noise, odor and water
. quality. The Wtnthrop Board of Selectmen are In the process of preparing
a critical analysis of the document based on the findings of the Town's
consulting engineer. A copy of this document will be forwarded to HAPC
under a separate cover later In the week.
SIGNATURE:
01 Harch 1985
fVtUiam C i»wvf*. Vict-Prnnlent
funk 1. fli.tet. $exrcti<>
A. S'jctv. Tre«i
C. i**y«f.
* A. 8/Mv, Tw
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Metropolitan Area Planning Council
110 Tranont Street teuton. MjinchutatU 02108 (U7M51-2770
OEIR-8S-21
Serving 101 C$»-£-TbttHs in Metropo/ilan Boston
PralS 9l2W'lfc
RECEIVED
MAR-1B65
February*. I9a5t,'lt 3 CF/:CE
Metropolitan Area Planning Council
110 Tremont Street Breton, Mauachmctu 02108 (617M51-2770
Swing 101 Civet A Towns in Metropolitan Boston
February 4.. 1985
DEIR-85-21
TO:
PAuL
TO:
COMMUNITY:
...
rill in NameJ
RECEIVED
MAR-5S85 .
Vf/, ,
((•ill in coomunUy)
Enclosed Is a description of the project referenced balm.
Tht Council requests that you consider whether this report adequately
describes the project's Inpact upon your community and addresses
significant environmental benefits and potential damages.
COMMUNITY:
in toomunlty)
Enclosed Is a description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your community and addresses
significant environmental benefits and potential damages.
to
I
PROJECT TITLE:
Siting of Hastewater Treatment Facilities for Boston Harbor
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS DEADLINE. YOUR COMMENTS MUST BE
RECEIVED AT THE MAPC BY March 5. 1985
THE COUNCIL HAS ONLY 20
E.O.E.A. TO MEET THIS"
RECEIVED AT THE HAPC BY
ENDAR BAYS TO FILE COMMENT WITH
INE. YOUR COMMENTS MUST BE
March 5. 1985
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
MERITS FURTHER ENVIRONMENTAL STUDY '
II NEED MORE INFORMATION
EXPLANATORY COMMENTS:
I have examined the Information contained In the report, have reviewed tha varioua
option! contained therein, and I u la(t with the dlatinct impraaaion that tha raport
praaaatad tha data in auch a Bannar aa to ataar tha reader towarda tha option of eitinq all
(aellitlaa at Daar Island.
It nay vary wall prove to b« that Deer laland ia tha optinua choica (or tha aatinq of
tha prinary and, if naad baf aacondary treatment facllitiaa. However, thara ara nany
laqltlnata concerna and objactione to Oaar laland which cannot limply ba paaaad ovar.
It ia my opinion that further atudy of tha aitinq optlona and thair impacta ia warranted
I feel that tha conclualona contained in the atudy by C. B. Haquira are open to question
becauae of a lack of objectivity reqardinq tha aitinq altarnativea.
SIGNATURE:
DATE:
\ I AOEQUATaY DESCRIBES ENVIRONMENTAL IMPACTS
MERITS FURTHER ENVIRONMENTAL STUDY
II NEED MORE INFORMATION
EXPLANATORY COMMENTS:
The public hearing process associated with this Draft Environmental Impact
Study should be diligently observed. The relative Impacts of an expanded facility
at Deer Island or Nut Island upon the surrounding community versus a new facility
at Long Island require sensitive a.nd deliberate attention during the public hearing
process. Reasonable claims to mitigate Identified Impacts should be supported
and funded.
SIGNATURE:
DATE:
CUf.bvth A. Bf«mti«ld. Prntdcm
WOIiwn C S*wy*r,
Pxtncia A. S/ttfy. T
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Metropolitan Area Planning Council
IIP Trcmont Stir« Botlon, M«uthu»etti 02108 (617M5V2770
Serving 101 Cities & Towni in Me(repo/iun Boston
February 4. 1985
DEIR-85-21
TO:
AMKkA FNICN
(Fill In
Lc«lNaTO«
I
*>•
e offered to Ulnthrop by the Commonwealth and by the
Cities and Towns serviced by this major facility In order to let that
Town not severely be affected by such a facility, and to provide
compensation and/or relief.
SIGNATURE:
DATE:
f.
Such considerations would be supported by Lexington If they were
deemed fair, equitable and reasonable.
fjiutwth A. tamfold.
Funk C. &ui«. fecrt
Pttnci* A. Btulv. Trait*.
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Metropolitan Area Planning Council
110 Trtmonl Street Boston, MimchutttU 02108 (617MS1-2770
Serving 101 Cities & Towns in Metropolitan Boston
February 4.. 198S
OEIR-85-21
RECEIVED
MAR-1B85
TO:
;,. S.
COMMUNITY:
(Fin in 1
(rill in Community)
Enclosed If • description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your connunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Hastewater Treatment Facilities for Boston Harbor
.THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
•E.O.E.A. TO MEET THIS DEADLINE. YflUft COMMENTS MUST BE
RECEIVED AT THE MAPC BY March 5. 1985
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
MERITS FURTHER ENVIRONMENTAL STUDY
I1 NEED MORE INFORMATION
EXPLANATORY COWENTS:
Metropolitan Area Planning Council
110 Trtmont Street Boston, Misuchusttts 02108 (617V-4S1-2770
Serving 101 Cities t Towns in Metropolitan Boston
February 4.. 1985
OEIR-85-21
MAR-1J985
TO:
COMMUNITY:
(Flu In Name}
(Fill in comnunlty)
Enclosed Is • description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your commmlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE CCrMENT WITH
E.O.E.A. TO MEET THIS OEADLIrie. VflUft COMMENTS MUST BE
RECEIVED AT THE MAPC BY March 5. 1985
(~^T ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
CD MERITS FURTHER ENVIRONMENTAL STUDY
rI NEED MORE INFORMATION
EXPLANATORY COMMENTS:
SIGNATURE:
DATE:
DATE:
2./X7/
y A. a/«*v, Tieiio
lliubcth A. ann*Tt«Hd. Pr«M)*fH
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Metropolitan Area Planning Council*
110 Trtmoot Strert Button, MuuchutttU (HIM (H7)-45V2770
Serving 101 Cf'l/es A Tbwni in Mevopo/iun Boston
February 4; 1985
OEIR-85-21
TO:
G!
COHtffllTY:
IFIII
(Fin in toonunlty)
Enclosed Is a description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your coomunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
* -/~~
™** Aw-^
THE COUNCIL HAS ONLY 20 CALENDAR OATS TO FILE COrFENT WITH
E.O.E.A. TO MEET THIS DEADLlNC. YOUft COWENTS MUST BE
RECEIVED AT THE HAPC BY March 5. 1985
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
II MERITS FURTHER ENVIRONMENTAL STUDY
II NEED MORE INFORMATION
EXPLANATORY COMMENTS:
SIGNATURE:
DATE:
A. BrintAvld. Pr*wd*«( WdJum C S4wy«r. VPimd*nt fttnk I. Biittr. S^rcury Piincu A. Bfidy. Trcn
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00
DATE:
I.D. I:
Metropolitan Area Planning Council
110 Turnout Street Boston, MMMchimtU 03108 (&17M51-3770
Serving 101 Cities & Towns in Metropolitan Boston
February 4. 1985
OEIR-85-21
TO:
Boston Water 1 Sewer Commission. Charles Button
(rill in
COMMUNITY: Boston. HA
(rill In toomunlty)
Enclosed Is a description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your comnunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS'DEADLINE. YuUft COM1ENTS MUST BE
RECEIVED AT THE MAPC BY March 5. 1985
GO ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
II MERITS FURTHER ENVIRONMENTAL STUDY
II NEED MORE INFORMATION
EXPLANATORY COMMENTS:
The only logical primary choices are "All Primary Deer.Island*
and "Split Primary Deer Island (52-acres) and Hut Island (18 acres).
The only secondary choice worthy of consideration Is
•All Secondary Deer Island (115 acres). However, It 1s not
environmentally or economically reasonable to construct and
operate secondary faclltles at all based on data gathered
for the waiver
Metropolitan Area Planning Council
110 Tfemont Street Boston. Ma««chin«m 02108 (>17>-45T-2770
Serving 101 Gli« 4 Towns in Metropolitan Boston
r
1C.
February 4. 1985 L - - :
OEIR-85-21
TO:
KEVTH J. SHEA MAPC REP.
V • V
commm:
iFiTT in Name}
nv myi SPA MASS.
(rlll in community)
Enclosed Is • description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's'Impact upon your community and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR PAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS OEAflLlNE. VOUft COMMENTS MUST BE
RECEIVED AT THE MAPC BY March 5. 1985
II ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
1I MERITS FURTHER ENVIRONMENTAL STUDY
I""1*! NEED MORE INFORMATION
EXPLANATORY COMMENTS:
SIGNATURE:
DATE:
cc: N. Baratta. HOC
itub«t>> A. S>imfi«U. Pnwten
William C. Saw>«f. ViC*Pr«IMJcn<
Frank C. Baitcf. S««rcury
Patncia A. Bradv. Trcaiw
SIGNATURE:
OATE:
n A. ItamTwid. Fmdtra
w,tl..m C. Saww. Viu-PnuteM
Puncu A. Brady. Ti»«,
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Metropolitan Area Planning Council
110 Tramont Sired Boston. Massachusetts 02108 <617)-4S1-2770
loving 101 Cilia 4 Towns in Metropolitan Boston
RECEIVED
February «. 1985
OEIR-aS-21
MAR-6 1385
TO:
te . Mo
u—
0-t
in Name)
COMMUNITY:
[FJTrtii Community)
Enclosed Is • description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Inpact upon your connunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE: Siting of Wastexater Treatment Facilities for Boston Harbor
Metropolitan Area Planning Council
110 Trtmonl Street Boston, Massachusetts 02108 (617MS1-2770
Serving 101 Cities A Towns in Metropolitan Boston
February 4. 1985
OEIR-8S-21
26 ees
TO:
COMMUNITY:
fn
HrT
coimunlty)
Enclosed Is a description of the project referenced below.
the Council requests that you consider whether this report adequately
describes the project's Impact upon your comsunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS DEAfllM. YflUfl COMMENTS. MUST BE
RECEIVED AT THE HAPC BY March 5. 1985
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
I I MERITS FURTHER ENVIRONMENTAL STUDY
I | NEED MORE INFORMATION
EXPLANATORY COMMENTS:
SIGNATURE:
OATI:
: '--> -- *~^
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
JJJOAR
LINE.
E.O.E.A. TO MEET THIS DEADLINE. YOUft COMMENTS.MUST BE
RECEIVED AT THE MAPC BY March 5. 1985
CD ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
CD HEnrrs FURTHER ENVIRONMENTAL STUDY
NEED MORE INFORMATION
EXPLANATORY COMMENTS:
Can no4- t\Ur^ef llt_- fib. *>*» If fj'
SIGNATURE:
DATE:
CUutMth A. taintoU.
Funk t. (Uxicf. Sexrciw Pitncu A. Brady, Trcii
WiUUm C U**v*f.
* A. 8**
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Metropolitan Area Planning Council
IIP Turnout Street Boston, Massachusetts 02108 (HTMSVITTO
Serving 101 Cities i Towns in Metropolitan Boston
February 4. 1985
OEIR-85-31
TO:
COMMUNITY:
(7T
Irill Ira unanimity) ,
Enclosed Is • description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your coununlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS DEADLINE. YOUR COMMENTS MUST BE
RECEIVED AT THE HAPC BY March 5. 1985
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
II MERITS FURTHER ENVIRONMENTAL STUDY
II NEED MORE INFORMATION
EXPLANATORY COMMENTS:
Metropolitan Area Planning Council
ItO Tremont Street Boston, Massachusetts 02108 ((.17M5V2770
Serving 101 Cities A Towns in Metropolitan Boston
February 4. 1985
FE3 1 -i •-
OEIR-a5-21
MAR-6B85
TO:
COMMUNITY:
(fin in community)
Enclosed 1s • description of the project referenced below:
The Council requests that you consider whether this report adequately
describes the project's Impact upon your caanunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastawater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CAl
E.O.E.A. TO MEET THIS Of
RECEIVED AT THE HAPC BY
DAYS TO FILE COMMENT WITH
LINE, YOUR COMMENTS.MUST BE
March 5. 1985
G£J A
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
L^J MERITS FURTHER ENVIRONMENTAL STUDY
II NEED MORE INFORMATION
i
EXPLANATORY COMMENTS^
SIGNATURE
DATE:
SIGNATURE:
DATE:
A* As
A. Bamfold. fnvOtnt .
WUlum C &4wy*f. Vic*>PmKltni
funk i. Bum. hcicun
Patncu A. BfMty. Trtiiu
EUutwfh A. |r*ft«A«ld. Pr«*il«nt
A. Bfady. T>«*
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I
U1
DATE:
1.0. I:
TO:
Metropolitan Area Planning Council
110 Tremont Street Boston. MasMchusetts 02108 (617MS1-2770
Serving 101 Cities t Towns in Metropolitan Boston
February 4. 1985
OEIR-85-Z1
COMMUNITY:
(Fill in Comnunlty)
Enclosed Is a description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your cannunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Facilities for Boston Harbor
TO:
COHMUN
Metropolitan Area Planning Council
110 Trcmont Street Boston. MauachusdU 02108 (617M51-2770
Serving 101 Cities & Towns in Melropo/iun Soilon
February 4. 1985
OEIR-85-21
RECEIVED
MAR-5 1985
in I/ in comnunlty)
Enelostd It • description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your coomunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastatater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS DEADLlNC. YOUft COMMENTS MUST BE
RECEIVED AT THE MAPC BY March 5. 1985
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE COMMENT WITH
E.O.E.A. TO MEET THIS DEADLINE. VflUft COMMENTS.MUST BE
RECEIVED AT THE MAPC BY March 5. 1985 '
< ] ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
MERITS FURTHER ENVIRONMENTAL STUDY
I I NEED MORE INFORMATION
EXPLANATORY COMMENTS:
II ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
II MERITS FURTHER ENVIRONMENTAL STUDY
f^L NEED MORE INFORMATION
EXPLANATORY COMMENTS:
SIGNATURE:
DATE:
SIGNATURE:
DATE;
! •'/.
Cliutmh A. flnmtwl
f. Vic«-Pmid«ni
f » jAk i. Bulcf. S« »eu*y tancu A. 8rMy. Trvitui
Fi«nli I. &MICT. Wcratuv
P«lnci« A. 8odv. Tr«itu>
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A. IwnncU.
WOl.jm c Sjwyn. vicr-f>in«l
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MeitrojpolittaiQ Area Pkamiag Council
110 Tremont Street Boston. Massachusetts 02103 (617)-4S1-2779
Serving 101 Cine) A Towns in Metropolitan Boston
RECEIVED
February 4. 1985
MAR-6fi85
OEIR-85-21
TO:
t* *
COMMUNITY:
tun in Name)
/-?
(nil in CommdnltyK
Enclosed Is a description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your coanunlty and addresses
significant environmental benefits and potential dacages.
PROJECT TITLE:
Siting of Uastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE CO»-45V2770
Serving 101 Cil/es 4 Towns in Metropolilln Beaton
February 4.. 1985
OEIR-85-21
n~CE/V.TD
'•MR-51S85
TO:
comfflrrr:
(Fill in Name)
(Mll in Community)
Enclosed 1* a description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your coonunlty and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Uastewater Treatment Facilities for Boston Harbor
THE COUNCIL HAS ONLY 20 CALENDAR DAYS TO FILE CCrWENT WITH
E.O.E.A. TO MEET THIS QUfiLINE. VOuft COMMENTS. MUST BE
RECEIVED AT THE MAPC BY March 5. 1985 _
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
MERITS FURTHER ENVIRONMENTAL STUDY
I I NEED MORE INFORMATION
EXPLANATORY COMMENTS:
SIGNATURE:
DATE:
tr—r
SIGNATURE:
DATE:
*~*-
C. Sa<*v«r. V
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ui
TO:
Metropolitan Area Planning Council
110 Tremont Street Borton. Mamchmetti (0108 U>17)-4S1-2770
Serving 101 Citiet & Town in Metropolitan Boston
February 4. 1985
OEIR-85.21
COMMUNITY:
TMIIII
in Community)
Enclosed Is a description of the project referenced below.
The Council requests that you consider whether this report adequately
describes the project's Impact upon your community and addresses
significant environmental benefits and potential damages.
PROJECT TITLE:
Siting of Wastewater Treatment Fadl 1 tles for Boston Harbor
THE COUNCIL HAS ONLY
E.O.E.A. TO MEET THI
RECEIVED AT THE MAPC BY
DAYS TO FILE COMMENT WITH
INE. YOUR COMMENTS MUST 8E
March 5. 1985
ADEQUATELY DESCRIBES ENVIRONMENTAL IMPACTS
l~~1 MERITS FURTHER ENVIRONMENTAL STUDY
l~~l NEED MORE INFORMATION
EXPLANATORY COMMENTS: '
SIGNATURE:
DATE:
Eliubcth A. BrantAdd. President
ftuik I. Baittr. S
P«inci« A. Bradv. Tr««t,
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WINTHROP
OFFICIALS/BOARDS/DEPARTMENTS
COMMENTS
2-55
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TOWN OF WINTHROP
ROBERT A. DELEO, Chairman
RONALD V. VECCHIA
ROBERT E. NOONAN
MARIE T. TURNER, Secretary
TOWN HALL
WINTHROP, MASS. 02152
846-1077
to
I
(Jl
OFFICE OF THE
BOARD OF SELECTMEN
STATEMENT OF SELECTMEN ROBERT A. OELEO
PUBLIC HEARING. MEMORIAL AUDITORIUM. WINTHROP. FEBRUARY 28. 1985
RE: SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT AND STATEMENT ON
SITING OF WASTEWATER TREATMENT FACILITIES 1M BOSTON HARBOR.
Ladles and Gentlemen
Ulnthrop cones here tonight united - united as one people In total and
unalterable opposition to the siting of a new wastewater treatment facility on
Deer Island.
We have read your study - and we have listened to your arguments - but we are
not ready to placidly walk that last mile to the most certain death of this
Comminlty.
We submit to you that this document ... the Supplemental Draft Environmental
Impact Statement ... Is fatally flawed. It Is Inadequate In Us technical
analysis of Identifiable Impacts ... It Is dangerously deficient In Its
apparent and deliberate segmentation of Issues necessary to make a sound and
fair decision ...and It Is obviously biased In Us treatment of Deer Island
and this Community. This Town will not be a pawn to unsound decisions arising
out of an unsound and partisan study.
From the beginning - Deer Island has been a social and economic dumping
ground. As a once physically remote and Isolated Island... It was the perfect
site to "closet" those problems which were considered too distasteful for
polite discussion.
Although the Island Is no longer physically Isolated from the mainstream of
society... and Is. In fact, an appendage to the Town of Ulnthrop... the sane
type of medieval thought process seems prevelant In any discussion of the
future of the Island. ...For It would seem that the weight of the arguments
posed In the SOEIS are geared toward conning us Into believing that It would
be far better to site a facility on Deer Island than to desecrate the pristine
beauty of Long Island.
In reading the SOEIS, one would think that Long Island's archaelogollcal and
historical significance is paralleled only by the ruins of ancient Greece.
Over the years It has been curious to note how Long Island's recreational
value has grown In stature while Deer Island's recreational potential
diminishes dally. Both Islands were included in the 1972 Boston Harbor Island
Comprehensive Plan — But Deer Island has mysterously disappeared from the
Department of Environmental Managements' 1984 Master Plan Update.
We ask here tonight what geographic phenomenon occurred to purge Deer Island
from the Boston Harbor Island system - and if it Is no longer considered for
Inclusion in the pending nomination of the whole Island system 1n the National
Register of Historic Places?
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We would also like to remind the federal and state officials here this evening
that the Boston Harbor Island plan Is "just* a plan and holds no guarantees
for the future of Long Island - any more than the 1972 "plan* guaranteed the
future of Deer Island. There would seem to be too many uncertainties on the
future of Long Island to preclude Its Inclusion as a viable siting option.
Unless of course the so-called "moderate" Impacts of this facility on the Town
of Ulnthrop have been manipulated to allow us the perception that we have
participated In a fair and equitable process... while actually having been the
unknowing dupes In an economic sellout.
If this process Is not an empty ritual — If It Is not a form of tokenism but
rather a true disclosure of all the facts, then we ask you to consider the
following:
The social, economic and environmental Impacts of siting a facility on Deer
Island must be accurately assessed and human rights oust be given priority In
the weighting process which will be used to make the final siting decision.
Our concerns on these Issues have been well documented.
We have asked for assurances that both the long-term and short-terra effects of
this facility on property values be accurately and realistically assessed. In
spite of assurances received, we are far from satisfied with the analysis
provided In the document.
-3-
Our request for documentation has been written off as some fora of fanatic
emotionalIso. You say you can't scientifically measure the value of our
homes. But In the purest economic sense, the largest single Investment that
most Individuals make within their lifetime Is In buying a home. This
Investment cannot be taken lightly — It Is the obligation of government. In
contemplating any action to carefully analyze the Impacts and weigh Its
decisions according to how It will effect this Investment. The SDEIS falls to
oake a concerted effort to properly assess these Impacts under the apparently
excusable argument that the parlmeters for this kind of evaluation do not
exist. We believe this to be an (INEXCUSABLE ARGUMENT...and will not let the
fate of this Community rest on the contradictory statements found within this
document. Clearly, the authors have covered all bases. They Indicate In one
section that post construction property values will rebound and then Indicate
In their summary table that they will not. We want and we deserve more than
this superficial examination of the economic Impact of this facility on this
Coonuinlty. And we demand this as the fundamental right of any Conmunlty.
Please don't patronize us or try to "cure" us through some therapeutic
dialogue designed to lull us Into believing we have received a fair evaluation
of our concern.
We have always born a disproportionate cost of this regions so-called
"cures". Our concern with property values Is part and parcel of our concern
with the multitude of costs that this Community Is asked to bear In the name
of a cleaner harbor. We bear the full cost for the maintenance and repair of
the truck route through W1nthrop...We bear the cost of traffic control and
police escort service to the Island. We bear the costs of fire service ... as
we are continuing to bear the cost of participating In this process despite
continued pleas for technical assistance funds. If this Is fairness, we want
no part of It.
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for those areas In which you apparently do have proven scientific perimeters
to make an Impartial assessment of Impacts. We contend that you have failed
miserably.
On your treatment of transportation Impacts, you have failed to make any real
commitment to barging — rather you have Included Halted promises to fully
resolve the Issue In the future. But our future Is now. When do you begin to
recognize this? When our Community and Us tax base have been destroyed?
On your treatment of water quality, you have again deferred for later connent
Items such as dredging and disposal of potentially hazardous harbor
sediments. You have also failed to make any guarantees that those water
quality standards which do not carry the weight of law will be enforced. And
although we can appreciate that most of the criteria for evaluation of the
effects of consumption of contaminated seafood Is from tests on ranch mink, we
respectfully request a more detailed analysis of how this effects human life.
We have noted your Halted examination of air quality Issues — knowing that
the topic cannot be properly assessed without the Inclusion of the segmented
and mysterious management of sludge.
Yes -- we are still asking and will continue to ask how you can so blatantly
segment the Issue of sludge management. — When sludge processing and
disposal represents approximately SOI of the capital cost of waste management
and occupies a significant portion of the physical plant.
We are In the process of preparing a somewhat lengthly document Identifying
our full and critical analysis of this study. We can't quite match you In the
volume of our document...but we believe the quality to be sound — and we
presume that you have the financial resources ... which have always been
denied us ... to Bake a proper technical and legal examination of our
document. The speakers who follow will highlight the concerns which we have
Incorporated into our document.
We ask that you listen to them, and while listening we would ask that you keep
in aind the following quote. It comes fron a letter concerning the
recreational value of Long Island. It shows the basis of OEM's argument
against the location of a treatment plant on that Island."The Impacts of the
plant which concern DEM the most are those of sight and smell. It would not
benefit the Park and the thousands of people it serves to have the plant be a
negative visual impact or produce foul odors."
Look closely at the Intent of this quote and you will realize that we are,
after all, only asking that the residents of Winthrop — as taxpayers and
citizens of the Conmonwealth be given the same consideration as the thousands
of tourists which DEM is so quick to defend.
If participation of the governed In government Is the true cornerstone of
democracy...then you must give our concerns the full attention which they so
rightfully deserve and we so strongly demand.
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TOWN OF WINTHROP
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VO
ROBERT A. DELEO, Chairman
RONALD V. VECCHIA
ROBERT E.NOONAN
MARIE T. TURNER, Secralsiy
TOWN HALL
WINTHROP, MASS. 02152
846-1077
OFFICE OF THE
BOARD OF SELECTMEN
STATEMENT OF SELECTMAN RONALD V. VECCHIA.
PUBLIC HEARING. MEMORIAL AUDITORIUM, WINTHROP. FEBRUARY 28. 1985.
RE: SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT AMD STATEMENT ON
SITING OF WASTEWATEK TREATMENT FACILITIES IN BOSTON HARBOR.
Ladies and Gentlemen:
Once again, this Community stands before you and pleads for
fairness regarding the Issue of expansion.
For the Town of Ulnchrop. there has been no protection;
there has been no fairness In dealing with the Issue of a
clean harbor.
There are obviously two sets of standardswhen the environmental
significance of Deer Island Is downplayed; yet the significance of
protecting Long Island Is played up. Nowhere Is It more evident
than In the "biased and one-sided" document called "SPEIS Oil SITING
OF KASTEUATER TREATMENT FACILITIES IN BOSTON HARBOR."
The "biased" SDEIS Report downplays the significance of Deer
Island as being a part of the original Boston Harbor Islands
Compreshensive Plan Issued by Che Metropolitan Area Planning Council,
dated October 1972, which reads:
"DEER ISLAND -- Relocate existing House of Correction to
mainland site -- Utilize southern end of Island as large. Informal
park and initiate planting program to reforest Island and to screen
aewage treatment plant -- Create open grass areas for playflelds
and children's playground -- Develop a three-mile system of
Page 2.
bicycle trails and extensive walking trails — Expand present
beach Co aceonodata 200 people -- Develop picnic areas — Develop
mooring area and dock ipaca for SO small boats — Construct a
fishing pier."
Needless to say, with the expansion of the present facility
at Deer Island, this proposed plan could not exist, and in fact,
the entire Island would be leveled and the historic Drumlin would
be removed.
The geographical location of this property is most unusu , 1.
The only community it touches Is Ulnthrop — but the Town of Wlnthrop
owns none of ltt and it would appear, has no say In what is placed
there. He have been forced to live with the problems of pollution,
prison, safety, traffic, and loss of our recreational activities.
1C is said that proposed construction on Deer Island will not
affect any historic sices. Bear with ae a moment and let us review
the history of Deer Island. The Island was granted co Boston In
1634 and was noted at that time ae a game preserve with pasture and
timber land. Early colonists flrac used the Island. In 1676,
Deer Island was used as s prison for hostile Indians captured during
the King Philip War. In the 1700's the Island was in agricultural
use. In the early 1800's the Island wss a popular spot for picnics
Construction of municipal buildings began in 1847, when a
temporary quarantine hospital wss constructed when smallpox broke
out among the Irish immigrants. Hundreds dies and were burleri
on the Islsnd in unmarked graves. In 1850 construction was begun
on a large poor house, and 1852 the poor house was opened. In 185fl
that building became the House of Reformation. The Suffolk Cou..ty
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Page 3.
Page 4.
to
I
House of Correction cook over the building In 1896 and atlll occupies
the >ae« building which la over 130 year* old. and chac, ladles and
gentlenen la che seme Deer Island Prlion which houses over 400
prisoners codsy -- overcrowded and delapldaced.
In 1889 an HOC sewage pimping station was estsbllshed on che
Island. Coal furnaces and stesm engines produced power to
puap rsw sewage Inco the Bay. As far back as chac, ladles snd
gentlemen. MDC was polluting che Harbor wacers of che Town of Ulnthrop.
The Deer Island peninsula was once separated from the mainland
by Shirley Cut. By 1935 a sand bar had formed, connecting che
Island wlch che msinland. A cwo lane roadway over the sand bar
./as constructed at the beginning of World War II. joining che
Island to Ulnthrop.
In summary I would like to touch on several aspects of c*ie
siting issue as it pertains to Boston, and ita overall reaponslbllity
in this matter.
From the beginning, we the people of Hlnthrop have talked
about the issue of fairness. Obviously it is falling on deaf ears.
Boston, more than any other community in the MDC System, has
promulgated a building boom with no regard to where che waste ends
up. Raw sewage outfalls in che Harbor and an over~burdened sewage
syscem is s mejor concrlbucor Co Boscon Harbor's pollution problea.
I ask you -- Is it not fair Chat che new expanded facility be
slced on Boston's Long Island?
When che issue of Long Island is broughc in as an alternative
for expenelon. it la downgraded because it is environmentally
significant or because it Is part of the overall Boston Harbor
Island Park Program. There seems to be two seta of standards applied—
one which bends to political pressure, yet uses che excuse of
cose or environmental impact; and one that downplays a site
in favor of unmarked graves versus the health and well-being
of the living.
The people of this community have had enough! It Is evident
by the attendance here tonlghc chat the fight is not over — that
we are unified in our commitment - and that this fight may take
us co che streets where our children play, or to che highest Court
In our land.
The necessity of such confrontation will resc on Scate and
Federal conaclencea. for we have attempted through every means
et our disposal to get fsir and unbiased trestment. and the
best solution to aolve the pollution of Boaton Harbor once and
for all time. That solution is LONG ISLAND NOT DEER ISLAND.
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TOWN OF WINTHROP
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ROBERT A. DELEO, Chairman
RONALD V. VECCHIA
ROBERT E. NOONAN
MARIE T. TURNER, Secretary
TOWN HALL
WINTHROP, MASS. 02152
846-1077
OFFICE OF THE
BOARD OF SELECTMEN
STATEMENT Of SELECTMAN ROBERT E. NOONAN.
PUBLIC HEARIHC. MEMORIAL AUDITORIUM. WINTHROP. FEBRUARY 28, 1985.
RE: SUPPLEMENTAL PRATT ENVIRONMENTAL IMPACT AMD STATEMENT ON
SITING OF WASTEWATER TREATMENT FACILITIES Id BOSTON HARBOR.
Ladles and Cenclemen:
I come before you conlght as a Selectman of Che Town of Ulnthrop
Co commenc on Che Supplemental Draft Environmental Impact Scacenent
on Siclng of Wsstewater Treatment Faclliciea In Boacon Harbor.
Buc - I nuac confess - my comnenc on chla document would be
unprintable! 1f Che Consulclng firm responsible for chls docunenc
was direcced Co prepare a fair and complete analysis of Che
slcuaclon, and co present a fair and complece soluclon Co Che
problema. Chen I submit Co you chla documenC does nelcher.
In reviewing Che docunenc. 1 gee Che deflnlce feeling 1C
Is prepared with a view coward presenclng a case Co locace chls
facility ac Deer laland and only Deer Island! Fundanencal fairness
does noc even exlac In chls docunenc! The uccer disregard of Che
20,000 realdencs of chls community based on Che logic of Che possibility
of moving a llccle-used hosplcal, or a snail cemetery which might have
archeologlcal value Caxes our comnon sense, and Is an Insult to our
Incel1Igence.
As 3 Selectman, I resent chls! As a citizen, father, homeowner
and human being, I resent chlsl
Page 2.
I coo am In government, repreaenclng 20tOOO citizens of chla
Town. And, lee me assure you, no Individual In local governmcnc
would dare Cry Co foist a project such as chls on an already over-
burdened communlcy such as Ulnchropl 1C Clcy, Scace, and Federal
Covernmenc la allowed to swallow up our small Town coday, who Is
nexct
WE WILL NOT BE SWALLOWED UP BY THE OCTOPUS OF STATE, CITY OR
FEDERAL GOVERNMENT! WE WILL BEAR HO MORE! OUR VOICES MUST BE HEARD!
We have been forced Co concend with a delspldaced and anclquaced
prison facility of the Clcy of Boston. Who allowed that slcuaclon co
decerlorace Co chls condiclon? THE CITY OF BOSTON.
We have been forced Co concend wlch an alrporc which cransforms
Che sklea above us Co a nighcmare of noise and air polluclon. Who
allowed chIs slcusclon co progress Co chla Incolerable sicuaclon?
THE COMMONWEALTH OF MASSACHUSETTS AND THE MASSACHUSETTS PORT AUTHORITY.
And for nearly Cwency yeara, we have been forced Co concend wlch
Che fiasco chey call a "treatment facility" polluting the harbor,
and adversely affecting the health, recreation and peace of mind of
every resident of Wlnthrop. Who allowed chls slcuacion Co decerlorace,
proliferate, and ganerace co a point where 1C Is a disgrace Co our
enclre nation! THE COMMONWEALTH OF MASSACHUSETTS AND THE METROPOLITAN
DISTRICT COMMISSION.
And, even chough we Che Town of Wlnchrop are NOT responsible
for any of these adverse conditions. WE HAVE BEEN FORCED TO BEAR
THE BRUNT OF THEM ALL!
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Page 3.
The cleanup of Boston Harbor Is of prime Importance Co this
Town. It Is utterly unfair and untrue to attempt to brand this
Town aa an obstructlonlat In such a cleanup. BUT IT MUST BE
DONE CORRECTLY, ao that we are not back here again each and
every year fighting the same battle.
f° GIVE US NO MORE REPORTS PREPARED FOR AN AGENCY THAT ALLOWED THIS
°* SITUATION TO EXIST IN THE FIRST PLACEI WASTE NO MORE TAXPAYERS DOLLARS
to
ON STUDIES! CLEAN UP THIS BLIGHT ONCE AND FOR ALLI BUILD THE
NECESSARY FACILITY ON LONG ISLAND - BUILD IT CORRECTLY - MAINTAIN
IT REALISTICALLY. AND LET US GET ON WITH OUR DAILY LIVES I
WINTHROP HAS LONG BEEN KNOWN AS A BEDROOM COMMUNITY - WE DO NOT
INTEND TO SIT BACK AND BECOME KNOWN AS A "BATHROOM COMMUNITY I"
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MCGREGOR. SHEA & OOLINER
ATTORNEYS AT LAW. PC
HAALANM OOLMfR
LAUREN B SLOAT
GEORGE A NAU- JR
CAROLYN W BAIOW*
QIC
RAU>HR WIUMEfl
EnMTonmnul AMWT
• AdRMUd m NH on*
27 SCHOOL. STREET-SUCTE 603
BOSTON MASSACHUSETTS O2108
• 171227.7289
MCGREGOR. SHEA & OOLINER
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TOWN OF WINTHROP'S LEGAL
COMMENTS ON SDEIS ENTITLED
SITING OP MASTEHATER TREATMENT
FACILITIES IN BOSTON HARBOR
EOEA 14895
Submitted pursuant to the
National Environmental Policy
Act and the Massachusetts
Environmental Policy Act
March 11, 1985
TABLE OF CONTENTS
PACE
I. INTKOODCTION AND SUMMARY 1
II. THE SDEIS FAILS TO MEET THE REQUIREMENTS FOR IT UNDER
THE NATIONAL ENVIRONMENTAL POLICY ACT. "NEPA" 2
III. ANALYSIS THE OF SDEIS' INADEQUACIES AND VIOLATIONS REVEALS
THAT IT IS FATALLY FLAWED 3
A. Inadequate Screening Criteria for the Seven Alternatives... 3
B. Segnentatlon............................................... 5
1. Overt end lapllclt Segoenceclon......................... 5
2. Chilling Effect on Scope of Public Connentary... 8
C. Inadequate legal end Institutional Analysis.. 8
D. Omission of Chapter 372 of 1984 9
IV. TEE SDEIS IS INADEQUATE UNDER THE MASSACHUSETTS ENVIRON-
MENTAL POLICY ACT, "MEPA" 14
V. CONCLUSION 16
RECEIVED -EPA
'.VilE?. C'.'i'jT/ DIVJ'CH
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MCGREGOR. SHEA & OOLINER
ATTORNEYS AT LAW. PC.
GREGORI MCGREGOR
JOHN F SHEA-
HARLANM OOLStfR
LAUREN B SLOAT
GEORGE A HAU.JR
CAROLYN W BALOWM-
37 SCHOOL STREfT.SUITE SO3
BOSTON. MASSACHUSETTS 02100
Bl 71227-7289
AALPHR WIUMER
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March 11. 1985
BAND DELIVERED
Michael R. DelAnd, Regional
Administrator
U. S. EPA-Reglon I
John f. Kennedy Federal Building
Boston. HA 02203
Jamea S. Hoyte, Secretary
Executive Office of Environmental Affairs
100 Cambridge Street j
Boaton, MA 02202 I
Attention! MEPA Unit
RE: Siting of Uaatawater Treatnent Pacilltlea for Boaton Harbor
Comments on Supplemental Draft Environmental Impact Statement/Report
EOEA «4895
Dear Meaara. Deland and Hoyte:
On behalf of the Board of Selectmen for the Town of Wlnthrop we hereby
aubmlt our conmenta on.the SDEIS entitled "Siting of Wastewater Treatment
Facilities In Boaton Barbor". Theae comments are part of the entire package
of commenta being submitted by the Town of Ulnthrop pursuant to the National
Environmental Policy Act (KEPA) and the Massachusetts Environmental Policy Act
(MEPA). In addition to the Section (Part IV) of theae comments specifically
referenced to MEPA, the document as a whole la Ulnthrop'a legal comments under
both the federal and atate processes.
I. INTRODUCTION AND SUMMARY
Our review of this SDEIS/SDEIR. hereinafter referred to as SDEIS. leads
us to conclude that the document poasesaes algnlflcant and potentially fatal
legal defects that must be corrected In the Final Supplemental EIS/EIR. These
defects Include the segmentation out of the EIS review process of significant
Issues that affect the siting decisions inherent In this oversll review pro-
cess, the selection of screening criteria for the evaluation of siting alter-
natives which violate the requirements of NEPA, inconsistent statements and
legal conclualona relstlve to comparative analyses of Deer and Long Islands,
an inadequate and Incomplete legal and institutional analysis of the siting
choices, and a lack of analysis of both substance and effects of the enabling
legislation for the new Massachusetts Wster Resources Authority viz., Chapter
372 of 1984.
MCGREGOR. SHEA & OOLINER 2
Moreover, aa the SDEIS nlao constitutes an envirooental Impact report
"EIR" under the Massachusetts Environmental Policy Act (MEPA), It violates the
regulations promulgated thereunder aa to the content required in this report
aa a reault of the scope delineated for it by the Massachusetts Executive
Office of Environmental Affairs. Changes eubaequent to the publication of the
SDEIS have triggered the so-called "change of project provision" in the
regulations promulgated under MEPA.
II.
THE SDEIS FAILS TO MEET THE REQUIREMENTS FOR IT UNDER THE NATIONAL
ENVIRONMENTAL POLICY ACT, "HEPA".
We respectfully submit that the SDEIS falla to comply with NEPA la that
its examinations of environmental impacts, required by Section 102(2)(C)
(1), alternatives, required by Section 102(2)(C)(111), and Irreversible and
Irretrievable commitment of resources, required by Section 102(2)(C)(v), are
Inadequate and vlolative of the standards required by that Act. Section
101(b) of NEPA requirea the reviewing agencies to "...uae all practical meana,
consistent with other essential considerations for national policy, to Improve
end coordinate Federal plana, functions, programa, and resources to the end
that the Nation may...
(4) preserve Important historic, cultural and natural aspects
of our national heritage, and maintain, wherever possible,
an environment which aupports diversity and variety of
individual choice...
(5) achieve a balance between population and resource use which
will permit high standards of living and a wide sharing of
llfes amenities...".
Among our reasons for strongly believing that the above standards have
been violated In the SDEIS la that the document falls to take Into account
changes in the standard of living and the "snaring of life's amenities" that
would be available to the citizens of Uinthrop. In Its screening of alterna-
tives and in its minimal discussion of balancing, for example, Wlnthrop'a high
and dense population against the lower population factors Involved In the Long
Island sitings, there is no discussion of the standard of living impacts of a
non-Deer Island siting. Such a siting would sfford algnlflcant natural
amenities by virtue of the potential for recreational use, and historic and
open apace preaervatlon on Deer Island for the citizens of Wlnthrop.
It Is clear under MEPA that where significant portions of a project and
in some Instancea vhere an entire program are Involved (auch aa the overall
long range treatment of waatewater In the municipal Boston area and the up-
grading of water quality In Boston Harbor), that an EIS that segments out par-
ticularly controveralal, technically difficult, onerous or uncertain issues
may be legally defective. This "segmentation" flsw Is reflected In the SDEIS
by the sbsence of the long term and interim sludge mansgement plana, and
aerlous technicsl Issues aa articulated by the technical commenta that are
aubmitted with the Town of Wlnthrop'a commentary package.
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MCGREGOR. SHEA & DOLINER
MCGREGOR. SHEA & OOLINER
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In Trout Unltalteo..?.. Morton. 509 F.2d 1276 (9th Ctr. 1974) Che United
States Court of Appeals found that a future phaae of a project muat be
dlacuaaed aa part of an BIS on a conteaporery phaae If it would be irrational,
or at leaat unwlae to undertake that firat phaae if subsequent phaaea were not
alao undertaken. Certainly ell partiea in thla Batter egree that It would be
the height of folly to undertake the aiting of tbeae treataent facilitlea
without a resolve on the part of the proponent authoritlea to arrive at and
Implement a aludge management plan.
Under the atandard articulated by Trout .Unlimited and its progeny, the
Town of Ulothrop nalntalna that segmentation ia fatal to the current, ongoing
BIS proceaa If it ia not corrected In the FSEIS.
The failure to Include the aludge management plane in the SDEIS not only
Impedea widespread public knowledge of end comaentary upon those plana, but
within the context of the SDBIS Itself falla to "Include epproprlate mitiga-
tion iseesurea not already included In the proposed action or alternatlvea", aa
required by 40 CFR. Sec. 1502. 14(£).
III. ANALYSIS Or THE SDEIS'
INADEQUACIES AND VIOLATIONS REVEALS THAT IT IS
FATALLI FLAWED.
A. Inadequate Screening Crlte
ernatives
The SDEIS laya out alx criteria on which the proponent agenclea baae
their deciaiona concerning the acreening of the seven alternativea etudled in
detail In the SDEIS. The alternatives will be screened using this criteria
and then rated agalnat the crlterle. Aa a final atep, the decision criteria
will be weighted to detemlne which of the criteria are nore Important than
otbera. It aeema clear that for Wlnthrop'a purpoaea the criterion entitled
Effecta on Neighbors ahould be given the most weight especially in light of
the fact that Ulnthrop already la affected by aeveral different facllitiea
auch as Logan Airport and the Deer Island House of Correction. Additionally,
it la a very denaaly populated community that will feel the effecta of any
major development. Theae Impacts run the gamut including odor, noise,
traffic, air pollution, construction impacts, etc.
The second importsnt criterion to Winthrop should be the effects on
natural and cultural resources. Taken together these two criteria are most
important In determining what the environmental aod social impacts of an
expanded feclllty on Deer Island will be. Theae Impacts must be clearly
identified so that proper mitigating measures cao be taken to avoid or
mlnlmlie those impacta. The ultimate altlng decision ahould be baaed on the
overall environmental and social Impact 'of the facility aa well as the ability
to have thoae Impacta mitigated. The SDEIS falls to do thla adequately,
especially in terma of the mitigating measures. Additional criteria
identified in the SDEIS such aa Harbor enhancement, Implementablllty, coats
and reliability are clearly very Important. It la imperative that the
ultimate altlng decision results in the enhancement of the Boston Harbor
environment from a variety of perspectives Including recreation, water
quality, etc. Coat and Implementablllty are alao Important although froa
Wlnthrop'a perapectlve they are probably secondary to Che effecta on the
neighbors and the effects on the natural and cultural resources. Finally,
Ulnthrop la very intereated in ensuring that the ultimate solution la a
reliable one and will not result in the failures that the current Deer Island
facility la now experiencing.
Thla discussion of the screening criteria ahould not be taken as an
acknowledgement of the validity of the crlterle. On the contrary, we have
reservations about the STEEFLI acreening methodology. Thla quantitative
method limits public accessibility to and understanding of the siting decision
process and can be legitimately challenged In court. The SDEIS falla to offer
• basis by which lay comaentatora and decialonmakers can understand the matrix
model and its limitations. Understanding'of the quantitative mathematical
analyala ia forbidding to the laymen. See for example, Cleveland FVrtrlc
Illuminating Co. V..EPA. 572 F.2d 1130 16th Clr.), cert, denied, 435 U.S. 996
(1978) and Cincinnati. Cas. ti.Electric. Co.. .v.. EPA- . 578 F.2d 660 (6th Clr. 1978).
Declaionmakera muat avoid the temptation to baae their altlng cholcea on
the abstract technology of computer enalyala.
The screening process set forth et Section 2*0 of Vol. 1 of the SDEIS
violates NEPA Sections 102(C) (4),(5) in that the criteria aelected, at page
2-3, ere extremely general, and not Incluaive of the apeclflc evaluative
criteria aet forth at parta 4 and 5 of the atatute. The vague nature of the
selected screening criteria is reflected later on In the document In that
there la a failure to snalyie the historic and cultural aapecta of Deer laland
(aa la detailed In the other comments submitted by the Town of Winthrop) and
in the fellure of the SDEIS to analyze how a balance between population and
resource uae can or will be achieved In the alternative selections that would
permit the high atandard of living and aharing of amenities required.
The preselection elimination of Alternative 5b.2, (All Primary Long
Island), further Indicates the hiss generated In the SDEIS by the arbitrary
selection of the screening criteria. At page 2-6 of the document, for
example. It la stated, "the legal and institutional obatacles to altlng a
large (approximately 52 acrea) primary treetaent plant on Long laland would be
formidable end perhapa insurmountable." Thla atateaent In and of itaelf la
not even en accurate reflection of the admittedly Incomplete legal analysis
contained in Vol. 11, end Ignores the formidable end perhaps Insurmountable
legal conatralnta to sitings of facilities on portions of Deer Island.
Assuming for the sake of argument that the page 2-6 etatement la true. It Is
then totally inconaiatent for the authora to conclude that the All Secondary
Long laland (Alt. 2b.1) la feasible In light of the "formidable and perhaps
Insurmountable" legal hurdles. This conclusive prescreenlng based on reasons
auch aa the one quoted above la not eupported by law or by data elsewhere in
the SDEIS. Thla error la compounded at page 2-9 where It is stated, "the
major obataclea to the timely and reliable iapleaentation of a plan for siting
a consolidated primary treatment plant on Long laland are the atringent
requlrementa of many atate and federal environmental lawa, aa well as necea-
aary legislative approvals". The fact that these epprovals and other permit-
ting requlrementa would be "very difficult to obtain" because of the competing
public uaea preaent on Long Island makes the situation no leaa easy because of
the competing public uses on Deer Island. The only apparent major differences
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MCGREGOR. SHEA & DOLINER
MCGREGOR. SHEA & OOLINER
to
i
relied on »e the preieoce of Che Long Island Hoapital, which our other
commentary indicates li closely analogous to the pretence of the Bouse of
Corrections on Deer Island, and the proposed recreational uses on Long Island
which, ss Is pointed out by our comments, Is not an absolute.
The errors wrought by the srbltrary selection of screening criteria
continue In Vol. II of the SDEIS. For example Section 12.9, the sludge
disposal overview, Barely applies general evaluative criteria to the sludge
disposal alternatives rather than the criteria that are required under HE PA at
Section 102. The upshot of the application of these erroneous criteria is
that sludge management decisions are erroneously segregated out of the BIS
process under the sasumption that they would not affect a siting decision.
See, e.g. Sec. 12.9.1.
B. Segmentation
1. Overt and Implicit Segmentation
The segmentetlon In the SDEIS Is boch overt, (the affirmative decision to
separately analyie aludge management plans), ss well as implicit in terms of
Intern*! Inconsistencies contained throughout the document. Many of these
Internal inconsistencies are dealt wltb In the technical and other comments
being submitted by the Town of Wlntbrop, and some will be noted In passing In
these legal comments. Both overt and implicit aspects of segmentation In this
SDEIS first occur at page 3 of the Executive Summary. The third paragraph on
page 3 states in pert, "the Impects of aludge disposal will be defined in a
separate study and described In a separate environmental Impact statement in
the near future, not in this document". This decision apparently Is juitlfled
by the SDEIS's continuing sssertlon that the choice of sludge management
options will not drive the selection of s siting alternative. We maintain
that this basis for segmentation Is erroneous. Wlnthrop's technical SDEIS
commentary clearly raises the issue that sludge management solution choices
could drive the aitlng decision, and that the acreenlng criteria for siting
alternative evaluation Ignoree the algnlficant Impacta that would be wrought
by the construction and operation of various aludge management options at any
alte.
The implicit segmentation in the SDEIS alao begins on page 3 of the
Executive Summary. Mitigation measures, as aummarlzed in four paragraphs on
that page, are all qualified by language auch as "to the maximum feasible
extent" and "all practical". The use of this qualifying language not only
dilutes the commitment to mitigation that la required under HEFA, but also
highlights the fact that by aplittlng the wastewater treatment program for
Metropolitan Boston into a projected programmatic series of declslonmaklng
proceaaea (some of which would be the aubject of future environmental Impact
statements and some of which would not), It is impossible at this time to
aacertaln the practicality of mitigation Implementation and so to commit to
it. This leaves the Town of Wlnthrop at s loss to plan, as they are required
to do so under Chapter 372 of the Acts of 1984, for their participation In the
endeavors of the new Massachusetts Water Resources Authority. This segmenta-
tion of the overall effort to achieve water quality Improvements la further
set forth In Vol. I of the SDEIS beginning at page 1-15. Failure to Include
adequate analysis of options for aludge management, off-site transportation,
other technical issues snd new alternatives (such as the "new island" optione)
deprlvea the public of a unified environmental review document upon which it
•ay have informed input. See, e.g. Cras-lm Fielda Facm. .v. Goldschmldt» 626
F.2d 1068 (1st Clr. 1980).
The segmentetion out of the sludge dlsposel elternatives is discussed
further et Section Z.5, Vol. 1. pages 2-21, 2-23. At page 2-23 It is stated:
during the SDEIS analysis, it was concluded that none of the
aludge disposal alternatives being considered eltered the siting
conclusions being made on wastewater facilltlea. In part, this
wss due to the available option of locating aludge facilities
offalte away from a treatment plant. It was also a function of
the varied aitlng requirements of each of the aludge alternatives
which, although they do not drive s treatment plant siting decl-
. slon, require more analysis.
This language reflects the broad assumption in this document that somehow
the offslte disposal of aludge will be easy to accomplish. The SDEIS, how-
ever, lacks a guarantee that In fact sludge will be disposed offslte. It also
ignores the Impsct of the lend transportation of auch aludge (let alone grit
and skimmings) should the proffered barge transportation of aludge be "not
feasible" or not "practical". There is still no basis preeented for
sepsrsting sludge management decisions out from this BIS.
There is no basis presented for the conclusion that the sludge disposal
alternatives do not alter the siting conclusions .that will be made on
waatewater treatment facilltlea. Bather, the end of the above-quoted
paragraph indicates that more analysis of the sludge management questions is
required. Both the bests for the conclusion that aludge management decisions
will not drive the selection of a aitlng alternative, and the additional
analyala of the aludge management alternatlvea muat be presented In the FSEIS.
The segmentation of aludge disposal facility questions Is sgaln mani-
feated at page 4-103 of Vol. I. That section, including a dollar analysis of
the proposed Improvements etstes, "these costs do not Include sludge disposal
facilities which srs to be developed ss part of. a. separate facility planning
effort and environmental .review proceaa now, .underway" (emphaela added). There
Is no bssls given for separating out the coets of sludge disposal facilities
into s apparently parallel and contemporaneoua environmental review proceaa.
To do ao fruetratee the intenta of NEPA and MEPA and prevents the public. In-
cluding the Town of Wlnthrop, from obtaining an overall comprehensive analysis
of the costs Involved for the varioua aitlng and sludge treatment alterna-
tlvea.
The proposition Is set forth at page 3-1 that "unresolved Issues"
including sludge disposal, offslte trsnsportatlon, and future waatewater flows
"do not have the potential for affecting the location or other pertinent
aitlng characteristics of these trestment facilities". No factual basis Is
set forth for this conclusion. The Town of Ulnthrop most strenuously
disagrees with this conclusion, particularly In light of the fact that such
technical issues
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MCGREGOR. SHEA & OOLINER
MCGREGOR. SHEA & DOLINER
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as skimmings disposal, incineration, and landfilllng have not been adequately
examined or dlapenaed with, aa la noted In the technical comments aubaltted by
Mr. Graber. Page 5-2 goea on to aay that **the first [oethod and location for
sludge disposal] will have to be reaolved before the matewater treatment
facllltlea are substantially completed*1 (enphaala added). It la folly
postulate that the waatewatar treatment facllltlea would be under cona
tion. let alone alted, prior to dlapoaltlon of the aludge management 1 aue.
Further, the attempt to preclude public review of the unified Harbor c
program la highlighted in the next paragraph on page 5-2 which again a
eanup
lerta
of
that the five laauea dlacuaaed la Section 5.0 will be evaluated aa par
aeparate environmental review. These environmental reviews, in turn, may not
necessarily be part of eeparate ElS's. The statement at page 5-3 that long
term dlapoaal alternatives, aa well aa Interim dlapoaal solutions, are
currently under study and will be independently reviewed for environmental
acceptability prior to any decialoa on sludge management la not a commitment
to an BIS under HEPA. There la no coonltment that a final decision on aludge
management will be subject to the environmental review proceaaea mandated by
HEPA and MEPA. Even If auch commitments to separate EIS/EIR documents for
these integral phases were made In the SDEIS, the procesa would still be
fatally segmented.
The Implementation of waatewater improvements la further broken down Into
segments aa Indicated at the top of page 5-4 where it la disclosed that no
site baa yet been identified for an off alte barge terminal. Thla triggers
the Town's concern that a commitment to barging la at beat ahaky, based on the
qualifying Language at the beginning of the EIS. Thua, the broad commitment
early In the EIS, read on Ita own. Is misleading. Moreover, the legal
ramifications of an out-of-atate aludge destination, sich aa Interstate trans-
portation requirements and other states' siting laws, are never addressed.
The Section 5.4 discussion of potentially contaminated Harbor sediment
disposal contains the admission that the Impacta of such disposal would be
"identified and evaluated", but they are not included in this Supplemental
EIS. We expect that this Information will be developed and Included to" the
Final Supplemental EIS, aa It doea drive a siting decision. The Town of
Winthrop la highly concerned about the aerloua deleterious environmental
Impacts that would be caused by dredging for the Installation of barges,
shoreline improvements, and piers. It la ridiculous to aaflume that this Issue
doea not affect the siting declalon. (See also, discussion on this Issue at
Section III C, infra.)
The Section 5.6 analysis of future waatewater flow growth control Is
misleading in Implying that there will not be a program or strategy
specifically addressing future system growth and potential future system
overload. The new Massachusetts Water Resources Authority la required
to fomulate such a program by Chapter 372 of 1984. This IB another reason
for including a complete analysis of Chapter 372 In the Final Environmental
Impact Statement.
A slightly more accurate picture of the potential adverse Impacts front
the Inability to barge sludge from the site la touched upon at paragraph (d)
on page 12.9-5. However, this paragraph also contains no guarantee that
barging la possible. This la because barging and aludge management are not
dealt with adequately in this SDEIS, aa la Indicated by the technical
comments, and becauae they have been segregated from the public scrutiny that
la inherent to this primary EIS.
2. Chilling Effect-On Scope of. Public Commentary.
The segmentation Issues and examples discussed above raise more than an '
interesting legal problem and defect with the SDEIS as it la currently
constituted. This segmentation erroneously provides the public with the
impression that their commentary oust be limited to Issues that are within the
parameters of the document as set by the proponent agencies. For example, at
page 2-26 of Vol. I It la stated that public comment Is aought upon only three
issuesi adequacy of declaion criteria, rating of options, and weighting of
decision criteria. Given the statements throughout the SDEIS that various
subjects will be dealt with elsewhere and as the subject of other review
proceaaea the statements at page 2-26 constitute a vlolatlve chilling affect
on public commentary greater in acope than these three areaa.
C. In
Legal information and analysis la contained in Sectlona 11.1 and 11.2 and
Section 12.11 of the SDEIS, aa well aa being Interspersed throughout the
document's two volumes and Executive Summary. Although there la probably a
rationale for "segmenting" the legal analyses, this segmentation and Incom-
pleteness make the overall legal analysis Incomplete and inadequate. All
legal issues are not fully and accurately dlacloaed and dlacuaaed.
Section 11.1. federal .And State. Permits. Checklist
The major defect in this section la the failure to recognize the
existence and Implication of local permits and regulations. The checkliatr
ignores municipal legislation which could regulate various aspects of the
siting of a waatewater treatment facility. The Cities of Qulocy and Beaton
and the Town of Ulnthrop have ordinances and bylaws to protect the public
health and environment which are presumed valid "unless it la shown beyond a
reasonable doubt that they conflict with the applicable enabling act or the
Conatitutlon." Crall, .v.. Leomimter. 362 Maaa. 95, 102 (1972). Such municipal
Legislation will be voided only if it la "Inconsistent with" laws properly
enacted by the General Court, Bloom v.. .Worcester. 363 Masa. 136 (1973).
However, "legislative intent to preclude local action must be clear." Id. at
155. In addition to zoning and non-zoning legislation, a Board of Health may
exercise Ita powers under M.G.L. c. Ill, Sees. 150A and 150B. There may be
additional reviews and approvals by other municipal boards as mandated by
local laws and regulations.
The only recognition of local controla la the mention of Conservation
Commission review In item 13 of the Checklist. However, this description
views an Order of Conditions solely under the Wetlands Protection Act; It does
not recognize that Conservation Commlaaiona have review and permitting
responsibilities under local wetlands bylaws or ordinances.
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MCGREGOR. SHEA & DOLINER
MCGREGOR. SHEA & DOLINER
10
NJ
i
en
en
Item* 110 and III to the Checklist appear* to Igoor* deliberately the
possibility that sludge and acua landfllllng operation* night require fllluga
and review under H.G.I, c. 21D and regulatlona found at 990 Qffi 1.00. The
landfllllng operation would cone within the acope of 21D If the aludg* or acua
can he defined aa hazardous waate. Moreover, whether the sludge and scum la
hatardoua or not, the landfill muet be the aubject of a alte aaalgnment
proceeding under H.C.L. c. Ill, aec. 1SOA and 150B. A alte aealgnment would
be governed not only by the atatute but elao by local board of health
regulations.
Item 114 In the ChecUlat la titled Tldeland Construction". What
pemlt, review or regulation la thia item referring tot la It enother
reference to M.C.L. c. 91 Waterway Licenses (aa outlined In Item IS of the
Checklist), or the draft tldeland regulation*, or the Maaaachuaetta Supreme
Judicial Court caaea dealing with tldeland* use, or the prior public uae
doctrine, or Article 97 of the Maaaachuaetta Constitution!
While Item #7 of the Checklist reference* DEM land u*e review, la thla
the aaae review and consent required by Chapter 742 of the 1970 Acts snd
Resolves of the Msaaachuaetta Legislature!
Section, 11.2.1
Thla section la an overview of actions requiring permlta under Federal
law. Thla aectlon contalna an adalaclon by the project proponent aa to the
very dangera alluded to in our criticisms on segmenting the altlng proceaa.
Specifically, thla section admlta the Isck of detsll on Impact! from marine
construction for particular altlng options. Critical limitation* baaed on a
lack of information and analyala la recognized at page 11.2-2 when the project
proponent atatea:
A* such, this BIS does not address Che specific marine
related impacts of a particular altlng option. Lack of
thla detail, however, would not likely affect the altlng
decision because the type* of marine construction Impact*
aaaoclated with all the sltea appear to be almllar (except
for the possible filling at Nut Island) and would not favor
any particular option over another. Thla assumption la
generally aupportable..." However, the aoalyaia goes on to
demonstrate that contaminated dredged material "Illustrates
that alte specific Information can potentially affect the
Implementeblllty of any SDEIS site option chosen.
If alte apeclfic analysla of environmental Impacta la not done, how can
the siting deciiloomakera even begin to utilize the "implementablllty"
criteria act forth at page 2-24 of the SDEIS!
Section 11.2.3. Legislative/Regulatory Framework
Thl* section 1* an excellent aummary of the federal requirements for
marine construction activities. It should prove an Invaluable tool in guiding
the project proponeot chrought the. federal atatutory and regulatory maze. It
1* noted, however, that the preparation of thia aectlon required little effort
•Ince It 1* *ub*tantlally excerpted from an exiatlng EPA document.
Two defect* are noteworthy. Flrat, a better description of the Army
Corp*' and EPA'a public Intereac review proce** *nd requirement* must be
Included In the FSEIS. Secondly, thla aectlon *uffer* from it* focu* on
federal requirement* only and the failure to dlacusa state and local re-
quirement*. It 1* Insufficient to parenthetically observe that; "(n|ote that
additional requirement* in Ma**achu**tC* Include a Division of Wetland* and
Waterway* Llcenae, local conaarvatlon* comml**ion Order of Condition*, and
HEPA compliance." (at 11.2-8)
Section 12.11 Legal and Institutional Constraints on Long. Island, .and Peel
Island
Thla aection comprised of two Research Memoranda dealing with legal and
Institutional issues ha* several major defect*.
Flrat, the two memoranda are dated because they were prepared in August
and November, 1984, and therefore do not reflect the atate-of-the-law at the
time of the release of the SDEIS for public comment. Specifically, the
memoranda do not review and analyze Chapter 372 of the Act* and Resolves of
1984 which eatabliahed the new Maaaachuaett* Water Heaourcea Authority. The
legal analyala done for the final SEIS should address Issues raised by Chapter
372. In addition to a detailed analyais of this comprehensive itatute which
Is fundamental to the siting proceaa, the legal 'analyala should address
eminent domain authority, the review power* of the Maasachuaett* State
Division of Capital Planning and Operation* (DCPO), the powers of the
Governor and the Massachusetts Water Resources Authority to provide munlcipall-
tlea with money compenaatlon in addition to or In lieu of mitigation measures,
and the Authority'* power to provide technical assistance to those communities
which are not participating in the evaluation and decision proceas on altlng.
No longer applicable 1* the lengthy dlacuaaloo of the MDC authority
Section A(l) at page* 6-7. Section A(6) et page* 15-16 needs revialon to
reflect Chapter 372. Finally, Section B at pagea 18-21 needa to be completely
revlaed to provide an analyala not of the propoaed statutory power* but the
current atatutory authority of the Maaaachu«ett* Water Resource* Authority.
Secondly, the omissions and layout of thla section make the legal
analyaea of limited value to the public and the decialonaakera.
Regarding layout, the aectlon la dl*jointed In that the two memoranda
lack coordination and synthesis. The aole attempt* at providing coherent
aoalyaia are the pagination of both memo* to appear a* one memo (and thla
effort failed), and the brief comparative analyala found at pagea 56-59 and 61.
In order to he valldly uaed for comparative analysis and ultimate
declalonmaklDg, the legal aectlon needa to be reorganized in addition to being
expanded. For example, there should be a summary of the analyses In
narrative, outline, or chart format ao that one can quickly aee what the legal
requlrementa and institutional conatralnta might he. Thla aummary ahould be
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MCGREGOR. SHEA & DOLINER
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MCGREGOR. SHEA & DOLINER
12
to
i
10
backed-up by appropriate analyses which Bight Include tho first two memoranda
and a third memorandum dealing with new laauea and dafecta In thla preaant
eectlon.
The Inport and value of any legal opinion which la prefaced by broad
dleclalmere ouat be aerloualy .queetloned. There ere two auch dlsclainera In
thla aectlon. The Auguat 28. 1984 memorandum at page 2 atatea:
Our analyala rellea upon the accuracy of certain facta with
reapect to environmental conditions, legal ownerahlp, and
poaltlona taken by verloua public bodies'. Beceuee of time
and coat limitations Involved In thla effort, we have not
conducted en Independent verification of many of theae
uttara. We have attempted to Identify tboae aaeumptlons In
thla memorandun, and can dlecuea what might be done to
clarify theae polnta.
He are told once again that the November 27, 1984 memorendua la even leaa
uaeful then the flret, alnce "Available time and reaourcee preclude a almllar
complete eaaeaaaent of ell theae lawa aa they effect Deer laland". Thla
memorandum clearly attempted to aupply additional legal review aa an after-
thought .
It appeera that time, money and dlrectlona from the project proponent
have precluded a legal analyala covering the full apectrum of applicable lawa
and environmental consequences. By ita own admlaalon, thla aectlon la
Inaufflclent and defective.
More Importantly, the legal analyala la of limited velue becauae of Ita
very narrow acope. We ere told In the Introduction to the Auguat 28, 1984
memorandum that there eziata a lerger analyala dealing with compliance with
NEPA. Where la thla analyala In the body of the SDEIS? Many, If not moat,
EIS and EIR documenta have dlacuaalona of the requlrementa of NEPA and KEPA
and how they relete to the current document under review. Sometimes thla
takes the form of a narrative deacrlptlon, flow chart or summary chart of the
requlrenenta of the law and bow they are being met. Thla type of analyala la
totally lacking In the SOEIS.
Paragraph 2 of the Auguat 28, 1984 memorandum llata Items which need
legal analyala but were either not looked at or looked at "only to the extent
that algnlfIcantly different laauea or concerna can be anticipated with
reapect to Long laland which would not be ralaed with Deer leland or Nut
Islsnd". While a number of theae laauea are Hated In the Section 11.1
checkllat, there la no detailed analyala of the legal requirements, no
timetable eatlmatea for compliance, and no forecast on the length and types of
delays which might be encountered In those legal proceedings.
Given the limited acope of work for the attorneys to examine only Article
97, prior public use doctrine, DEM end DCPO powers, and federal and atate
hlatoric review proceaaee, it appeara that by thla narrow topic aelectlon the
project proponent la attempting to atage a battle solely on political grounds
(aa the flrat memorandum observes "...many of the laauea dlacuaaed herein may
be aaen aa merely creating the landscape upon which the, debate will .take
place**), and not to focua on the legal foruma where environmental concerna are
uaually addreaaed (the Itema Hated In paragraph 2 at page 1 of the flrat
Hemorandua).
The laauea exaolned do not poae, however, the legal and Institutional
conatrainta one might imagine aiaply becauae of the length of the memoranda.
It baa been our experience that hlatoric and archaeological reviewa can be
coordinated end handled within NEPA and HEPA reviewa ao that no undue delays
are neceaaary. See for example how hlatorical laauea were handled in the
final Environmental Impact Report for the Worcester Bio-Medical Reaearch Park,
EOEA 14521. and how the hlatoric laauea were avoided In the International
Place project* The analyala of atate end federal hlatoric preaervatlon lawa
should provide clear guidance to the project proponent to ensure timely
consultations and full compliance with theae lawa.
The Memoranda spin out several worse-case scenarios In the event of
agency confllcta during the conaultatlon and review proceaaea. The reellty la
that the Dukakis Adalnlatratlon operatea with a unified front: that la, all
agency heada aupport the gubernatorial aelectlon and work to aee a timely and
proper implementation of that choice. In other worda, we are confident that
the Dukakla team cen end will avoid political Infighting in order to implement
the siting decision.
The Article 97 and prior public use analyse! indicate legislative
epprovala may be needed. Once again, theae are not Inaurmountable con-
atrainta. The key to avoiding conflict la "[T)o the extent that proposed
construction activities on Long laland could be reatrlcted to areaa away from
sensitive envlromental reaources, hlatoric and archaeological resources and
exlating hoapltal actlvltlea, Impacta on theae reaourcea can be minimized,
perhapa avoiding some regulatory problems". Thus, If the project proponents
so choose, these Issues may be avoided.
The reality la that these legislative approvala are regularly obtained
without fanfare if the legislation la "nurtured" through the General Court.
Every year the legislature is asked to deal with doiena of requests for votes
under Article 97. Many of these cases do not present the legislators with
time to study the proposal and in moat caaes there is no discussion of the
proposed legislation. While the siting of facilities to help cleanup Boston
Harbor does not enjoy the anonomity of other requests to the legislature, if
legislative approval la required it can be done in a way to minimize
controveray.
The Coastal Zone Management consistency review and the potential
applicability of Pederal Executive Ordera la appropriately addressed In the
Memoranda, but aa observed above, the analyala foregoea examination of the
Wetlanda Protection Act and municipal reviewa. Certainly zoning and nonzonlng
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MCGREGOR. SHEA & OOLINER
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MCGREGOR. SHEA & OOLINER
to
i
ordinances and bylaw* present l«g»l and Initlcutlonal constraints. Municipal
controls, local political Inatltutlooa, and stste and federal pre-emptions
issues oust be examined. For example, under the Boaton Zoning Coda, a aewage
dlapoaal plant la a conditional uae In tnduatrlal and waterfront dlatricta. A
apacial penalt would be required from the Zoning Board of appeals for projects
on Deer or Long leland. Municipal alte aaalgment lawa and regulatlona nay
alao apply.
Finally, In order to fully and fairly examine all the legal and
Inatltutlonal conatralnta the full panoply of laauea aa they apply to Hut
laland deaerve examination.
Concluaiona on Legal, and InatltutlonaX Analysis
While the legal analyala haa Ita ahortcoalnga, we agree that there are
nany administrative, procedural, and aubatantlve requirement i Impoaed by atate
and federal law protecting wetlanda, hlatorlc altea, and prior public uaee;
that nany of theae requirements can be avoided or Impact! minimized by the
facility altlng location; and that "the ultimata aelectlon will depend very
heavily on political conalderatlona and, poaalblly, actlona taken or not taken
by the Maaaachuaetta legislature." However, we object to the limited scope of
the analyala, the lack of a aummary which ayntheelzea the aub-analysea, and
the Implicit claim that the leglalatlve and hlatorlc approvals are more
difficult to obtain In a timely manner than the environmental approvals which
are not even analyzed.
If thla aectlon of the SDEIS la Intented to truly "create the landscspe
upon which the (siting) debate will take place", then all the legal and
political Issues need to be discussed. Without s thorough snd full
examination of all legal and Inatltutlonal conatralnta In the FSEIS, the
"landacape" will remain a surrealistic impression rather than a realistic and
objective essessment snd planning tool.
D. Qnlsalon .of Chapter 372. of .1.98*
Aa mentioned in Section III C aupta. the SDEIS lacks any analysis of
Chapter 372 of 1984, the enabling act for the new Maaaachuaetta Water
Resources Authority. Given the timing of the publication of this document,
this obviously was not possible, but it is sn oolsslon that must be corrected
In the Final Supplemental EIS. At the minimum, there should be an inclusion
of the statute in toto. at Section 9.0 and an inclualon of a legal analysis of
Chapter 372 In Section 12.11. Moreover, specific Issues that are raised by
enactment of 372 must be dealt with In the FSEIS as they relate to costs,
planning, and cultural impacta. For example, the definition of "costs" found
at Section 2(d) of 372 constitutes a ststutory basis for the Authority's legal
power to provide munlclpalltlee with money compensation in addition to or in
lieu of mitigation measures. This position is underscored by Section 6(0)
which provides the Authority with power to eater into arrangements in "...all
mattera necessary or convenient to the operation of this Act...".
The costs envisioned for analysis In the FSEIS would Include technical
assistance that would be supplied by the Authority under Section 6(1) of
Chapter 372 to host and other effected commnmltiea as well as the cost of
assistance to boat and abutting communities a* those terns are defined by
M.C.L. c. 210. this is becaue* Chapter 372, Section 8(1) placea the Authority
under the Jurisdiction of Chapter 21D, the Hazardous Waate Facility Siting
process. Other Issues that must be analyzed In the context of this new
legislation Include the historic analyses Inherent not only In siting but in
the calculation of sewer charges for the communities Impacted by a alte
aelectlon. Thla sort of analyala la mandated at Section 10(a)(lv) of Chapter
372.
Finally, Section 26 of Chapter 372 empowers "local bodies" such aa the
Town of Wlnthrop to join the Authority la Investigations, studies and other
activities. The Town of Wlnthrop hereby notiflea the proponent agenclea that
under Section 26 of Chapter 372 which states that a local body such as the
Town of Wlnthrop la a "partner" with the new Authority In the sewer system
planning proceasee, and la entitled to full and open acceaa to the FSEIS and
all other planning documents prior to publication. We Intend to utilize our
"partner" status with the Authority for the purpose of assisting in the
preparation of the FEIS by providing the Authority with such data aa Wlnthrop
can develop given the technical aaaiatance that It la due under Chapter 372
and with the data we are already submitting In conjunction with these comments.
IV.
THE SDEIS IS INADEQUATE UNDER THE MASSACHUSETTS ENVIRONMENTAL POLICY ACT.
"MEPA"
In addition to the requirements under NEPA. the SDEIS snd Its review
process are governed by the Maaaachuaetts Environmental Policy Act (MEPA).
The Commonwealth haa promulgated a separate body of regulations which describe
the MEPA process, and regulatea the contents of an environmental Impact report
(EI&), and Ita review. The contenta of an E1R under MEPA are very almller to
that required under HEPA. Specifically, the project proponent must describe
the project, describe the environment of the ares likely to be affected by the
propoaed project, discuss alternatives to the proposed project, discuss the
probable Impact of the project and its alternatives on the environment, and
dlacuaa all mitigation measures utilized to minimize environmental damage.
Additionally, the Commonwealth under the auspices of the Secretary of the
Executive Office of Environments! Affslrs (EOEA), issues a scope for the EIR
which is e distinct document from the scope under the NEPA process.
The SDEIS raises seversl sreas of concern with regard to MEPA and its
scope. The major concern la the method by which the alternatives were
evaluated vla-a-vle the "Unresolved Issues" stated in Section 5.0 of Vol. I.
These Issues Include sludge management, off-site transportation, disposal of
potentially contaminated Harbor sediments, tunnel versus pipeline construc-
tion, and other areas discussed In Wlnthrop's technical comments. These
issues were segregated from the major decision on the selection of the final
siting alternative on the basis that they will not influence the siting
decision. That argument is flawed alnce they failed to look at each.
alternative and their Impacta in their entirety. These Issues are not
dlacrete and will Influence the siting decision. Conversely a altlng
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MCGREGOR. SHEA & OOLINER
15
MCGREGOR. SHEA & DOLINER
i
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decision may dictate a solution to those iesues outlined above. It !•
imperative tact each alternative be thoroughly examined by the entire matrix
of environmental Impacts and mitigating meaeurea. All factors affecting
altlng must be looked at In one comprehensive document and should not be
aegregated and treated In a aeparate decision making proceas. The process
described in the SDBIS vlll result In a siting decision which Is baaed on
Inadequate information since decisions on Items that are clearly related to
siting have either been put off or are being atudled under separate cover.
This also deprives the public from making any serious comments concerning the
siting decision since they will now have to review a multitude of documents In
order to see what the entire decision making process looks like.
Onder the "Generic lesues" Section of Jamea Boyte's December 6, 1983 EN?
Certificate (page 5), the SKIS was to Include a thorough discussion of
mitigation meaaures which Include the questions of moving workers and
construction materials to a site by weter, the potential Impacts and benefits
of barge delivery of chlorine, and odor control. This discussion was to
Include the techniques, feasibility, potential Impacts, and lapacta on coata
for these mitigation measures. The SDEIS falla to dlacuaa any of these issues
in adequate detail. Barging of construction materials sod chlorine aa well as
the busing of construction workers are to be accomplished to the "maximum
extent feaalble", according to the SDEIS. There la no guarantee that these
options will be accomplished. In fact, there are some complicating factors
which may make their implementation difficult. Theae Items, not discussed In
the SDEIS, Include the necessity for a fairly lengthy permitting process In
order to build temporary wharves for barging, which could conceivably add to
the cost of the barging alternative and will disrupt the current timetable for
construction of the treatment facilities. Should these Impediments become
unacceptable, then the barging alternative may become unfeaalble.
Section 4.0 of the SDEIS details the impede resulting from construction
at all of the proposed sites. The traffic section* for each alternative are
baaed on the assumption that barging will occur, thereby having a minimal
affect on traffic through the effected towns. If varioua contingencies occur
which preclude the option of barging construction materials into the work
site, such es permitting problems and coat, the Impacts will change signifi-
cantly. All towns will realize significant adverse traffic Impacts. The
SDEIS cannot aaaume that certain mitigation meaaures will be Implemented
without studying the feasibility of utilizing them. Regardleea, It Is
Incumbent upon the project proponent to analyze environmental Impacts that
would result In the abaence of mitigation measures. Since there la Inadequate
discussion of Impacts reaultlng from construction traffic through the towns,
the project proponent will be required to submit additional Information
concerning the traffic Impacts that would result If barging no longer becomes
feaalble. The HEFA regulatlona, at 301 Qffi 10.16, require that If a project
change occurs which would significantly Increase the environmental
consequences, the Secretary may require additional Information.
Issues for this option to determine if on existing information alone it should
be ruled out. If costs.alone do not clearly generate Lt from, other, ontiona.
other reasona. for atate. and local, oppoajltlon to.Xhat option, ahall.hu
considered1*. (Emphasis added.) This statement clearly resulted in e blaa In
the SDEIS against any Long Island treatment- facility, thereby resulting In a
more favorable analysis to the other alternatives. This section of the scope
and the SDEIS focuses such of Its sttentlon to problems in altlng a facility
on Long Island. As the SDEIS notes throughout its entirety there are problems
with all of the selected alternatives. There la, however, a noted slant In
detailing problems with s Long Island site. This skewing of the analysis does
not result in e document that can be fairly Interpreted by the reviewing
public. A much more objective analysis of the alternatives is needed and we
expect that the Final Supplemental BIS will contain a more objective analysis.
When compared to the other alternatives, the Long Island proposal does have
Its attrlbutea aa well, and those should be examined In detail.
V. COHCUISIOM
The Town of Uinthrop fully expects that the SDEIS' flaws and deficiencies
deacrlbed above will all be corrected in the FSEIS. A legally and sufficient
rSEIS Is the minimum base instrument under which the town may participate in
and aasess the Important siting and implementation decisions facing it and the
Commonwealth. Any decislona or actions taken under an Inadequate or flawed
VSEIS will be vulnerable to challenge.
Sincerely.
Ralph R. Wlllaer
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TOWN
ROBERT A. DELEO, Chtlrmtn
RONALD V. VECCHIA
ROBERT E. NOONAN
MARIE T. TURNER. Secretary
WINTHROP
TOWN HALL
WINTHROP. MASS. 02152
848-1077
Mr. Michael R. Deland, Regional Administrator
March 13, 1983
-2-
OFFICE OF THE
BOARD OF SELECTMEN
March 13, 1985
THOSE ISSUES THAT FAVOR THE LONQ ISLAND SITE FOR FUTURE
UASTEMATER FACILITIES
tsj
I
Mr. Michael R. Deland, Regional Administrator
U.S. Environmental Protection Agency
J. F. Kennedy Federal Building
Boston, HA O22O3
Dear Mr. Deland:
Winthrop's technical response to the SDEIS is provided bv mean*
of thl» letter, which incorporates the input of our engineering
consultant, S. David Eraber. Our technical response also
includes the written statement of Richard C. Larson, Mho is a
Hinthrop resident and Professor of Urban Studies and Co-Director
of the Operations Research Center at MIT. Dr. Larson's statement
was submitted at the Public Hearing on February 28, 19BS. Our
legal response is contained in the separate letter from our legal
consultants, the firm of McGregor, Shea I Doliner.
We also Mish to state that the numerous verbal and written
responses provided by the citizens of our Town and the separate
letters of the members of this Board are regarded by us as being
of equal if not greater importance than this technical response.
We trust that they Mill be given full and equal attention.
A guid* to our DETAILED TECHNICAL RESPONSE is presented first,
organized under the following headings:
- THOSE ISSUES THAT FAVOR THE LONG ISLAND SITE FOR FUTURE
WASTEWATER FACILITIES.
- THOSE ARGUMENTS WHICH'HAVE BEEN ADVANCED IN FAVOR OF A DEER
ISLAND SITE WHICH ARE REFUTED.
- ISSUES IMPORTANT TO ALL ALTERNATIVES.
With the exception of the fairness and implemented!1ity
discussions included in the guide, the guide simply references
the pertinent section or subsection of the DETAILED TECHNICAL
RESPONSE. Where section titles are listed without ampl ifTcatVarft jC
the reference is simply to the section of that title. ' •" '. •>~'-\
Fairness
The fairness issue was thoroughly addressed at the Public
Hearing, and needs little amplification here. As was
emphatically stated at the Hearing, the Town of Wlnthrop has
shouldered the burden of major regional facilities, including the
Dmmr Island Prison, Dew Island Sewage Treatment Plant, and Logan
Airport. The SDEIS state* the case well when it says: "Together
the cumulative effects of the regional facilities on Deer Island
and at Logan Airport, all in close proximity to Winthrop and
paticularly the Point Shirley and Cottage Hill neighborhoods,
have caused • serious decrease in the quality of life for
residents.* The adverse effects of the Deer Island Plant on
Winthrop have included severe degradation of our coastal waters
and beaches, loss of recreational resources, threats to our
health, severe odors and other air quality impacts, noise,
disruption due to fires and frequent emergency conditions at the
plant, and disproportionate monetary costs.
It is time for all agencies concerned with this issue, all
municipalities in the MDC Sewage System and, most of all, the
City of Boston, to share the burden that those of us in Winthrop
and Quincy have borne for too long. By any standard of fairness,
and considering all the other issues involved, we believe Long
Island must be the site of future wastewater treatment
facilities.
Implementability
The implementability of expanded wastewater treatment facilities
at Deer Island was also a subject of the Public Hearing. We
respectfully suggest that new wastewater treatment facilities
would be ouch easier to implement at Long Island, and request
that the SDEIS so reflect.
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Mr. Michael R. Da land. Regional Administrator
March 13, 1983
Mr. Michael R. Da land. Regional Administrator
March 13, 1983
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Construction Noise
Our technical response addresses existing noise conditions,
projected noise conditions, and noise mitigation. The subsection
on Noise - Projected Noise Conditions - Construction pertains.
Ode
Please see the section on Odors. We also refer you to the
odor/noise survey conducted by the Winthrop Concerned Citizens
Committee, which is being submitted separately.
THOSE ARGUMENTS WHICH HAVE BEEN ADVANCED IN FAVOR OF A DEER
ISLAND SITE WHICH ARE REFUTED
Land Use and Recreational Opportunities
Historic and Archaeological Resources
Economics — Comparative Costs o-f the Alternatives
Air Quality
ISSUES IMPORTANT TO ALL ALTERNATIVES
Visual Quality - Drumlin, etc.
Disproportionate Costs to Nearby Communities and Compensation
Reduction in Property Values and Tax Base
PI ease me* the subsect i on ent i11 ed Economi c* — Di aproport i onate,
Costs to Nearby Communities and Compensation.
Transportation
Visual Quality - Mitigating Measures
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Mr. Michael R. Del and, Regional Administrator
March 13, 1983
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nr. Michael R. Del and. Regional Administrator
March 13, 1983
Sludge Management
to
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narina Environaant
nitigation o* Conitructian Noi»
Suggestion* for additional «itigation of conmtruction noi«« ar«
givan in th» mubsection on NoiM - No in* Mitigation.
Not** DUB to Plant Operations
Pl*as« mem the sub a vet ion on Noise - Projected Noise Conditions -
Plant Operations !• Traffic. We also refer you to the odor/noise
survey conducted by the Winthrop Concerned Citizens Committee,
which is being submitted separately.
DETAILED TECHNICAL RESPONSE
Transportation
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Mr. Michael R. Del and. Regional Administrator
rUrch 13, 1983
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nr. Hichol R. Del and. Regional Administrator
March 13, 1963
th* beach at Point Shir 1 By ar* very bothered by noise from thorn*
engines (which im mentioned on p. 12.6-13 of the EDEIS).
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Noise
Th* topic at noiM is evaluated below under the headings of: (1)
existing conditions, (2) projected conditions, and (3) Mitigation
matures.
EHiSllDfl-NfllBe-CfiQlltllBQa
The SDE1S
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Mr. Michael R. Del and. Regional Administrator
March 13, 1985
Mr. Michaml R. Del and. Regional Administrator
March 13, 1983
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A reasonable noise standard for prevent purpose* would be 33 dBA
at a receptor location am dimtant fro* thm plant »>tm(») am thm
2OOO—feet dimtancm between Point Shirlmy and thm Ommr Imland
•it*. * An attmnuatmd noise level of S dBA Immm than thim at thm
same receptor location dum to treatment plant noimm mourcBm
mhould result in an acceptably IOM increase in thm noimm level.
Thum a 33 - 3 - 3O dBA attmnuatmd not mm Imvml at thm rmcmptor
location should be acceptable. With proper attention during
design, much an attmnuatmd noimm Imvml should bm attainablm.
However, a simplm example Mill demonstratm thm need for such
attention. A group of dimsml engine* could generate thm
equivalent of 9O dBA within 1O feet of thm effective source,
which would bm attmnuatmd to 76 dBA at thm plant periphery if thm
source was located 3O fmmt from that periphery. A distance of
2.OOO feet Mould result in a 32 dBA attenuation2 of an effective
noise source 3O feet inside of thm plant periphery. Thus thm 76
dBA noise would only bm attenuated to 76 minus 32 - 44 dBA, which
Mould bm mxcmssivm. Although this example is hypothetical it
should make thm point that thm location and magnitude of all
significant noise sources that could act in concert at new
facilities would have to bm considered in design.
The best thing that the SOEIS could do at this stage is accept a
criterion of the type suggested above, and make a commitment to
conduct an analysis in thm design phase sufficient to
demonstrate, with mitigation, compliance with that criterion.
The present muffler noise situation should also be noted. In
that connection, it should be recognized that unforeseen noise
problems may arise, and the test of thm Authority's sincerity in
such a casm would be their preparedness to make necessary changes
if that occurred. The MDC's performance in this regard (relative
to the muffler problems) has left much to be desired. There is a
good likelihood that diesel engines would be provided to drive
generators at any new treatment facility (see the discussion of
diesel engines in the section on ODORS in this document).
1. The revised Fast-Track report concurred with this standard! it
stated: "Any new improvements should consistently strive for a
dBA value of 33 or less in Uinthrop to assure against
community-related impacts."
:. 20 Iog(d2/d1> - 20 log (2OOO/3O) - 32.0
In order to prmvmnt operating-noise problems, attention Mill have
to be given to this area in design. Thm selection of types of
equipment and equipment specifications can be important in this
regard. Diesel engines, motors, air blowers and compressors are
among the potential problem areas. Diffused-air aeration for
secondary treatment would bm much less likely to cause noise
problems than mechanical aeration (although mechanical aeration
would probably not be smlmctmd- for a plant of this sizm for comt
reasons).
Construction. The SOEIS (pp. 6—13 to 2O> assesses construction
noism by estimating construction-noise levels at the plant sites
(SO feet froa the equipment) with and without mitigation, then
calculating the attenuated levels resulting at residential areas
from construction at thm different sites.
Thm estimatms of construction noise levels at the plant sites are
reasonable, with and without mitigation, fg.C_iadiyid.yal_UQita_et
CaaSiCUCSlQO_fi3nlQSBOt. **• agree that the mitigation applied to
individual units of equipment probably would lower their
sound-pressure levels by 1O dBA. However, multiplm units working
in concert could generate significantly higher noise levels. For
example, ten identical or similar units working in close
proximity to each other could cause a noise level lOUog 1O> » 1O
dBA higher than an individual unit, causing the total mitigated
noise level to be the same as that of an unmitigated single
unit. The large size of this project must be considered in
projecting noise levels.
Referring to Table 12.6-8 of the SDCIS, and considering the
above, it would seem more reasonable to consider the unmitigated
figures as being representative of the combination of mitigated
equipment. On that basis, the nearest residences In Point
Shirley would be subjected to a 36 dBA "typical" noise level and
69 dBA "worst case" noise level. This is, respectively, 11 and
24 dBA higher than the ambient day-time standard suggestmd above,
which corresponds to a moderate to severe impact according to EPA
criteria (see below). Considering the duration of construction
in this case (see below), these might be better characterized as
severe to extremely-severe. (Me must take the strongest
exception to statements on pp. 4-9 & 1O of the SOEIS in light of
the above.)
Table 12.6-8 indicates that construction at Long Island would
result in unmitigated (or realistic mitigated, considering
multiple units) noise levels at the nearest residence in Squantum
of 4O dBA "typical" and 33 dBA "worst case". A point worth
noting in this connection is that Squantum is really no closer to
Long Island than Point Shirley. In fact, measured from the water
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Mr. Michael R. DaIand. Regional Adairtistrator
March 13, 1983
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March 13, 19B3 (
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tank hill at the center erf Long laland (Mhich is the appro*loat*
center of the proposed Long laland traataent plant), Point
Shirley is tha closest residential araa, followed by Hull Hiqh
School and the Pemberton section at Hull, than Squantua. The
edge of tha Squantum residential area and the center of Point
Shirley are approximately equidistant, at about I2.3OO feet from
Long Island.1 This "typical* noise level would probably not be
audible at all at the residential areas. The Horat case noise
Mould probably be audible, and Mould correspond to an increase of
appro*iaately 8 dBA above the aabient 'standard* suggested
above. Thus even this -level Mould correspond to a moderate
nuisance at adjacent residential areas.
The *worst case' Mitigated noise levels referred to in the SDEIS
pertain essentially to impact tools, including pile drivers,
pavement breakers, jackhammers, and rock drills. It should be
noted that pile driving (one of the noisiest construction
operations) is planned for the Fast-Track construction (pile
foundation for the addition to tha power plant building), and
there is good probability it Mould be necessary for further
expansion at Deer Island. Additional noise mitigation, beyond
that assumed in the SDEIS, is possible for such operations (see
below).
Another point that should be aade is that there is a great
difference betMeen the impact of noises on people residing in an
area coapared to elective, occassional, seasonal visitors'to a
recreational facility (be it at Long Island or Deer Island).
No aattar how the numbers are manipulated, the conclusion that
Deer Island construction Mould result in much greater residential
noise impact is inescapable. In this regard, the SDEIS
Chapter IV- stated the following:
"Facilities at Long Island are therefore least likely
to lead to noise complaints. Facilities at both Deer
and Nut Island will likely result in noise complaints
because of the closer proximity of the'residences.
Point Shirley near Deer Island is an araa already
subject to. frequent high noise levels as a result of
jet traffic from nearby Logan Airport. Construction
noise and noises resulting from operation of treatment
1. Page 12.6-14 gives a distance of about 12,OOO to nearest
residences, Mhich is said to be "six times the distance between
Point'Shirley and Deer Island*.
facilities are therefore more likely to be perceived as
problems at this site."
With regard to noise and all other construction-related impacts
(transportation, etc.), construction durations referred to in the
SDEIS (e.g., 7 years for all Deer Island, B - 9 years for all
Long Island, etc. — see Table 4-1 and 4—2) refer only to Initial
construction. (Under the section on Economics MB question the
Long Island construction duration.) There Mill be periodic (on
the order of every 13 years) needs for major upgrading, and the
possibility of expansion construction in the future.
A final point to be made regarding noise impacts concerns the
standards and criteria that may be applied to such impacts. The
criteria that come closest to being realistic for a project of
this magnitude (and in an area with a high "average" noise level
biased by aircraft overflights) are tha criteria stated in the
section on Community Noise Criteria of EPA's "Direct
Environmental Factors at Municipal Wastewater Treatment Works"
(cited above): 'If the noise is O to 3 dBA higher [than ambient],.
little or no impact may be expectedl if 3 to 13 dBA higher,
moderate iapact may be expectedl and if 13+ dBA higher, severe
Impact may be expected."
SDEIS Section 12.6.3 gives the follOMing standards and criteria:
- City of Boston Noise Control Regulations (Table 12.6-3),
Mhich, in addition to nona-construction noise regulations.
Halt construction noise in residential and institutional
areas to an L.- level (level exceeded 1O percent of tha
time) of 73 dBA and a maximum noisa level at the affected
property line of 86 dBA. Depending on the nature of the
noise, these could be very bothersome noise levels. Note
also that the Regulations apply to tha 7 An to 6 Pn period,
with Mork during other times and Sundays requiring a
permit. Although it is not stated in the SDEIS, pile
driving is exempt from the maximum, noisa regulation.
- The EPA criteria presented in Table 12.6-4 are referred to
as "yearly average equivalent sound levels*, and pertain to
hearing damage and activity interference. Those "average"
levels are already exceeded in Winthrop due to aircraft
overflights. Such criteria are not useful in Winthrop.
Tha only State standards are tha limited DEQE requirements.
applicable primarily to operations noise. As described on
page 12.6-1O, they limit the increase in broadband noise
level to 1O dBA above ambient (corresponding to L9Q) , and
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Mr. Michael ft. Del and. Regional Administrator
March 13, 1963
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Mr. Michael R. Daland. Regional Administrator
Harch 13, 1983
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also establish limits tar puretone conditions.
The SDEIS (p. I2.6-1O) elates that application of the City of
Boston standard* on Deer I ml and would serve to protect Minthrop.
The only practical May that these standards could be of benefit
is if they Mere ap'plied at the prison boundary closest to the
treatment plant (or better still the boundary of the treatment
plant property), and CBQtlQyaua monitoring and enforcement are
required. Even then, this standard and the others given in the
SDEIB are not at all appropriate in our opinion. The EPA
criteria mentioned earlier arm* Much more suitable.
Irtffic. The SDEIS promises to barge Materials and bus
construction workers as the principal Mans of reducing
construction-traffic noise. Concerns over the qualifications
attached to the barging "promise", the feasibility of barging,
and hence the en tent to Mhich it Mould actually be used are
stated in the Transportation section of this document. It is
also noted in that section that barging of Materials has not been
indicated to the extent that it could bel further reductions in
the numbers of trucks should be possible with barging.
Other comments made in the Transportation section also apply
here, as do comments made above about construction duration.
Under Section 12.6.3, it is suggested (among other things) that
Mork at Deer or Long Islands be scheduled during daylight hours
(7 AH to 6 PM> , Mith a special permit being required from Boston
for work outside those hours Including Sundays and holidays. The
1982 Site Options Study said that land-based construction work
Mould take place 3 days per Meek from B AM to 4 PH, "although the
contractors may vary the Morking hours as needed throughout the
construction period". More stringent controls should be
requiredl on a project of this type a contractor could easily
fall behind and start Morking extra hours.
The noi se— mi ti gated equipment referred to in the SDEIS Mould have
to be carefully specified in construction contract documents.
along Mith a vigorous noise control program.
Mitigation of noise due to impact tools may be feasible to a
greater degree than assumed in the SDEIS. In place of pile
driving, holes can sometimes be bored to bedrock and reinforced
concrete piles poured in place. The SDEIS should revieM
available geotechnical data to determine the depth to bedrock and
feasibility of such an alternative.
Odors
In Secretary Hoyte's certificate on the ENF for the Site Option
Study (September 9, I9B3) he stated his expectation for a
thorough discussion of odor control, including techniques,
feasibility, potential impacts, and impacts on costs. That has
not been done.
Section 12.7, entitled Odor Analysis, is provided in the SDEIS.
Its four pages give an absolutely minimal treatment in terns of
quantity and content. Note that odor has been reported to be
the number one public concern Mith regard to MasteMater treatment
facilities. Large and, in some cases, relatively new wastewater
treatment plants have had to be abandoned because of public
outcries over odors.
The SDEIS should adequately address odors from the standpoints
of: (1) existing Conditions, (2) projected conditions, and (3)
mitigation measures. It is inadequate in all of these areas.
In addressing existing conditions, the SDEIS (p. 1-17)
acknoMledges the "odor...problems Mhich have plagued the
adjoining neighborhoods of Houghs Neck in Quincy and Point
Shirley in Minthrop", and states (p. 12.7-1) that the odors
resulting in the most complaints due to Deer Island facilities
are diesel fumes from generators and occasional chlorine vapors
from chlorination system leaks. Discussions Mith members of the
Winthrop Concerned Citizens Committee and their odor survey
.results indicate that odor problems are much more extensive than
indicated in the SDEIS, and are a major concern to the Town.
Odors in the Cottage Hill and Point Shirley neighborhoods of
Minthrop have been a severe problem.
It should also be noted (see SDEIS pages 3-28 8. 24) that septic
sewage odors have been a particular problem at Nut Island due to
1. Sullivan, R.J., "Preliminary Air Pollution Survey of Odorous
Compounds," PH 22-68-23, U.S. Dept. of Health, Education, and
Melfare, October 1969.
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Mr. Michael R. Deland, Regional Administrator
March 13, 1983
Mr. HichMl R. OB!and, Regional Adalnistrator
March 13, 1983
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the long distance* the sewage must travel In the HOC South System
before reaching the Nut Island Plant. This potential would b«
even greater at Deer Island if South System seMage Mas piped
there.
Projected conditions ars discussed in a cursory fashion in
Section 3.2.4 (Air Duality and Odors). Figure 3-4 purports to
show the three highest percentages of prevailing summer Hinds,
Mhich comprise a total of 72X of prevailing summer Minds, and
indicates that Minds Mould be in the direction froa Deer Island
to Point Shirley 13X of the tine. Section 12.7 (ODORS) provides
Figure 12.7-1 Mhich shoMS percentages of seasonal Minds for each
of 16 compass points, separately for summer and Minter. Section
12.7 states essentially the folloMing Mithout reference to
specific sites:
- Odors caused by QQCflsL-fiBlCstiBQ! Mould be slight
the sites.
at any of
Infrequent odor probleas Mill occur in spit* of odor control
•4ts.ftur.tft as * result of in.tdaqu.ito Maintenance, equipment
breakdowns, or process upset*. Odorm due to anaerobic
influttnt( periodic cleaning of haadMork*. chlorine leaks
Mith prechlorination (at headMorks), and sludge facility
Maintenance procedures are also aentioned.
With prcx.pt
supervision, odor
duration.
ial
leaf
action and close operational
s Mill be infrequent and of limited
- Diesel engines Mould not be used for the neM facilitiesl
therefore, no further problems with odors froa diesel fumes
Mould occur. tIbil_i.a_nst_SBCrgst_z_aea-6filSMi]
- The potential for odor problems Mill vary directly Mith the
size of the facilities and the number of treatment
components located at each site. CJh,i.3 __ j.g __ a.n __ iGQQrtant
___-_
thi.n! Mould attenuate these
effects soaeMhat." (Underlines added.)
Under Section 4.6 (ADVERSE EFFECTS WHICH CANNOT BE AVOIDED), the
following is stated:
Occasional odors are likely to result froa process
upsets in proposed facilities at all sites regardless
of the level of treatment. For the aost part, these
temporary iapacts Mould be moderate and of limited
duration at nearby receptor areas. Nearby residents of
Quincy Great Hill on Houghs Neck and the prison
population on Deer Island aay be most affected by
unpleasant odors! odors aay also result on Point
Shirley, and to recreational visitors and the hospital
population on Long Island, Mhich are farther away from
the respective treatment facilities."
We have a copy of an interesting letter from James Gutenaohn,
Commissioner of the Department of Environmental Management, to
EPA, dated October 3, 1983. In opposing the use of Long Island
for MasteMater treatment, Mr. Gutensohn states the following:
"...it is important that the siting of... treatment
plants does not negatively impact the major
recreational resource, Boston Harbor State Park....The
impacts of the plants on the park that concern DEM the
most are those of sight and smell. It Mould not
benefit the park and the thousands of people it serves
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Mr. Hich»l R. Del and, Regional Administrator
March 13, 1983
Mr. Ml chad R. Da lend. Regional Administrator
Harch 13, 1983
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to haw the plant* be • negative visual Impact or
produce foul odor•. ...Based on our understanding of the
siie and external Impacts of a facility we feel the
uses [Na»toMater treatment and recreationl are
incoepatible."
We maintain that there is a euch higher degree of incompatibility
between wastewater treatment and residential land uses than
between Mastewater treateent and recreational use.
Without knowing what specific Mitigation eeasures are proposed,
it is impossible for us
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Hr. Michael R. Del and. Regional Administrator
March 13, 19B3
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Nr. Michael R. Del and. Regional Administrator
Harch 13, 19B3
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That statement, Mhich was omitted (ram the published SDEIS,
coincides Mith the conclusions drawn above.
10
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Under Section 2.3 (CONDITIONS PLACED ON THE ALTERNATIVES
REMAINING), it is said that odor control equipment Mould be
included at all sites. Mitigating measures are not discussed in
any detail. Section 12.7 merely stating (p. 12.7-1): -Odor
control measures Mill be required at all sites, including
enclosed facilities and special ventilation systems for treatment
components where odors may be produced."
Section 12.4 (Engineering Cost Estimates) presents some cost
estimates for odor control facilities. It would appear from the
unclear presentation on pages 12.4-7, B, fc 11 and Table 12.4-3
that the SDEIS did little more than use earlier costs developed
in the 1982 Site Options Study. SDEIS Table 12.4-3 includes a
capital cost of S17,O7O,OOO for odor control equipment at each of
the primary or secondary treatment plant locations. In the case
of the split plant options, that cost figure is shown twice, once
at each of the plant locations. That certainly makes the split
treatment options look more costly, and it is probably true that
odor control Mould be less costly at consolidated facilities!
'however, doubling the cost of odor control for split treatment
seems incorrect. It is also debatable whether the same degree of
odor control would be necessary at Long Island as at Deer
Island.
The cost of headworks odor control is shown as »74O,OOO at Nut
Island! that figure is combined into the treatment plant odor
control cost for Nut Island treatment plant alternatives. For
options that would leave only headworks at Deer Island, the odor
control costs at that location are given as «22O,OOO. The
specific equipment assumed in developing these costs is not
stated. The identical costs assumed for odor control at primary
and secondary treatment facilities could imply that no odor
control of secondary treatment components is intended. Further-
more, the mere doubling of odor control costs at split treatment
facilities suggests that containment as a component of odor
control was not considered.
Odor control can be provided to varying degrees, and assumptions
of the SDEIS should be stated explicitly. Furthermore, different
types of equipment may vary in their odor producing potential.
and can be selected accordingly (examples include
velocity-controlled vs. aerated grit removal and air vs. water
agitation of channels conveying primary influent and mixed liquor
suspended solids). These considerations should be addressed.
The more effective means erf odor control entail containment
(providing covers over odorous treatment components), and venting
of the contained air to air-treatment units. Any facility at
Deer or Nut Island, whether a pumping station or treatment
component, should be fully contained and have the most complete,
state-of-the-art equipment available.
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Harch 13. 1983
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March 13, 1983
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Air Quality
Section 3.2.4 of the 80EI8 addresses air quality in a vm-y
cursory fashion. Sludge disposal im a major component of
potential air quality Impacts, as discussed in the section on
Sludge Management later in this document.
Aside from sludge Management issues of air quality, and questions
of odor as discussed above, potential air quality impacts are in
the areas of: U> traffic-related air pollution due to
plant-induced traffic! and I2> harmful emissions from liquid
processing facilltes is a clear concern, and adds weight to arguments in the
area of transportation as discussed elsewhere in this document.
Item (2) gets us into an area that has emerged fairly recently in
the technical literature. It has been dealt with more as an
occupational health issue relative to treatment plant workers,
but could impact adjacent residential areas, and do so even more
than plant workers if stacks associated with odor control
equipment cause greater exposure off-site. What is at Issue here
is: (1) the recognition that aerosols containing pathogenic
microorganisms are released at wastewater treatment plants. and
(2) that a substantial fraction of many of the volatile organic*
"removed* at wastewater treatment plants are "stripped" into the
atmosphere rather than being wasted with the sludge. Such
stripping occurs to a degree at plant headworks, and probably
more so in the aeration tanks employed for secondary treatment.
EPA has sponsored numerous studies in this area. This issue is
scarcely acknowledged in the SDEIS, the only related reference
being on page 11.3-9 which notes that "high percent removals for
most volatile organic compounds, including many solvents. are
consistently reported for secondary treatment plants. This is
probably due to volatilization (evaporation) in the secondary
treatment aeration tanks."
Recent references on this subject include:
U.S. EPA, 19BO. "Wastewater Aerosols and Disease."
EPA-tOO/9-80-028. U.S. EPA, Cincinatti, Ohio. December I98O.
(Included are such topics as "Worker Exposure to Organic
Chemicals at an Activated Sludge Plant*.)
- Lurker, P.A., Clark, C.8.. and Ella, V.J., 1982.
"Atmospheric Release of Chlorinated Organic Compounds from
the Activated Sludge Process*, Journal Water Pollution
Control Federation, December 1982.
- Kincannon. D.F., Stover, E.L., Nichols, V., and Medley, D.,
"Removal Mechanisms for Toxic Priority Pollutants*, Journal
Water Pollution Control Federation, February 1983.
— Cannon, R.E., "Aerosol Release of Cyanophages and Conforms
from Activated Sludge Basins", Journal Water Pollution
Control Federation, August 1983.
- Roberts, P.V., Hunz, C., and Dandliker, p., 1984. "Modeling
Volatile Organic Solute Removal by Surface and Bubble
Aeration", Journal Water Pollution Control Federation,
February 1984.
Pathogenic spores released fro
been detected quite recently.
composting operations have also
The public health concerns related to the above strongly favor
the Long Island site, with its relative isolation from
residential areas. Even at the Long Island site, adequate air
monitoring should be provided for at least the full range of
priority pollutants that might be volatilized, and for pathogenic
microorganisms. For the same reasons, secondary treatment
aeration should be by means of diffused-air or pure oxygen
aeration of high oxygen-transfer efficiency, to reduce the
emissions potential compared to mechanical surface aeration and
lower efficiency diffused air systems. If secondary treatment
facilities were located near residential areas, covers should be
provided for process units that could emit the aerosols and
volatile organic-, of concern and so that, in conjunction with
odor control equipment, the off—gases may be treated to remove or
inactivate these substances. Considering the size of the
facilities, this would be a prudent approach if the facilities
were located in close proximity to residential areas. The
centralization of off-gases would also facilitate the monitoring
referred to above.
The section on Transportation in this document addresses the
issue of chlorine leaks from the Deer Island Plant and potential
problems with the transporting of chlorine through Winthrop.
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March 13, 1983
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Transportation
The transportation issues can be broken down into those
transportation during construction and transportation related
plant operation.
of
to
Section S.3 of the SOEIS (also not*
states the following:
Section 2.3 and p. 12.2.2-1)
"The largo aiza of the waototdater treatment facility
construction project combined with the difficulty of
roadway access to the various facility locations under
consideration has led to the conclusion that barge
transportation of heavy equipment and materials to and
froai the selected site(s) be required tg.tbl-QaaiSyg
S&tBQt-iaalikLS to limit the adverse environmental
inpacts of the project. As a result, EPA and the
Commonwealth have eade the above commitment a condition
of the project's funding. In addition, barging may
also be warranted for sludge management." Cemphasis
added]
Noting that barging will require the establishment of one or eore
land-based barging termini. Section 3.3 then goes on to say that
"Cover] 2O sites along the Greater Boston waterfront and as
distant as Rhode Island and Maine have been considered by the
MDC's consultants, but none, so far, have been found to be both
suitable and definitely available for such future use." Thus,
barging may not prove feasible, in which case the above
commitment means nothing. Section 4.3.2.a addresses further the
difficulty of finding barging sites. The cost of such barging is
estimated to add *2O M to S4O M to the cost of construction.
Availability of funds could affect feasibility.
Section 3.3 further states that: "This unresolved issue will be
studied in detail by both the HOC and EPA as part of further
planning for this project, including evaluation of the environ-
mental acceptability o< all parts of the barge transportation
system." Page 12.2.2-4 states that "specific impacts of such
added facilities at prospective locations will be addressed
during final facility design".
The barging issue should be resolved as part of the BOEIB, rather
than IMCfQltd into another part of the process. If barging is
not implemented, then the concerns expressed in relation to
traffic associated with normal plant operations (see below)
become greatly magnified in connection with plant construction.
(Pages 12.2.2-1 to 3 gives estimates of the large number of
trucks, etc.) It should also be noted that the land-based
barging terminal could involve marine construction approvals and
consequent delays or even disapproval (note SOEIS pages 11.2-9,
1O, etc.). At the very least, there must be an iron-clad
commitment to barging of all construction materials, disposed
equipment, and excavated materials not used at the construction
site, plus busing of construction workers.
In Secretary Hoyte's certificate on the ENF for the Site Option
Study (September 9, 1983) he stated his expectation for a
thorough discussion of the moving of workers and construction
materials to a site by water and the potential impacts and
benefits of barge delivery of chlorine, including techniques,
feasibility, potential impacts, and impacts on costs. With
regard to m land—based barging terminus, he stated the following:
"Although a construction staging area cannot perhaps be
selected, the Draft Supplement should identify the
criteria necessary for such an area—such as parking
area, storage area, utilities, highway access, water
access, and water travel .time to the construction
site(s) (I expect that during preparation of the Final
EIS, more progress can be made in identifying actual
sites)."
Secretary Hoyte's requirements have not been met.
The busing of construction workers is also promised "£g ttlB
St&loya talSQt IsasiBlS" (Section 4.3.2.b>. The cost of such
busing is estimated to add »IO n to »2O n to the cost of
construction. Again, availability of funds could affect
feasibi1ity.
There would still be significant truck traffic according to the
plan presented in the SOEIS. However, the proposals on pages
12.2.2-3 <> 6 do not seem logical. A one-week startup period of
trucking to begin excavation work is proposed, immediately after
which barging could be accomplished. This is said to avoid
costly delays, etc. If the barging capability would be available
in one week, such a delay would be of no significance. More
realistically, construction of a pier would be required (if not
completed during Fast-Track in the case of Deer Island) and this
could entail an initial period of trucking far more extensive
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Mr. Michael R. Del and. Regional Administrator
March 13, 19BS
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Hr. Michael R. Dal and. Regional Administrator
March 13, 1983
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than indicated. A realistic plan should be presented for the
Deer Island and Long Island alternatives, and it. should be noted
whether the existence at a pier at Long Island presently confers
a significant advantage to that site (this also relates to marine
impacts). Truck volumes and iepacts with barging alternatives
are estimated on pp.. 12.2.2-3, 6, 8, 9, 1O. 13, 14, and 171 also
note Table 12.2-4, which does not appear to be referenced in the
text. Inspection of Table 12.2-2 suggests that those volumes
could be further reduced. Note, for instance, that trucking of
cement and reinforcing steel is indicated, where these could
readily be barged along with concrete aggregate. Additional
reductions in trucking voluaes may also be possible.
Section 4.3.2 of the SDEIS addresses construction traffic
•itigation in addition to the barging of Materials and busing of
construction workers. Sections 4.3.2.e, f, g, h, and i address
truck and bus traffic control (also note p. 12.2-13 & 16), street
repair, structural improvements to roadways, improvements to
roadway routing, and other measures. Beyond what is said there,
are mitigation measures of the type Uinthrop has requested (and
expects) in connection with Fast-Track construction! these
include adequate compensation for traffic control and police
escort services, coordinating with infrastructure construction
work Including compensation (for contractor extras, etc.),
compensation for loss of Urban System Project Grants, and
infrastructure assessment and repair (sewers, water mains,
streets, gas lines, etc.). More specificity should be provided
in these areas and in areas such as permissible hours of
land-based construction work. If barging is used to the extent
it should be for a project of this magnitude, some of these
measures might be unnecessary.
The SDEIS (pp. 4-91 !• 12.2-21) states that the Long Island Bridge
is in need of approximately »2 M of rehabilitation work, and that
with "rehabi1itation as proposed" (proposed by whom?) the bridge
would accooodate vehicles required for Long Island construction.
It is said that the Long Island Bridge would only require
restoration to its as-built condition. The Belle Isle Bridge
should also be mentioned in this context. The information which
we have on the Belle Isle Bridge indicates that it also is in
need of major repair, is being gvgr.l.Qa.de.g' by present use
(including chlorine trucks to Deer Island), and would require
restoration above and beyond its "as-built" condition.
The SDEIS notes (pp. 12.2.1-3, 18) that access of construction
vehicles to Long Island can be improved significantly if Quincy
Shore Drive can be used. That roadway is referred to as a four
lane HOC Parkway presently prohibited to trucks. Approval by the
MDC to use this roadway would be a very reasonable expectation.
If such approval is obtained, then the potential adverse impacts
of Long Island construction traffic are said (p. 12.2-2O) to
affect a total of about 223 homes and apartment buildings through
Squantum and North Quincy for approximately 3.3 miles (more
without such approval). The potential adverse impacts of Deer
Island construction traffic is said (p. 12.2-14) to involve about
19O homes and 13 businesses which abut the approximately 2.3 mile
access route through Point Shirley (including the segment of road
leading from Cottage Hill). Have all of the abutting portions of
Winthrop been considered? What about East Boston? We question
the accuracy of the descriptions of the traffic capacity of
Winthrop roadways and impacts of traffic through Winthrop.
We share the concern of our School Committee over the dangers to
school children posed by traffic related to construction and
operation. We also share the concerns of our Chief of Police
regarding the serious ramifications on the police service due to
effects on traffic control, traffic-related accidents, and
traffic-related air pollution. These same concerns would seem to
apply to varying degrees at any of the sites! they provide
important additional reasons for reducing plant-related traffic
to an absolute minimum at any of the possible sites. In the case
of Deer Island, the Town has already been forced to live with the
problems of traffic, etc. caused by the use of Deer Island for
the prison and treatment plant.
One fact that is not brought out in the SDEIS, but which becomes
apparent from inspection of the data in that report, is that
construction of a secondary treatment facility at Deer Island and
relocation of the hospital would result in a net CfidysttOQ of
operations traffic at Long Island .(according to SDEIS data, from
1BO to 86 autos per day with approximately the same number of
trucks.) This should be clearly stated in the SDEIS.
There are a number of transportation issues related to plant
operation that are not addressed at all in the SDEIS. These are
discussed first, followed by discussion of additional
transportation issues.
As noted in the discussion of chlorination under the section on
Marine Environment in this document, if dechlorination is
required then transporting of sulfur dioxide to the treatment
plant could result. This chemical is similar to chlorine in
hazard potential. This transportation implication is not
addressed anywhere in the SDEIS.
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Mr. Michael R. Deland, Regional Administrator
March 13, 1983
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Mr. Michael R. Deland, Regional Administrator
March 13. 1983
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Trucking of fuel to the plant nit* could be significant, and im
not addressed anywhere in th« SOEIS. There ar» a number ai
unresolved issues that come into play in this regard. These
relate to uncertainties in the interrelated considerations of
total plant power requirements and how those requirement* Mill be
•at. Factor* involved ara: the question of laying a Bomton
Edison cable to the plant mi tat hypochlorite generation (which Me
favor) Mould increase energy requireaientsi the questions of
primary vs. secondary treatment and methods at sludge processing
and disposal (which relate both to power requirements and the
availability of Methane and recoverable heat wnich can meet some
of the plant power requirements). These considerations are
important determinants of the extent to which fuel Mould have to
be trucked to the plant site for dual-fuel engines such as the
HOC presently uses to generate all its power at the Deer Island
site. Supplementing digester—gas fuel capacity Mith purchased
electricity and/or barged fuel could eliminate the need for such
trucking. Failure to address these issues in the SOEIS 868960.18
the process.
As noted in the section on Sludge Management in this document,
significant transportation implications are associated Mith
as-yet-undetermined plans for sludge end-product disposal and (in
the case of composting - Mood chips) sludge processing as Mel 1.
Where Mould incinerator ash, compost, or dewatered/treated sludge
by disposed of and what are the transportation implications of
such sludge disposal? Sludge management decisions also bear
significantly on the need to supply fuel to Deer Island and
related transportation impacts, as noted above.
The SDEIS states that the issue of chlorine transport vs. on—site
hypochlorite generation should be resolved during "detailed
facility planning and design", by considering "alternative
disinfection methods and practices to minimize chlorine's toxic
effects on marine life". (See the section on Marine Environment
in this document.) It further states: "On—site manufacture of
sodium hypochlorite from sea water should also be investigated as
an alternative to chlorine transport through populated
neighborhoods.... The facility planning and design evaluation of
different chlorine disinfection alternatives should...consider
the impacts of chlorinated hydrocarbon formation." We do not
believe this issue requires further study. Experience with these
systems elsewhere and studies already completed for the MDC
clearly indicate that on-site hypochlorite generation provides
the most economical £a£e. alternative at any of the sites.
Ue have serious concerns about the safety of chlorine transport
through Winthrop and the use of gaseous chlorine at Deer Island.
Uinthrop requires notification and police escort for present
chlorine deliveries (which often occur mix days a Meek rather
than the three to four times Meekly indicated on p. 3-26 of the
SDEIS). The 1982 chlorine leak from the Deer Island Plant could
have been a serious incident. The consequences of a truck spill
could be immense. The U.S. Department of Transportation's
"Emergency Action Guide for Selected Hazardous Materials" notes,
among other things, the extent of the area that Mould be impacted
by flying fragments if there Mas a chlorine container explosion
(due to the heat of fire) and the large area that Mould have to
be evacuated in the event of a chlorine truck spill. These areas
constitute a significant portion of Winthrop. In November 1979,
2SO,OOO residents of Mississauga, a city near Toronto, Ontario,
had to evacuate after a train derailment which included chlorine
leakage.
The SDEIS (p. 3-29) indicates that Ouincy residents have
expressed concern over chlorine dalivarios to Nut Island. They
Mould probably also be concerned about chlorine deliveries to
Long Island.
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Mr. Michael R. Deland. Regional Administrator
March 13, '19B3
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Mr. Michael R. Deland, Regional Administrator
March 13, 1989
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Visual Duality - Drumlln, ate.
Raduction in Property Values and Tax Base
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Construction of a secondary treatment plant at Deer I*land Mould
necessitate removal of tha Dmmr Island Oruailin (Signal Hill).
Thi» unique geologic formation rises to 1O3 feet above Ma laval,
and in one of the highest formations oi thim typa to ba found on
tha harbor imland*. It affords majestic views of Bomton Harbor.
Tha removal of much a formation Mould ba a travesty, ranking far
above any necessary relocation of gravam on Long Imland. Removal
of the Oaer Imland Drumlin mhould be ammigned a severe, weighting
relative to not only vimual iepactm, but himtoric and geographic
iapactm am well.
We almo Mimh to point out that the SDEIS evaluation of tha vimual
impacts of Deer Imland facilities on Mlnthrop fails to consider
the vieM from the Highlandm in Uinthrop. Thim further increasam
tha negative weighting that should be amsigned to visual impacts
of a Dear Island siting.
Tha negative visual impact of the stockpiling at Deer Island of
grit and scum from the various headworks should be noted.
Furthermore, plans for disposition of that material should be
included in the SDEIS.
We believe that any realistic assessment of the short-term and
long-term effects on property values Mill show that adverse
impacts are uniquely associated with any Deer Island siting. A
Deer Island siting Mill adversely and permanently reduce property
values in Uinthrop, and thus adversely affect the Town's tax
base. We base this on our discussions with area realtors. In
contrast, the remoteness of the Long Island site Mill prevent any
reduction in property values. This must ba assessed by
profemmional real emtata appraisers, and not be based on the
judgements of those lacking expertise in this area.
Chapter 4 of the SDEIS addresses this issue for each
alternative. Under the all—Deef—Island-secondary alternative
(Option la.2 - pp. 4-12 I 13) it is stated that the selling price
of some homes adjacent to Deer 4 ml and may be reduced during
conmtruction, but that property valuam would be expected to
rebound to pre—conmtruction levels after construction is
concluded. It is claimed that during operations new treatment
facilities should abate existing noise, odor, and traffic
nuisances Mith no adverse affect on property values. Table 4-1
draws a different conclusion than the text, indicating for
property values: "DECLINE, HAY NOT REBOUND FULLY". The SDEIS is
inconsistent in its assessment. It should furthermore be noted
that even a decline during construction alone could be
significant, considering the duration of construction. In
addition, odor and traffic nuisances (and possibly noise) could
be significantly greater after construction than they are now.
Sioilar statements are made for the split-secondary-Deer-Island-
&-Nut-Island alternative in the text (Option lb.2 - p. 4-2O) . but
here again Table 4-1 indicates: "DECLINE, HAY NOT REBOUND FULLY"
for both Deer and Nut Islands.
For the al1-Long-island-secondary alternative (Option 2b.l>. p.
4-34 indicates slight, temporary reductions in property values in
Uinthrop and Ouincy (due presumably to demolition and headworks
construction at Deer and Nut Islands, and possibly traffic to
Long Island through Quincy). Table 4-1 indicates: "DECLINE AND
REBOUND" for the three areas affected (considering Hough's Neck
and Squantum separately). Similar impacts on property values are
projected far the split-Deer Island-and-Long-Island alternative
(Option 2b. - p. 4-36 and Table 4-1). Similar conclusions are
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Mr. Michael R. Del and. Regional Administrator
March 13, 1983
Mr. Michael R. Del and. Regional Administrator
March 13, 1989
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also drawi lor Winthrop impacts under the primary treatment
alternatives (Option. 4a.2, 4b.2, Sa.2, 36.2 - pp. 4-61, 71. t
83, and Table 4-2).
On page 12. 1-13, property values In Point Shirley are said to be
suppressed due to it» "location adjacent to Logan Airport, the
Deer Island House of Correction, and Deer Island WasteMater
Treatment Plant*.
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Land Use and Recreational Opportunities
Uhat constitute* necessary or best uses of limited harbor island
environments? WasteMater treatment on harbor islands is a
necessary use for reasons that have to do Mith the topography of
the region (including natural drainage patterns) , the evolution
of the region's sewerage network, engineering/economic
feasibility, and the lack of other IOM— lying areas Mhich are
properly situated geographically. Conservation, and passive
recreational uses compatible Mith such conservation, constitute
important uses of harbor islands. Modern priciples of land use
planning Mould dictate that other institutional uses, including
prisons and hospitals, be located elseMhere. The present uses of
harbor islands for such Institutional purposes is a carry over
from the past, when the islands' remoteness (and abundance of
open space elseMhere) determined the islands' uses.
Given the tMO valid uses of harbor islands (MasteMater treatment
and recreation/conservation) , hOM should Me best plan for such
uses? Planning for harbor land uses should be considered in the
context of all necessary and best uses, and their relations to
other harbor land uses. Consideration of MasteMatef — treatment
planning separate from recreational /conservation planning,
consideration of recreational /conservation planning in the
absence of MasteMater-treatment planning, or consideration of all
of these Mithout regard for compatibility Mith adjacent land uses
Mill not result in sound planning. It is this vacuous planning
that has resulted in conflict between MasteMatet — treatment and
recreation/conservation uses, where no such conflict should
really exist.
An overriding consideration in planning for-these uses should be
the adequate buffering of surrounding residential land uses from
wastewater treatment facilities. Recreational and MasteMater-
treatment land uses are far more compatible than residential and
MasteMater — treatment land uses. A restored Deer Island affords
the same opportunities for recreational /conservation uses as Long
Island . The loss of Oeer Island for recreational /conservation
1. The land area of Deer Island is given on p. 3-33 as 21O acres,
Mith the existing treatment plant occupying about 26 acres. Long
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Mr. Michael R. Del and. Regional Adainistrator
March 13, 19B5
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nr. Michael R. Del and. Regional Administrator
Harch 13, 1983
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purposes should be rated Just am "severe* in th0 SDEIS as the
loss oi Long Island for such purpo»m. Theme considerations
clearly indicate • sound basis for selecting Long Island for
future MastaMater facilities.
Relocation of the Deer Island Prison and Long Island Chronic
Disease Hospital Mould clearly be mandated by eodern planning
concepts. In fact the relocation of both of these facilities has
been proposed in the pasts
- As noted in the SDEIS, recreational plans for Deer Island
contained in the 1972 Comprehensive Plan assumed that the
prison Mould be relocated.
- Page 3-24 of the SDEIS notes the problems that the Deer
Island Prison has posed for Hinthrop, and refers to efforts
to relocate the prison.
- Page 3-33 of the SDEIS notes the deteriorated condition of
the prison, and refers to studies indicating that the most
cost-effective solution Mould be to build a completely n«w
facility.
- The 1972 Comprehensive Plan assumed the relocation of the
Long Island Hospital and the use of that land area for
recreation (Section 12.3.1, p. 27).
- SDEIS pp. 3-44 t 43 notes that past and prevent City
administrations have considered closing the hospital. A
Jan. 19B4 report for Mayor Flynn is said to have proposed
closing the Long Island Hospital in 1969 and consolidating
operations with the City's existing chronic care facilities
at the Mattapan Hospital. (Also note p. 12.1-3 in this
regard.) No future use for the hospital facility Mas
identified.
The Long Island Hospital is currently one of two chronic
disease hospitals run by the City of Boston (the other being
the Mattapan Hospital). BetMeen the two hospitals, there
are 443 licensed chronic disease beds and only 3OO patients!
and of theme 3OO, only 16O are certified to be legitimately
in need of chronic disease care, and the rest are homeless
.(Section 12.3.1, p. 1O).
- Relocation of the Long Island Hospital
placed on the project if Long Island
secondary treatment (SDEIS Section 2.3).
is
a "condition-
required for
Island has an area of 213 acres (p. 3-44), making it virtually
identical to Deer Island in size. Thus, reference to Long Island
as the largest island in Boston Harbor (e.g., p. 12.1-3) is
slightly misleading.
The current recreational plans, embodied In the 1984 Update of
the Boston Harbor Islands State Park Master Plan, are a key
factor in the favoring by tom» (and, MB suspect, not very many)
of Deer Island over Long Island for the siting of MasteMater
facilities. The 1964 Update
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Mr. Michael R. Deland, Rational Administrator
tlarch 13, 1983
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Hr. Michael R. Deland, Regional Administrator
Harch 13, 1983
treatment plant I craatlng open grass areas for playfields and a
children's playgroundI developing a three-mile system at bicycle
trails and extensive walking trails! expanding the present beach
to accommodate ZOO people! developing picnic araasi developing a
aooring area and dock space for 3O saall boatsl and constructing
a fishing pier. The relatively undisturbed eastern half of Deer
Island exhibits the natural beauty that all of Deer Island could
exhibit. Deer Island is the place for recreational/conservation
usesl Long Island is the place for the necessary use of
wastewater treatment.
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1. This remains a valid concept for the interim period during
phased, temporary use of Deer Island wastewater treatment
facilities.
Historic and Archaeological Resources
Section 12.1O 4Archaeological and Historical Resources Report and
NHPA Compliance Summary) addresses both the historical and
archaeological significance of Long Island and Deer Island.
Without meaning to belittle the Importance of such resources, urn
believe that the devotion of 1OO pages and the associated effort
to this topic reflect a thoroughly misplaced sense of
priorities. This is particularly so when compared to the many
significant deficiencies of the SDEIS, not the least of which is
the absolutely minimal four page treatment given to the topic of
ODORS, which has been reported in literature of the U.S. Public
Health Service to be the number one public concern with regard to
wastewater treatment facilities.
Section 12.1O indicates essentially that, although both Deer
Island and Long Island have similar cultural histories (and
probably prehistories), disturbance due to past construction at
Deer Island has resulted in minimal present archaeological value
there, while significant archaeological resources remain at Long
Island. We point out to you that much of the disturbance at Deer
Island has been due to construction of waatewater treatment
facilities.
Section 12.1O and related parts of the main body of the report
(Section 4.3.4 and portions of Sections 4.1 and 4.2 dealing with
"Legal and Institutional Implemantabi 11 ty" (e.g., pp. 4-33 «. 34])
suggest that the archaeological status of Long Island could delay
or impair implementation at Long Island for all except current
Alternative 3a.2 (primary treatment split between Deer and Long
Islands). We feel that is exaggerated and highly speculative.
and that the same might be said of Deer Island if the same amount
of archaeological investigation had been conducted there for the
SDEIS.
The very objectivity of Section 12.1O becomes suspect as a result
of statements outside of the archaeological realm made in the
Summary and Recommendations section. For example, on page 96 it
is stated: "Even at the smallest scale (IB acre facility) the
proposed sewage treatment facility may affect the overall
integrity and character of Long Island."
It is said that some or ail of Long Island is being nominated for
placement on the National Register of Historic Places as a
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Mr. Hichul R. Del and. Regional Administrator
March 13, 1983
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Hr. Michael R. Del and. Regional Administrator
March 13, 198S
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district for prehistoric archaeological resources, and implied
that this connotes some special status to Long Island. As we
understand it, the island system as a Mhole is being proposed for
inclusion on the National Register.
Table 4 in Section 12.3.1 (following p. 23) should be corrected
to indicate the presence of "Existing Historic Structures/Forts"
at Deer Island.
Archaeological resources, although inportant, are of much less
importance than the people affected by the closer proximity of
Deer Island to Hinthrop. The need to remove the Deer Island
Drumlin, a unique geologic feature dating back to the last
glaciation, is also much more important to us than archaeological
remains on Long Island. Much of Deer Island's archaeological
value Mas lost as a result of the closing of Shirley Gut, an
action permitted by Hinthrop in the interest of national defense
during WWII. Consideration is ROM owed Wlnthrop in return.
Economics - Comparative) Costs of the Alternatives
Although the comparative costs of the alternatives are supposedly
not a factor in the site selection, we do consider it necessary
to question or comment on certain aspects of this issue.
Sections 12.4 (Engineering Cost Estimates) and 12.3.2 (Financial
Impacts by Alternative — Treatment Facility Costs) present a
confusing and redundant review of the development of economic and
financial data for the alternatives. Me hope this can be
redressed via responses to our questions and a clearer presenta-
tion in the SFEI8. Some general comments and questions follow:
- Conflicting statements in the SDEIS text and tables (e.g..
p. 4-103. p. 12.4-1, p. 12.4-34, p. 12.3-7, Table 12.4-1,
Table'12.4-3 Table 12.4-&, etc.) make it very unclear as to
what sludge processing and disposal costs have been
included. Mere'sludge thickening and treatment capital and
operating costs included while sludge dewatering and
disposal capital and operating costs were not? The term
sludge "handling* does not appear to have been used with a
consistent meaning. Please define and rectify that.
— The SDEIS states that costs of barging, busing, and other
mitigation measures are not included. These costs should be
included in both the economic and financial analyses to
reflect the commitment that the SDEIS claims to make in
these areas.
A comparison of the revised capital costs for the al1-Deer-Island
(la.2) and all-Long-Island (2b.l> options on Table 12.4-3
indicates that the capital cost for the former comes out sill M
(19X) higher than that for the latter. The costs of primary
settling, gravity thickeners, and anaerobic digesters at Long
Island are substantially higher, suggesting that costs at Deer
Island are being reduced to reflect the existing facilities at
that location. If that is the case, however, then it would
appear that the proper consideration of phasing out of Deer
Island facilities would reduce the all-Long-Island option costs
significantly. No one expects that the Fast-Track investment is
going to be wasted by phasing out of the Deer Island Plant before
its service life is completed.
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Mr. Michael R. Deland, Regional Administrator
Harch 13, 1983
Mr. Michael R. Daland, Regional Administrator
March 13, 1983
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To elaborate, MB recognize that Fast-Track work Mill extend the
service life of Deer Island facilities by 13 year* or so. During
part of that period, primary treatment facilities at Deer I (land
could significantly reduce tha amount at primary traatment
tankage required at Long laland. Tha additional primary
treatment tankage could be added at Long laland a> part of a
future construction step, when Deer Island facilities are ready
to be phased out. (Note in this connection that the end of the
service life of Fast—Track aechanical equipment and the existing
structures would coincide reasonably wall.) By considering the
possibilities of such phasing the life-cycle cost of Long Island
facilities Mould be substantially reduced. This is a realistic
consideration, and could ba factored into the cost estiaates for
the all-Long-Isiand option. At the very leaat, reasonable
phasing assumptions (possibly rare than one) should ba nade and
incorporated in the econoaic and financial analyses.
Ma have some additional specific comments and questions in
connection Mith the above—mentioned cost differences!
- Uhy are the costs of pier, tunnels, outfalls, and channels I
dikes for Long Island significantly higher? Mould not the
deeper Maters around Long Island reduce the amount of dred-
ging and hence the cost of pier construction? Is there not
already a suitable pier at Long Island? Why are construc-
tion durations assumed to be longer for Long Island?
- The statement is made on p. 12.4-34 that primary treatment
costs Mere not reduced to reflect settling-tank cost
corrections "since the question of sedimentation tank costs
did not affect the primary options*. However, does not the
failure to reduce primary settling tank costs make Long
Island look more expensive if existing Deer Island settling
tanks are used?
- According to the minutes of the February 1, 1984 CAG meeting
in Uinthrop (as contained in the revised Fast-Track report),
Dan Barson responded affirmatively to a citizen's question
whether Fast-Track expenditures at Deer Island would be
regarded as a "penalty* (meaning that Fast-Track dollars
invested at Deer Island would be added to estimated
long-range improvements at Deer Island when comparing with
other site options). Table 12.4-3 and the bottom of p.
12.4-27 and top of p. 12.4-33 suggest that such "credits"
aay not have been ultimately included. Section 12.S.2.2 (p.
12.3-4) even indicates that Deer Island costs were taken out
of the Fast-Track cost figures, contrary to Mr. Garsbn's
promise. Please correct either your report figures or any
misconception on our part.
Economics - Disproportionate Costa to Nearby Communities
and Compensation
As Uinthrop has clearly learned, the community(ies) abutting
major wasteMater traatment facilities bear disproportionate
coats, for which they should be compensated. This pertains to
the community (ies) that will abut future facilities, as well as
to Minthrop for that period that the Deer Island traatment
facilities Mill remain in place.
The following costs are among those which are significant in this
context:
— Costs associated with, transportation through the
community(ies).
— Provision of fir* department services.
— Community costs of in-house and outside sarvicea.
- Community costs of construction mitigation monitoring.
Each of these cost items is discussed below.
Coftl fiitocittfd tilth Transportation. Costs under this category
include:
- Traffic control and police escort services.
Infrastructure assessment and repair (streets, sewers;
watermains, gas lines). (Note in the casa of Uinthrop that
the truck route is owned by the Town and the Town bears the
cost for their maintenance and repair.)
- Costs of additional coordination and contractor extras due
to impacts on concurrent infrastructure construction/repair
work.
- Lost Federal Urban Systems Project Grants.
fir* Sercjca*. As the first responding fire service for Deer
Island, the Winthrop Fire Department and tha Town's taxpayers
have had to bear an unfair burden. The abutting community(ies)
should be compensated for this service.
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Mr. Michael R. Deland, Regional Administrator
March 13, 1963
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Hr. Michael R. Deland, Regional Administrator
March 13, 1989
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The need tor such fire services should be reduced by providing an
adequate fire alarm system and Internal fire protection at the
treatment plant mitele).
Cost* of In-house mnd Outside Service*. This refer* to costs
required to look after community interests under the prement
system during the various planning, impact assessment, and design
phases. Compensation for these costs should be provided.
Costs of Construction Hitigttion Monitoring. This includes the
tine of community representatives Mho participate in construction
•itigation monitoring activities. Compensation for this time
should be provided.
On the question of compensation for financial impacts, the SDEIS
(Section 4.3.6.a) states that the MDC currently has no mechanism
to pay local communities for such impacts, and.that it is not
known at this time what measures Mill be available to the
successor agency. The SDEIS should evaluate the legislation
enabling the neM Authority to determine Mhat measures could be
available, and make recommendations along these lines.
Construction contracts can include mitigating costs for things
such as police details, and possibly others, and this should be
examined in the SDEIS.
The SDEIS states that: "A mechanism to monitor disruption,
measure its costs, and provide compensatory remedies should be
examined as a part of any final facility planning and design
stage following the conclusion of the E1S process."
This should be done at this stage of the process, and failure to
do so will raise the •gggSQtttlBO issue in this connection. If a
MasteHater facility of this magnitude is to be built near a
residential area, then the Authority, et.tl. certainly should
expect to make compensatory payments.
Visual Quality - Mitigating Measures
Section 4.3.7 (Mitigating Measures - Visual Quality) discusses
means of mitigating adverse visual impacts, including
construction of earthern berms around treatment facilities to
screen views, buffer areas, open space, and landscaping, and
architectural treatment. Although discussion of such mitigation
is commendable, the SDEIS should reflect a much stronger
commitment for a project of this size and impact.
For any site, stronger mitigating measures should be included as
project conditions. As a minimum, these should include the
following:
- A detailed architectural scale model, including landscaping,
and a visual screening study should be included.
- Harbor communities should be allowed to play a major role in
architectural and landscaping decisions. A Harbor Islands
Aesthetics Commission (similar to the City of New York's
Arts Commission) merits consideration in this regard. An
entity having more legal authority Mould be preferred over
the CAC proposed on page 4-86 of the SDEIS.
- Prompt removal of all disposed equipment should be required
as a mitigating measure, as should ECQffiBS removal or
acceptable reuse of all excavated material.
— Dollar commitments should be made for efforts in this area.
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Mr. Michael R. Deland, Regional Administrator
March 13, 1983
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Hr. Michael R. Deland, Regional Administrator
March 13. 19B3
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Sludga Management
Ha have already gone oo record as having strong reservations
regarding the segmenting of th« process into an SOEIS for the
liquid-processing facilities and subsaquant study and EIS and/or
EIR for solids-procassing facilities. Ma do not agraa that sita
decisions can proparly be made in this manner. Solids-procassing
constderations (Including not just sludga handling but also
skimmings/scum disposal) seem to us to ba at least as iBportant
as liquid-processing considerations in siting decisions.
We cannot accept the argument that the decision on the location
of treatment and disposal of sludga is an independant decision
and is not driven by the final location and site for xastewatar
treatment facilities.
- Lsnd Us* md tconomic. Sludge processing and disposal
facilities occupy a substantial portion of a treataent plant
sita. The cost of sludge processing and disposal accounts
for 23 to 3O percent of the total cost of wastBMater
treatnent, Mith the higher figure being aora common . Land
use issues are recognized on page 12.9-6 of the SDEIS.
- Par Table 4-1, consolidated secondary treatment plants Mould
require 113 acres at Deer Island and 96 acres at Long Island
(the differences presumably being due to the need for
pumping stations at Deer Island and the reduced flexibility
associated Mith existing facilities). However, according to
page 4-1O2, these acreage figures do not include acreage for
sludge facilities (although some sludge facilities are
depicted on the plant layouts shown on Sections 4.1 and
4.2). The SDEIS should include reasonable estimates of total
acreage at this stage.
- Transportation. Significant transportation implications are
associated with plans for sludge end-product disposal and
(in the case of composting - wood chips) sludge processing
1. (Holcomb, R.W., I97O.
Turning," Science, 169. 3944.
Dick referred to below.)
'Uastewater Treatment: The Tide
(As cited in the publication
i s
by
as wall. Where Mould incinerator ash, compost, or
dewaterad/treated sludga ba disposed of and what are the
transportation implications of such sludga disposal? Sludga
management decisions also bear significantly on the need to
supply fuel to Deer Island and related transportation
impacts, as noted earlier. Page 12.9—3 notes, among other
impacts, that a composting operation could require up to
twenty trucks daily.
- Odors. Sludge processing facilities have significant
potential for odors. Tha existing sludge processing
facilities at Dear Island have resulted in serious odor
problems in Winthrop.
- air Outlitr- Air quality in a broader sense represents a
potentially significant Impact of sludga processing and
disposal. Significant public health concerns are part of
this issue, particularly if incineration is selected. Page
12.9-3 refers to "noxious* gasosl those gases can ba toxic
and carcinogenic as well. Tha discussion of health affects
on page 12.9-7 of the SDEIS Is inadequate. We are strongly
opposed to sludga incineration at "Deer Island. We have been
told that incineration Mould not ba allowed at Deer Island,
Jt9— ss«_Sbsl — LQcacnocatEfl— ai__i
JSBilS •
i
- Moil*. Page 12.9--3 notes the possibility of noise impacts
associated with sludge composting or transfer facilities.
Realixing that some of the problems referred to above can ba
alleviated by the design of sound sludga processing facilities,
wa nevertheless continue to be of the opinion that sludge
processing and disposal is a very significant and integral part
of the overall siting decision. Our legal counsel has indicated
that this is an area in which the SDEIS process is vulnerable on
legal grounds. We feel that we should assume the worst (e.g.,
incineration) relative to sludge management unless certain sludge
alternatives are clearly ruled out in the SDEIS.
In this
regard, it is significant that EPA*s expressed preference in the
1. A potentially viable course for the SDEIS to take would entail
assuming some means of sludge processing and disposal, such as
present methods of processing plus dewatering and disposal by
barging to landfill (with ocean disposal a passible
alternative). This could establish an acceptable impact baseline
against which other alternatives could ba compared.
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Mr. Michael R. Deland. Regional Administrator
March 13, 1983
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Mr. Michael R. Del and. Regional Administrator
March 13, 1983
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pamt haw been for incineration.
The following section* of th» SDEIS attempt to explain or
rationalize the sidestepping of the sludge Management issue:
- Section 2.3 - How Sludge Siting Relates to the Treatment
Plant Biting Decision
- Section 5.2 - UNRESOLVED ISSUES - Sludge Disposal
- Section 12.9 - Sludge Disposal Overview
The rationale provided in Section 2.3 and Subsections 12.9.1 and
12.9.2 is ridiculous. Furthermore, the rationale presented in
Section 12.9.1 is inconsistent with the impacts delineated in
Section 12.9.3.4 (erroneously called -12.7.3.2'). It is
significant that EPA had previously, via an E1S and record of
decision S), approved sludge
incineration at Deer Island without adequate analysis, and that
DEQE now essentially disagrees with the choice of incineration.
In Secretary Hoyte's certificate on the ENF for the Site Option
Study (September 9, 1983) he notes that EPA's Final EIS on sludge
disposal, reviewed by the State as an EIR, was found inadequate.
That certificate also states that the preferred alternative
resulting from further study and analysis of the sludge
management issue will be submitted by the HOC for review as a
Final EIR. Tha certificate further states the following:
•At the least, the Site Options EIR should discuss
compatibility of the various alternatives with both
primary and secondary sludge disposal options. If MDC
wishes to submit its Final Sludge Management EIR for
review simultaneously with the Draft Site Options EIR,
that will be entirely acceptable (to the extent
permitted by the schedule in the action Oyinc.* vs.
BBC,-)11
DEQE is said to consider ocean disposal options to have "the
least impact on public health*, and composting is now their
favored alternative. tA barged landlilling alternative (with the
possibility of ocean disposal and/or composting when feasible and
providad composting can be shown to have little impact) could
possibly be accepted at this stage.]
Page 12.9-4 makes the ridiculous statement that: 'The
construction effects of sludge facilities are relatively minor
compared with the greater construction activities and costs
associated with a treatment plant". The significant costs of
sludge processing and disposal were noted earlier. The attached
excerpts from a published presentation by Richard I. Dick , a
leading authority on sludge management, refutes the notion that
sludge management in a minor component of wastewater treatment.
(Note in this latter connection that gravity sludge thickeners,
anaerobic digesters, gas storage, scum incinerator, and -sludge
processing* have been variously assumed in the SDEIS, and line
item costs presented for some of those. Note Figures 12.4.1 and
Tables 12.4-3 and 12.4-4. In Table 12.4-3 (which is revised by
Table 12.9-3), those line item cost* total (148 million for all
Dear Island secondary, which is 17X of the total corresponding
capital cost. Note, however, that many of the other line items
in that table have portions attributable to sludge facilities.
Table 12.4 gives solids handling DIM at S6.633.OOO per year which
is I3X of the total DIM for all Dear Island secondary. The
revised capital costs of Table 12.4-3 show costs for all but
sludge processing. Revised Table 12.4-6 does not give O&M costs
attributable to sludge management.!
1. From the Proceedings of a National Symposium on Ultimate
Disposal of Uastawatars and Their Residuals", North Carolina
Research Triangle Universities and the U.S. Environmental
Protection Agency, Region IV, April 26 and 27, 1973.
2. A typographical error exists in Table 12.4-3: under Option
la.2 the figure in thousands of dollars for sludge processing
should be 111,924 (si 11.924.OOO) rather than 11,924.
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Mr. Michael R. Deland. Regional Administrator
March 13, 1983
nr. Michael R. Del and. Regional Administrator
narch 13, 1983
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HATin* Environment
The immuttti important to Hinthrap can be categorized a» follow*:
- Avoid.>nc.t of Plant Byp«»M.
- Tunn.il VB. pipeline construction.
- Drvdgi ng and di mpom*l oi h.wbor *4tdi .««nt«.
— Long—tstrtB Mater quality conmideration*.
Although SDEIS Section 11.3.6 addresses bypasses to some extent,
additional considerations are ieportant. The outfall tram any
of the plant sites, whether to President Roads (secondary
treatment) or deep ocean (primary treatment), must have
sufficient hydraulic capacity for all reasonable combinations of
peak floxs and worst (such as SO year) tidal conditions, to
completely avoid near — shore bypasses. Should it be necessary to
provide bypasses for mechanical malfunctions, etc., there should
also be provision for adequate notification procedures.
In the 1992 Site Options Study, all inter-island transport across
President Roads and deep ocean outfalls were to be by bedrock
tunnels, for which the environmental impacts are associated only
with the shaft sites at the termini of the tunnels. In the case
of Deer Island, these impacts (which include transport of workers
and construction materials and transport and disposal of dredged
spoils) would have occurred to some degree with all of the
alternative* that are now active. Both force main (pipeline) and
tunnel options were retained for transport between Nut and Long
Islands. Page 3-26 of the 1982 Study stated the following:
"The option of installing a force main across President
Roads (between Long and Deer Islands) was eliminated to
avoid a shipping lane and because it offered no cost
advantage over tunneling due to the depth of the harbor
bottom. Gravity lines were eliminated from detailed
analysis because the harbor bottom contour varies
significantly, thus making construction difficult and
costly."
Section 3.8 of the SDEIS (under the chapter on "Unresolved
Issues) now states: "A choice of conveyance for wastewater flows
between island sites and to an effluent discharge location will
be made during facility design. Depending upon the choice made,
significant environmental impacts may result and must be
evaluated....With pipeline construction, pertinent issues involve
water quality and marine life impacts, construction dredging
activities in the harbor, permits needed, characteristics of the
dredge spoils, and suitable transport and disposal
requirements."
Section 11.2 of the SDEIS addresses the permit processes that
would be required for construction in marine waters. Reasons are
given on the first paragraph of p. 11.2-2 for not addressing
specific marine-related impacts of particular siting optional the
logic of those reasons conflicts with statements in the second
paragraph on that page. It is noted that biological tasting of
harbor sediments in connection with other recent construction
projects showed bioaccuaulation of PCB's in test organisms
exposed to dredged materials to such a high degree that ocean
disposal is unacceptable. Quoting: "This illustrates that site
specific information could potentially affect the
implementability of any SDEIS site option chosen." Page 11.2-18
mentions specifically data from Minthrop Harbor which shows
significant bioaccumulation of PCB's in clams exposed to harbor
sediments. This suggests the need to resolve this issue b.8iQrfi
making a site decision.
Section 11.2-3 (pp. 11.2-9 to 14) provides additional information
on features of the SDEIS options which may impact on marine
resources. O-f particular interest is the statement on p. 11.2—12
that tunnel construction "was considered to be the most desirable
construction method Cin the 1982 Site Options Study] ... because
it provided least disturbance of sediments and no interference
with existing infrastructure".
Pertinent statements on pages 11.2—13 and 16 are quoted below:
"Of all the potential dredge or fill actions.
inter-island trenching within Boston Harbor poses the
greatest threat to harbor marine resources. This is
because of the large quantities of sediments which
would be excavated during the laying of the
pipeline(s), and the chemical quality of these
sediments. The principal resources which might be
affected include harbor shellfish and lobster.
Compared to tunnel alternatives, inter—island trenching
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Hr. Michael R. Del and. Regional Administrator
Harch 13, 1983
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•lt.trn.fttiv.tB Mould likely undttrgo • morm «>4t«nsiv«,
in—d«fpth «tnvirortA«nt*l ttVetluation «hould thay b«
propomvd by the HDC."
Why is pipeline construction now being considered as an
tive to tunneling?
alterna-
A statement appearing in the 1982 Site Options Study that does
not appear in the SDE1S is that installation of harbor pipelines
and outfalls would occur 24 hours per day, although force aains
cannot be constructed from February 1 to Hay 13 due to the Boston
Conservation Commission's eoratoriua on activities which cause
turbidity during the Minter flounder spawning season* Is this no
longer a consideration, and why is this not mentioned in the
SDEIS?
This is another area of ttflaSQtlQQ of the overall process of
making decisions and evaluating impacts. Me believe that the
decision on mode of Inter-island transport must be made as part
of the SDEIS. Me furthermore believe that the impacts of any
method other than tunneling must be assessed as part of the
SDEIS.
Disposal of potentially contaminated harbor sediments is listed
(Section 3.4) under the chapter on 'Unresolved Issues*. This
issue relates to both the areas of pipeline/tunnel/outfall
construction and pier construction. It also may relate to the
question of a land-based barging terminus. Here again, the issue
is being B89fi9Q£sd. by deferring it until the "design and
permitting process*. Me believe that the decisions related to
dredging and disposal of harbor sediments and assessment of
impacts must be part of the SDEIS.
Long-term water quality considerations refer to those resulting
after construction has been completed, and the new treatment
facilities are operational. Water quality evaluations in the
1982 Site Options Study Mere very limited. The SDEIS
(specifically Section 11.3) does a better job in this area.
, critical deficiencies exist in the following areas:
HoM
1. The discussion here pertains to secondary treatment
alternatives, which require local outfalls and to which the SDEIS
Hr. MichMl R. Del and. Regional Administrator
Harch 13, 1983
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- Embodiment of Mater quality criteria in
limitations and pretreatment requirements.
discharge permit
- Water quality considerations related. to the safety and
palatability of finfish and shell fish to human consumers
(particularly with respect to carcinogens).
— Chemical odors in receiving Maters.
— Water quality considerations related to the protection and
propagation of aquatic life.
tmtxidimrnt of Hftrr Qumlity Crittrtf in Oiachfrgf Permit
LimitftioaM fad Prrtrntxrnt Rrqairfmrnti. The SDEIS does a
reasonably good job of projecting some of the impacts on Boston
Harbor Mater quality on the assumption that the characteristics
of HDC MasteMater Mill remain as they are presently. Given those
characteristics, either primary treatment with daep ocean
outfalls or secondary treatment with local outfalls Mill result
in improvement. HoMever, the report does not go into those
things that must be done beyond the basic treatment/outfall
alternatives to achieve harbor cleanup vis-a'-vis HOC MasteMater
discharges. Specif icairy, the report should: (1) develop
MasteMater d.iS£h,«C98 criteria required to meet stringent Mater
quality criterial (2) recommend corresponding NPDES permit
limitationsl and (3) address the issue of hc*M pretreatment Mill
be implemented to achieve those limitations.
It is important to note that the State Mater quality criteria do
not get into toxicants beyond the very general statement that
'Haters shall be free from pollutants in concentrations
that. .. (injure], are toxic to, or produce adverse physiological
or behavioral responses in humans or aquatic life! or ... [exceed]
si te— specif ic safe exposure levels determined by bioassay using
sensitive resident species.* In Interpreting this statement, the
DWPC is supposed to consider EPA Mater quality guidelines . As a
practical matter, there are no Mater quality criteria for
toxicants that have the force of laM, and limitations for those
toxicants are virtually never found in EPA's NPDES permits.
prr if res
concerned.
ricts itself insofar as Mater quality impacts are
1. See page 13 of the "Boston Harbor Water Quality Baseline
Report" for the SDEIS, December 1984.
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Mr. nichMl R. Del and. Regional Administrator
March 13, 19B3
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March 13, 19B3
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Unless pertinent discharge limitations are developed in the
SOEI8, and unless those limitations are actually incorporated in
the NPDCS permit for the new plant (s), then there is no assurance
whatsoever that conditions projected in the SDEIS Mill be
attained.
Pretreateent is a key component of the managerial measures
necessary to achieve effluent limitations. Pretreatment refers
to the reduction of toxicants, etc. at industries and commercial
establishments prior to their discharge to the sewer system.
Almost all of the many toxicants in HOC wastewater are of
industrial/commercial origin, and are amenable to pretreatment.
The MDC has implemented a pretreatoent program of sorts, but it
would have to be made more purposeful to achieve the necessary
reductions. The SDEIS only alludes to needs in this area, such
as by stating (page 11.3—1): "However, without further reduction
of toxic metals and pesticides in the wastewater flowing to the
proposed treatment facilities, wator quality criteria for
toxicants could be exceeded on occasion under any alternative.
.1
Important questions Include: What plant influent limitations will
be established to assure effluent limitations are attained? How
will these be translated (in conjunction with categorical
pretreatment standards) to industrial discharge limitations, and
how will industrial discharge limitations be enforced? How will
pretreatment management be carried out considering the multitude
of communities, etc.? The SDEIS should address these questions.
Smffty ar>4 PaJataoJJIt? to Hummn Conrumers. Fish and shellfish
can store and magnify (thousands of times in the case of some
shellfish) toxicants in their environment. Human consumers of
such seafood may experience acute and chronic health impacts.
Such toxicants as cadmium and mercury may cause acute or chronic
health impacts due to their nature as direct "poisons". Others
may cause chronic health impacts due to their carcinogenic
(cancer—causing) potential.
1. In addition to protection of receiving waters, pretreatment is
important to assure that toxicants will not prevent biological
treatment processes (e.g., secondary treatment by activated
sludge and anaerobic sludge digestion) from attaining their
design efficiencies, to protect sewerage workers from health
hazards due to toxic gases, minimize the chance of explosions in
the sewerage system, etc.
This Issue Is acknowledged in a general way in the SDEIS:
"The most significant potential adverse impact of any
of the alternative effluent discharges is the public
health question posed by the accumulation of toxic
chemicals in edible marine life. The significance
attached to this potential impact, relative to other
discharge impacts, is attributable to the large number
of people potentially affected, the intensity of
potential health effects, and the uncertain level of
risk associated with fish consumption." tpage 11.3-21
"Any effluent discharge will contribute to the as yet
undetermined health risk to humans eating these fish.
By removing more of these toxic pollutants (through
industrial pretreatment, for example) higher levels of
wastewater treatment may lessen long-term ambient
concentrations which are bloconcentrated in fish, and
thereby .lessen the health risk to humans." Cpage
I1.3-61
"Toxic compounds in sediments may accumulate in marine
organisms to levels which threaten the organism's
health, and possibly the health of humans which eat
them. Fish disease and bloaccumulation of toxic
compounds in Boston Harbor food fish have been
documented (see separate SDEIS report: Boston Harbor
Water Quality Baseline (referring to pages 7, B, etc.
of that report]). The contribution of treatment plant
effluent to fish disease or toxic accumulation in fish
is unknown but is a continuing concern. The health
risk to humans who consume local marine life is
presently unquantified." C pp. 11.3-33 to 34]
"Limited sampling has found PCB concentrations in
edible fish tissues as high as O.B ppm. The Food and
Drug Administration has recently lowered the tolerance
limit for PCB in food from 3.O ppm to 2.O ppm stating:
*the 2 ppm level stikes a proper balance between
protecting consumers from the risks associated with
exposure to PCBs and the loss of food due to the
r — 4 • t •*«1 *
lowered tolerance."
11.3-341*
1. EPA's 1976 Qu.al.i.tv._Cri.£Sria_fgr_Water notes that a PCB residue
level of 2 ppm in fish consumed by commercial ranch mink has been
shown to preclude survival of mink offspring. and that
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Mr. Michael R. Daland. Regional Administrator
March 13, 1983
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Hr. Michael R. Del and, Regional Ad«ini»tratex-
March 13, 1983
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CO
The SDEIS even Implies acceptance of adverse impact• that can be
substantially ameliorated, by virtue of Section 4.A.I - ADVERSE
EFFECTS WHICH CANNOT BE AVOIDED - Mater Duality.
These factors should be explicitly and quantitatively considered
in the SDEIS. It is totally incongruous that criteria tor the
protection at aquatic Him (see belox) should be dealt with in
reasonable detail in the SDEIS, while water quality criteria
related to human consumers of seafood are totally ignored. That
there are scientific uncertainties is sometimes used to
rationalize the avoidance of much considerations! the SDEIS
certainly should do the best that can be done with what is
known. There is no mention in the SDEIS of criteria for direct
poisons such as cadmium and Mercury (although for those
particular chemicals the criteria for protection of human
consumers is sieilar to the chronic criteria for saltwater
aquatic life given in Table 11.3-91). Such poisons should be
explicitly addressed in the SDEIS, and limitations developed as
'discussed earlier. Definitive Mater quality criteria should be
selected, and dilution requirements, etc. established as
discussed below for marine life criteria.
Of particular concern are those toxicants for which huaan health
criteria are lower than criteria for marine life. Although they
are not identified as such in the SDEIS, the following is a
partial listing of toxicants for which the huaan health criteria
are lower than criteria for marine life:
Selenium (Table 11.3-18)
Dichlorobenzenes (Table 11.3-18 — total)
Thallium (Table 11.3-18)
2.4-dichlorophenol (Table 11.3-2O)
Dichloropropenes (one listed on Table 11.3-19)
reproduction was nearly eliminated in ranch mink fed a beef diet
containing O.64 ppa of the PCS Arochlor 1234. On this basis EPA
at that time (1976) suggested "that a tissue level of not more
than O.3 ug/g (ppm) would be required to protect ranch mink, and
by implication, other carnivorous mammals." This level is
one-fourth the FDA level for huaan consumption (and below levels
found in Boston Harbor fish), and raises concern about the safety
of the FDA level (and the safety of eating Boston Harbor fish).
1. As indicated in the separate memo of February 3, 1983, there
are a number of errors in the reference citations, etc. of tables
in Section 11.3.
Of perhaps greater concern ic the total failure to explicitly
consider carcinogenic chemicals which ar« hazardous to human
health through Ingestion of contaminated fish and shellfish.
According to EPA water quality criteria (Federal Register,
November 28, 198O):
"... the ambient water concentration should be zero
based on the non-threshold assumption for I these]
chemicalCsl. However, zero level may not be attainable
at the present time. Therefore, the levels which may
result in incremental increase of cancer risk over the
lifetimes are estimated at 1O~3, 1O~6, and 1O~7."
(Meaning one additional cancer case per iOO.OOO exposed
population, 1,000,0000 exposed population, and
10,OOO,OOO exposed population, respectively.]
Criteria corresponding to the above risk levels are given in EPA
documents, from which criteria corresponding to other risk levels
may be calculated. These considerations have not been factored
in at any risk level, in spite of the presence of many
carcinogenic chemicals in the HOC wastewater. Although they are
not Identified as carcinogens in the SDEIS, the following is a
partial listing of carcinogenic chemicals, taken from the SDEIS:
Table 11.3.12
Dieldrin (See 4.' Aldrin/Dieldrin)
DDT
Heptachlor
PCB's CAlso Table 11.3-21]
Table 11.3-18
Arsenic
Hexachlorobenzene (14. Chlorinated benzenes)
Benzene
Toxaphene
Trichloroethylene
Chlordane
Halomathanes (3 listed on this table - see note re/ combinations)
1. These numbers, given where required for clarification, refer
to numbered priority pollutants in the EPA water quality criteria
(Federal Register for November 28, 198O).
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Mr. Mich»l R. Del and. Regional Administrator
March 13. 1983
Table 11.3-19
Carbon tetrachloride
2.4-dinitrotoluene <31.>
1.2-dichloroethane V 1.1.2,2-tetrachloroethane <19. Chlorinated
ethanes)
4,4'-DDE (DDT metabolite - see above)
1,1-dichloroethylene (27. dichloroethylenes)
Some of the Lindane metabolites (several listed on thi» table -
BHC's1 - 41. Hexachlorocyclohexane)
Hexachoroethane (13. Chlorinated ethane*)
M-nitrosodiphenylamine
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Vr. Michael R. Deland. Regional Administrator
March 13, 1963
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Hr. nicheat R. 0*1 and, Regional Administrator
Harch 13, 1983
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non-metal priority pollutants would be substantially less after
secondary treatment (since secondary treatment reduces these
pollutants substantially), and these should have been
conservatively estimated (using readily available literature
data).
Comparing the dilutions attainable with dilutions required
suggests that dilution can be used to meet the criteria for all
but exceptionally high values of PCB's, heptachlor, and cyanide.
With the dlffuser designed for the highest feasible dilution and
addition of vigorous pretreatment requirements, the general
attainment of the criteria should be entirely feasible. This
should be the objective of this report, rather than ending with
the conclusions on pages 11.3-3 and 11.3-29 that: "At the
K> President Roads outfall site. the concentrations of toxic
I pollutants in secondary effluent may occasionally exceed EPA
I—« water quality criteria for the protection of saltwater aquatic
O !»«• «ven after Initial dilution.. .Over time, industrial
O pretreatment and control of banned chemicals m.a.y lower toxic
pollutants discharged to the • sewer system so that effluent
discharges never exceed aquatic life criteria after initial
dilution....Compared to the continuation of existing treatment
plant discharges, any of the alternatives under consideration
would provide better conformance to the criteria." [emphasis
added!
Two additional issues which are not adequately adressed are those
of dissolved oxygen depletion and chlorine toxicity. Dissolved
oxygen depletion is touched upon in a very cursory way on SDEIS
page 11.3-31. A sufficient analysis should not be too difficult
to complete here and should be required as part of the SDEIS.
The SDEIS treatment of the issue of chlorine toxicity (as
addressed on pages 11.3-29 to 3O> is a great example of remanding
an issue for further study rather than face the obvious and do
the work necessary to make decisions now. The fact is that
chlorine residuals in chlorinated, secondary effluent are
typically on the order of 1 - 3 mg/1 (not the theoretical values
shown on Figure 11.3-13), and the safe level for saltwater
aquatic life is around 7.4 ug/1 (O.O074 mg/l>. Thus a dilution
of around 133 to 676 would be required (depending on actual
chlorine residual concentration within a I - 3 mg/I range), which
is not feasibly attained.
If sensitive marine life is to be protected, one or more of the
following is required: lower than normal chlorine dosages!
dechlorinationl or an alternate means of disinfection not
requiring chlorine such as ozonation or ultraviolet
disinfection. Mastewater dechlorination is usually (and most
economically) accomplished by the addition of sulfur dioxide, and
involves the tCiDSBSCtlDa of this chemical which is somewhat
similar to chlorine in hazard potential.
The SDEIS states that this issue should be resolved during
•detailed facility planning and design", by considering
"alternative disinfection methods and practices to minimize
chlorine's toxic effects on marine life". It further states:
"On-site manufacture) of sodium hypochlorite from sea water should
also be Investigated as an alternative to chlorine transport
through populated neighborhoods." Furthermore: "Chlorine
disinfection of wastewater is also known to cause the formation
of chlorinated hydrocarbons such as chloroform....The facility
planning and design evaluation of different chlorine disinfection
alternatives should therefore consider the impacts of chlorinated
hydrocarbon formation." The information Is available now with
which to make the necessary decisions. It is time to stop
protracting the study process. The problem is not too many
studies, it is inadequate ones. Failure to make the necessary
decisions as part of the SDEIS SWSfiQti the process.
The Long-Term-Improvement evaluations on liquid disinfection
presented in the Revised Fast-Track Report (pp. E9.9 to E9.24)
addressed ozonation, ultraviolet disinfection, and electron beam
disinfection. Although the accuracy of the evaluations are
reduced by the assumed disinfection of primary effluent (which
again shows how difficult it is to evaluate the issues
piecemeal), it was concluded that the none-chlorine alternatives
were considerably more expensive in both capital and operating
costs and, in some cases, inadequate from the standpoint of
disinfection effectiveness.
Discharges from secondary treatment plants are normally required
to comply with EPA's regulatory limitation of ZOO fecal coliform
per 1OO ml (mi 11i1iter). A 10:1 ratio of total:fecal coliform is
fairly typical, so this requirement corresponds to roughly 2OOO
total coliform per 1OO ml. The harbor inside of Deer Island is
classified as Class SB waters, for which the State criterion is
7OO total coliform per 1OO ml. There should be little difficulty
reaching that limitation after initial dilution at the outfall
diffuser. Outside of Deer Island, the harbor is classified as
Class SA waters, for which the State criterion is 7O total
coliform per 1OO ml. A dilution of 29 would be required to
achieve this coliform limit given a 20O fecal coliform per 1OO ml
effluentl such a dilution should be attainable with initial
dilution and dilution due to fai—field dispersion between the
outfall location and Class SA waters. This is dependent upon the
actual dilution attained with the outfall design, and the actual
location of the outfall. The actual outfall diffuser location
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Mr. riichael R. Del and. Regional Ada!nistrator
Harch 6, 1983
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and dilution are uncertain (not* 6DEIS pp. 11.3-4. Table 11.3-16,
etc.). The U.S. Public Health Service standards for bacterial
quality of shellfish areas im 7O total col Harm par 1OO •! for
"approved" and "conditionally approved" areas and 7OO total
conform per 1OO ml for "restricted" areas. The south shore of
Winthrop has restricted shellfish areas, and the 7OO total
conform limit there should not be controvened by the new
outfall.
An acceptable and definitive solution to the wastewater
disinfection problem for purposes of the SDEIS would be the use
of on—site hypochlorite generation Mith outfalls of sufficient
length, diffuser location, and design, to allow the use of lower
than normal chlorine dosages. The diffuser should be located far
enough fro* beaches and shellfish areas that intial and far-field
dilution would result in acceptable bacterial reduction. A
dilution of at least 73 should be attainable at such a diffuser
location, which would allow the criterion for saltwater aquatic
life to be attained with a chlorine residual on the order of O.3
mg/1. This residual at the end of a long, adequately located
outfall (in conjunction with adequate initial nixing of chlorine
and on-site contact tanks if needed) should result in attainment
of the 2OO fecal col ifore per 1OO ml limit nomm if not all of the
time. A einor secondary treateent waiver, for higher effluent
fecal col Morn, would see* reasonable in this case. A 73*
dilution would result in attainment of the Class SA requirement
of 7O total conform per 100 ml with an effluent having a fecal
coliform count of approximately 7O/1O x 75 - 323 per 1OO ml.
Some minor adjustment of the Class SA standard to a localized
Class SB in the immediate vicinity of the diffuser might also be
considered if the diffuser has to be located in Class SA waters.
Sincerely yours,
£J^j&^£4L6^A^---
•UJDOB HANOUNO AND DISPOSAL-STATE OF THE ART
RICHARD I. DICK
Pmtfttot at Chit £/ifwMcring
UniMfSity of Delaware
Newark
Th* basic approach to treatment of waterborne wute* i» lo
concentrate pollutant* which ere to be removed Into a compara-
tively email volume. Moat commonly, polltitanta are diverted to
the concentrated stream by usa ol solids separation processes
following any required chemical or biological conversion ol the
material to suspended solids. This practice allows return ol the
bulk of the waste Row to the environment or recycle ol the treated
affluent, but leave* behind a troublesome residue—sludge.
Whereas the volume ol sludges produced In wastewater treat-
ment I* small compared to the volume ol waste (commonly less
than one percent) the problems encountered In elective manage-
ment ol sludge* are lar out ol proportion with their volume. Okun
(1968) noted that "treating the waalewatar I* only hall the prob-
lem, and the easier hall at that The solids residue Is the rub,"
and Kershaw (1870) stated thai "sludge treatment and disposal
. . . constitutes what la probably the most serious problem lor
management"
The extent ol the sludge management problem Is Illustrated by
the contribution ol sludge treatment and disposal lo the overall
cost ol wast* management. Michel (1970) indicated that the
method* (elected lor sludge treatment and disposal produce the
greatest single Impact In the total cost ol operating and main-
taining waatewater treatment plant*. A British survey (Water Pol-
lution Research Laboratory, 1968) Indicated that treatment and
disposal ol sludge accounted lor about 40 percent ol total treat-
ment costs. Holcomb (1970) reported that. In this country, the
cost ol sludge treatment and disposal accounts lor 25 to SO per-
cent ol the total cost ot waste management, "with the higher
figure being more common."
The attention which has been given to sludge treatment and
disposal In the past a* compared to processes lor Initial removal
ol pollutanta ha* been more nearly proportional lo the relative
volume ol sludge than to the relative cost of sludge disposal. All
too often, the problems ol sludge treatment and disposal have
failed to titillate the Imagination ol researches or to attract the
127
Ronald V. Vacchia
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attention ol UM design engineer*. Instead, they tax* been left to
the frustration ol operating personnel. In lhl» regard, Evwu (1973)
recently has summarized that "the treatment and disposal of
•ludge ... are most difficult and expensive problems and. as
much as any. have been the child ol fashion and have suffered
from the lack ol planning."
The problem can only be expected to become worse In the
future. Uniform requirement* lor a high degree ol removal ol
cartMfiaceoua material will result In Increased quantities ol
voluminous, troublesome sludges and requirements lor nutrient
removal will produce enormous volumes ol nutrient-laden resi-
due*. Vet effective management ol these Increased quantities of
l^j more troublesome sludges must be accomplished In a fashion
I which will comply with Increasingly constraining standards lor
l_* air, land, and water quality.
O " In approaching the task ol preparing a state ol the art paper
IN) on the broad area ol sludge handling and disposal, it has been
chosen to develop a critical analysis ol the state ol the art rather
than an objective description ol current practices. In this way. It
la hoped that an assessment ol past development and current
practices can be combined with some Ideas ol the needs ol the
future In this critical area ol waste management. The disad-
vantage ol this approach, ol course. Is that it reflect* unduly the
past experiences and personal biases of the author. It Is left to
the reader to exercise Ma own crIUcal evaluation ol the author's
observations.
In the following section, the nature of some ol the processes
which have developed for treatment and disposal ol sludges are
bristly reviewed. Then some ol the thought patterns which have
typified sludge management practices In the past are examined
and Implications of those practices are noted.
Techniques ol Sludge Treatment and Dispose!
Element* ol sludge treatment and disposal systems may be
categorized as Involving thickening, conditioning, dewaterlng,
conversion, transportation, and ultimate disposal. The nature ol
sludge management techniques which have developed In these
categories are briefly reviewed here. More extensive reviews
have been prepared by Burd (1968) and by the author (Olck. 1972).
Thickening is the most commonly used sludge treatment pro-
cess. It can be accomplished at modest cost and significantly
reduces the volume ol sludge requiring further treatment end
128
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A Critique of the Decision Analysis Process
Oaed io the Supplemental Pratt Environmental Impact Statement
by
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Richard C. Larson
3 Johnson Tecrace
Hlntbcop, MA 02152
February 28, 1985
The Supplemental Draft Envlronnntal Impact Statement
(SDEIS) on the Siting of Wast* Hater Treatment facilities for
toeton Harbor alleges to use techniques of systematic analysis or
Uclalon analysts as a means for carefully identifying and
itudying alternative options tor cleaning up Boston Harbor. This
claim to use decision analysis is indicated, for Instance, in
Volune I (page 2-23) In which the report states that
'...Massachusetts and the EPA have agreed that it la necessary to
work within a logical framework to evaluate the components of a
decision.* Invocation of decision analysis Is also mentioned In
Section 12.12 of Volume II ("Screening Report*) which states that
the desire was *to select an optimal set of alternatives for
further detailed study based on the application of defined
screening criteria...* [emphasis added) (page 4-3). On page 3-1
of that section, it is stated that the 'report describes the
steps followed-in the analytic process leading to a determination
of the most feasible options which will be subject to further
detailed study...* (emphasis added).
It is my contention that the SDEIS not only has failed to
use a systematic evaluation procedure in analyzing potential
wastewater treatment sites, but also has biased its report toward
a preconceived conclusion -- that being that Deer Island is the
optimal location for an expanded wastewater facility. I
challenge the SDEIS on Its objectivity and Its analytical
premise. My goal in so doing is not to promote any preconceived
alternative site, but rather to discredit the report's
conclusion. The SDEIS is not a scientific study, and it
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disregards many obvious and known (act* a* well •• stated
priorities of citizen's groups which have taken an Interest In
the Boston Harbor cleanup. It Is Important not merely to arrive
at a remedy to this situation, but to objectively concern
ourselves with all aspects ot a very couple* and very important
Issue.
In this critique I review the use of the decision or
systematic analysis approach by the authors of the SOEIS. Severe
shortcomings are found In such areas as Identifying and retaining
relevant options, selecting adequate decision criteria,
artificially breaking up the problem Into pseudo Independent
parts, and overall biasing of the report toward a single
alternative. After reviewing general steps for a systematic
analysis, I comment on bow each of these steps was carried out In
the SDBIS. A summary of my findings, together with constructive
recommendations, conclude the critique.
1. The Steps in'a Systematic Analysis
It is generally agreed that the following eight steps
comprise the elements of a systematic analysis or decision
analytic study: (1) define the problem) (2) identify the
objectives) (3) specify performance measures) (4) Identify the
alternative courses of action) (5) analyze the alternatives to
understand the consequences of each) (6) compare the consequences
and select alternatives) (7) present the results and conclusions
to decision makers; (8) implement and evaluate an action plan.
Elements of steps one through six are presented by authors of the
SOEIS. And in each of the steps as completed to date, major
flaws exist.
2. Defining the Problem
In step one, defining the problem, the report suffers from
artificial serialisation or segmentation of the various processes
required to Implement one or more new waste water management
facilities. This segmentation is demonstrated by lack of
detailed consideration of the facts surrounding locating the
barge terminus, which will be required to transport large
fractions of construction equipment, materiel, perhaps personnel
and waste material from the construction site via the harborways.
The report demonstrates lack of detailed consideration of
Incineration of waste residue or other processes that would be
undertaken to dispose of the final product of the waste water
treatment facilities. The report asserts that these two planning
problems, among others, are Inconsequential with respect to the
current seven identified alternative options and praises such
'sequential decision-making* as a desirable and feasible way to
move forward on these difficult decisions. However, it is just
such sequential decision-making which biases the findings in each
step of the decision making process toward that incremental
decision which has least cost and is technologically most
expedient. Such biasing produces as an expedient step-by-step
growth In existing facilities at Deer Island and/or Nut Island.
The problem is further Incorrectly defined by the fact that
the SOEIS authors fail to consider that one or more of the
alternatives for waste water management facilities could serve
other purposes as well. For Instance, the development of an
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outer harbor man-made Island could possibly also serve additional
needs in solid retuse disposal and ultimately as the location for
* 21st century new airport (or the greater Boston area. This
•a.-mple is presented not to propose it as the "optimal* solution
(thbre is no optimal solution). but to demonstrate that the
existing SDBZS "decision process" has been driven by expediency
and parochialism.
3. Identifying the Objectives
In identifying objectives, the SDEIS (page 2-24) cites the
following, claimed to be "In no particular order of importance"i
harbor enhancementi
effects on neighbors!
effects on natural and cultural resources;
implementablllty;
coat i
reliability.
Required New Objectives
There are at least two other decision criteria that should
be added to this list:
1. Equity among communities In the distribution oi obnoxious
Equity among
facilities.
This decision criterion would reflect the extent to which
any particular alternative would enhance equity and thus
would have more communities accepting their proportionate
share of undesirable facilities (e.g., airports, prisons,
sewage treatment plants, nuclear reactors, hazardous waste
dumps) or would exacerbate the current Inequitable
distribution of such offensive facilities.
2. Risk to human lite due to proximity of a new facility.
This would refer, for instance, to the risk posed by leaks
of deadly gases (e.g., chlorine), that could arise from
faulty maintenance, human error, or natural or man-induced
disasters (e.g., major storms, airplane crashes). It would
also include long-term risks posed by exposure to sewage
odors, chlorine gases, and airborne Incineration residues,
some of which may be carcinogenic. The SDEIS does cite
"effects on neighbors* as a decision criterion, but the '
document's discussion of effects on neighbors does not
Include risk to human life.
Inverting Priorities
Regarding prlorltlsatlon of the various decision
alternatives, the process to date has been exceedingly biased
against the priorities indicated by citizens' groups. The
Citizen's Advisory Committee (CAC) ranked decision criteria in
the following order of Importance* social, environmental,
technical, institutional, economic, political, and legal. A
similar ranking was reported by the follow-up "Public Workshop,"
with the exception that economic impacts were given greater
relative importance. -Then, by a process that remains mysterious,
the authors of the SDEIS (in consultation with a "technical
advisory group" [TAG]) Inverted the'prlorltlzatlon and used for
the final screening of alternatives the following decision
criteria In their perceived order of Importancei technical,
engineering, social, environmental. Here, yet a new category,
"engineering," was added; this category appears to be the same as
technical, with the additional component of project costs. Thus,
early citizen's Input on priorities were totally ignored In the
consideration of such social Issues as construction activities,
odor, property values, and land use. The priority "one* Issue,
as reported by the CAC, was placed by SDEIS in admittedly low
priority In the final screening process. Tet it la alledged
throughout the SDEIS that this process of Identifying and
utilizing decision criteria is value neutral.
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in the SDETS
The SDBIS lists Its *lx decision criteria reportedly *ln no
particular order ol Importance." Yet the text surrounding that
discussion Is exceedingly biased. Hearly every qualification
given to the possible rank order Ings or weightings which could be
associated with the various decision criteria Is a qualification
In favor of utilising Deer Island rather than Long Island for the
siting decision. For example, the report reads, "to cite one
example, the likelihood of the Incorporation of Long Island Into
ths state park system will clearly affect the weight which Is
assigned to the harbor enhancement decision criterion, relative
to effects on neighbors.* Such language In an allegedly
value-neutral docuaent Is hardly unbiased. The authors of the
report are Baking a pretense of value neutrality and systematic
decision processes, but even a casual reading of the document
will reveal the biases Inherent throughout.
Even the photographs selected to depict the three
alternative sites'are biased. The cover photograph on each of
the two volumes conveniently crops a large portion of the
community of Wlnthrop out of the picture to deemphasize the
closeness of Deer Island to one of the most densely populated
communities In the Commonwealth. Those not familiar with
Hlnthrop might think that Deer Island Is the entire region to the
right of the thin beach or causeway area shown In the cover
photograph) In fact, as all Hlntbrop residents know. Deer Island
Is no longer an Island, but part of the Wlnthrop peninsula, and
the region to the right of the causeway Includes the densely
populated Point Shirley part of Wlnthrop. The close-up pictures
In the text correctly depict Nut Island as being very close to
residential communities, whereas photographic angles of Deer
Island deemphaslxe Its closeness to Point Shirley and Its
beautiful beaches. Long Island Is photographed from angles which
would have one think that It Is entirely virgin land, whereas the
fact Is that the proposed active use state park will be located
on the former site of Fort Drum, an acreage filled with dangerous
cement bunkers and even streets with existing fire hydrants.
Throughout the report. In the comparison of Deer Island to
Long Island there Is a consistent strong bias In favor of the
'natural beauty* of Long Island vs. the current obnoxious land
use of Deer Island. With this strong bias, the reader has no
Idea of the the deep water adjacent to Long Island which would
facilitate enhanced barge activity, whereas Intense dredging
would have to take place on Deer Island to facilitate barging.
There Is no comparable site on Long Island to the spectacular
.view of the entlr'e harbor from the 100 foot high drumlln atop
Deer Island. There are potentially valuable swimming beaches on
Deer Island, In contrast to the lack of comparable beaches on
Long Island.
The SDEIS bias la far from subtle. The report places great
Importance on the archeologlcal significance of undisturbed,
unidentified skeletons burled on Long Island, with apparent
disregard to the living huoan beings both on Deer Island and on
nearby Point Shirley In Wlnthrop. It offers the promise of
preserving Long Island Hospital as a national historical site,
whereas, In fact, the hospital -- comprised of a set of buildings
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with no particular architectural significance -- baa been on the
verge of abut-down and/or relocation lor years. An alternative
apparently not considered !• the use of the entirety of Deer
Island as a park, relocating the detainees In the Bouse of
Corrections and perservlng ^t as a national historical site -- It
Is architecturally Interesting and public tours through it could
serve as a deterrent to those with criminal Intentions.
The report repeatedly' refers to plans to Include Long Island
In the to-be-created Harbor Island State Parks yet whose plans
are these? The Commonwealth's — the same body (of governaental
officials and citizens) who are charged with deteralnlng the
siting of one or Bore new waste water treatment facilities.
These "decisions* to Include Long Island In the state park and to
exclude Deer Island froa the park are only additional examples of
the artificial serialization of the siting process as presented
by the authors of the SDEIS. If truly no decision has been made
with regard to waste water management siting, then the only
logical conclusion (since we are dealing with the same decision
aakers -- ourselves) is that no decision has been made on the
exact aakeup of the Harbor Island Park. The two decisions are
intimately intertwined and to treat them differently would be to
pose artificial constraints on the subordinate decision.
4. Specifying Performance Measures
Referring back to the steps in the systematic analysis, very
little attempt Is made in the SDEIS to reduce overall general
objectives to perforaance measures that can be monitored.
Illustrative performance aeasures would Include decibel levels of
noise, parts per ailllon of carcinogens, soae level of odor
level, etc.. all distributed over affected population areas.
The single perforaance aeasure tbat does leap out at the reader
Is-the estimated number of trucks required to pass through
densely populated residential coaaunltles each day -- nearly
1,000 per day for up to nine years (in parts of Wlnthrop or
Oulncy or both). The authors agree that such disruption would be
significant, and that mitigation measures are necessary, but
again with a bias against using Long Island as a site.
Regarding the effects of secondary wastewater treatment at
Deer Island with a headworks at HI (option la.2),, the report
says. *At DI, the construction period would last about seven
years. Major Impacts would result froa tbe dally transportation
of an average of 415 construction workers, and up to a peak of
940 truck trips per day through Wlnthrop (as well as through
Boston and neighboring comnunities).. .* (emphasis added). Kith
regard to effects' of secondary treatment at Long Island (option
2b.l), the report states, 'Impacts of this option during
construction would be significant, involving an estimated total
peak level of 428 workers and 975 truck trips dally, traveling
through Oulncy to both LI and HI. Construction period at these
sites would be three to four years at HI and nine years at LI.
These levels of construction activity would impose major adverse
impacts upon the Squantum community and moderate Impacts upon
nearby residential areas of Houghs Neck.* [emphasis added). Note
the absence of the work "adverse* In describing the non-Long
Island option. Of course, these Impacts (adverse or not) are
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supposed to be 'mitigated* by siting the barge terminus at a
yet-to-be-ldentlfled location — a location which itself would
then be impacted in a major, adverse way.
5. Identifying Alternatives
Step (our in a systematic analysis is Identifying
alternative courses of action. Here, the SDBIS Is fatally
flawed. Flrstt the 'scope of the analysis* (page 4-1. section
12.12, Voluae II) Is limited to existing studies that were
performed by the EPA, the HOC and their consultants. These
studies were nearly exclusively concerned with existing
facilities at Nut Island and Deer Island. To the extent that'
they consider subregional treatment or 'satellite' facilities
that would affect other communities In the Greater Boston area,
these alternatives are quickly and mysteriously eliminated in
Section 12.12. Thus, the screening of potential sites from 22 to
8, and now to 7 alternatives has been based on expediency and
cost efficiency. ' Moreover, an Initial universe of 22
alternatives Is not nearly comprehensive enough to consider 'all
feasible alternatives* which any EIS la mandated to do by law.
The tremendous preselection bias Inherent In using existing
studies of the NDC and the EPA to generate the 22 alternatives,
which are then quickly reduced to 7, is a far cry from
considering all feasible alternatives. The elimination of other
alternatives, even from the limited set of 22 remains clouded In
mystery. Recall, for Instance, the potentially attractive
utilization of man-made or artificial Islands, as cited earlier
In this critique. The sudden elimination of the eighth option
("all primary treatment at Long Island') is totally Inconsistent
with value neutral analysis of prospective uses of Deer Island,
Nut Island and Long Island.
6. Analysing the Alternatives
The last step, which was partially carried out In the
existing SDEIS, Is the analysis -of alternatives to understand the
consequences of each (Step 6 in a systematic study). This
critique has Illustrated throughout severe shortcomings In the
analyses carried out to date. Rather than reiterate them here,
or to Identify additional ones, it Is appropriate to summarise
our findings)
7. Summary
The SDEIS alleges to use the methods of systematic analysis
or decision analysis as a basis to consider the siting
decisionsi yet the execution of the systematic analysis is
seriously flawed.
The problem Is defined in the SDEIS in a way which
artificially serializes or segments siting processes which
are In fact closely tied together; the result is a built-in
bias In favor of Incremental decisions that are most
expedient,, usually.favoring existing facilities.
The problem Is defined narrowly so that other complementary
uses of a possible site —• for Instance, an artificial
Island ~ are not considered.
The list of objectives In the SDEIS process should be
lengthened to Include at least two additional ones: (1)
equity 'among communities in the distribution of obnoxious
facilitiesi and (2) risk to human life due to proximity of a
new facility.
The authors of the SDEIS inverted the priorities recommended
by citizens' groups, in favor of technical and engineering
considerations.
The SDEIS Is blatantly biased toward not using Long Island
as a site and toward the greatly expanded use of Deer
Island.
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- Tbe SOEIS has not COM close to considering all feasible
siting alternatives. Its Initial universe of 22 sites
suttees froa substantial preselection bias —- drawn froa
coapleted studies for the EPA and the Commonwealth that
focused on existing facilities at Deer Island and Nut
Island.
- Tbe pruning of the Halted universe froa 22 to 8 and now 7
alternatives was done under a shroud of aysteryt with not
one decision refuting the hypothesis of the SDEIS author's
bias In favor of substantial facility expansion for Deer
Island.
8. Recommendations
This reviewer recoanends delaying the SDEIS process, thereby
allowing tlae for an unbiased scientific, thorough analysis of
alternatives, incorporating vital new Information provided during
the first quarter of 1985. A delay of several aonths Is
negligible In coaparlson to a 9 year construction period and a
likely follow-on Impact period of at least a century. Open tbe
process to the entire community, soliciting Inputs from citizens
from throughout greater eastern Massachusetts. Solicit
innovative suggestions, not preconstralned by existing studies
(studies that often were commissioned in a crisis environment) .
Identify total alternatives, not partial alternatives that are
artificially segmented. Look for other beneficial features
associated with Innovative options. Recognise the need to
consider equity in the distribution of undesirable facilities
aaong communities and simultaneously to consider risk to nearby
human life posed by such facilities. Undertake the new process
in a truly unbiased, value neutral, scientific manner. It may be
discovered that some groups' perceived self-interests are in fact
better served by some options not currently favored or even not
currently identified.
Above all, It is essential that all citizens perceive tbe
decision process, tbe final BIS, and the ultimate decision(s) to
be fair, equitable, and effective In achieving one mutually
agreed upon goal — tbe clean up of Boston Harbor.
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QJnum of fflinttfrop
Boarb ofWealtlj
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Anne H. Dolrympla)
PaulF Dowton
Edward A. Haztett
TOWNHAU
WUMTHfiOP. MASS. 02152
646-1740
Meeting Monday Night
7:30 • 9:00 p.m.
The Wlnthrop Board of Health would like to take this
oppurtunity to go on record with thtlr thoughts as thoy
pertain to tho Supplemental Draft Environaental Impact
Statoaont on tho siting of wastewater treatment facilities
in Boston Harbor.
Proa th« outsot. lot it bo eltar that this Board
roaains adaaant in 4ts belief that tho placement of any such
facility can and must bo placod on Long Island. It should
also bo cloar that this Board is coaaittod to do all in its
pouor to «•• that tho Long Island alternative is tho only
ono under active consideration to becoae reality.
This Board has soae very real concerns associated with
this project. Our concerns are now, and have been, focused
not only at any proposed expansion at Deer Island, but also
at conditions as they exist now.
We have closely aonltored conditions at Deer Island.
Evidence of this is the daily visits by our Director to the
current facility. Based on his reports, as well as ill the
inforaatlon we have accuaulated, we would now like to share
just soae of our reservations with you.
The first of these issues deals with that of water
quality. This Board is concerned about the high incidence
of beach closings that are caused as a result of raw sewage
in the waters. We are not convinced that with any expansion
on Deer Island, coupled with proposed iaproveaents. that
pollution of our waters will not continue. Based on past
performance, who can really blaae us for our reservations?
Also of concern to this Board, and still pertaining to
water quality, is the discovery of a significant
biaaccuaulatlon of PCB's In elaaa in Wlnthrop Harbor. Our
records indicate that DEQE has on dozens of occasions.
closed Winthrop Harbor water* and flats froa all
shellfishing. These claas are harvestedfor human
consuaption. Any reasonable person can easily see and
understand our very real concern about this. We cybalt to
you that this issue Bust be resolved before any siting
decisions are aado.
Recent studies have found that there exists a high rate
of liver cancer in winter flounder found in Boston Harbor.
This can be directly attributedto the continuous buildup of
silt caused by the discharge of raw sewage into the Harbor
froa Deer Island.
The SDEIS has failed to directly consider cancer
causing chealcals which are extreaoly hazardous to any
person who aay eat any of the fish or shellfish. It is
totally Inconceivable that the protection of marine life
could be exaaineo in detail while water quality criteria
related to huaan consumption of seafood that aight be
contaainated remains completely ignored.
Moving to the subject of noise pollution, ue have
additional reservations. It is no secret that Point Shirley
and the Cottage Hill section of Winthrop are in the direct
flignt path of Logan Airport. Couple that with noise froa
the engine mufflers at Deer Island, and you haue a noise
level that is unacceptable and very aggravating.
Even taking into consideration the mitigation factors.
increased traffic to Deer Island, as well as the
constructionperiod and plant operations there, would result
in a strong increase in noise levels in the small, congested
area of Point shirlev. Such would not be the case, nor even
comparably so, on Long Island.
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Let us then look it the subject of air quality.
Increased facilities can only translate into factors that
will adversely iapa'et tht quality of the air we aust
breathe.
Looking at the increased traffic that will result in
eonotruction and plant operations at Deer Island, on* can
plainly see that exhaust ••issions will further pollute the
air. The alligation, factors call for the bussing of woikers
to the facility. These buses will coae through our narrow
and congested streets, spewing forth their dlesel exhaust.
Even after construction, you would have increased
traffic with new workers coalng to an expanded facility.
This is a aatter which is of soae concern to this Board.
Also of concern is the release into the aabient air of
soae aerosols that contain pathogenic aicroorganisas and the
stripping of volatile organlcs into the ataosphere rather
than being wasted with the sludge.
This Board would strongly suggest that there aust be
appropriate air aonitorlng for the full range of priority
pollutants that aight be volatilized as well as for
pathogenic •tcroorganisas.
Looking logically at the alternatives, froa a
standpoint of protecting the health and safety of all the
citizens of Winthrop, we believe that the only site that
would bring the least iapact to the least nuabers of people.
would be on Long Island.
Placement of any expanded sewage treataent plant aust
be on Long Island. This is the Town of Winthrop's
wholehearted belief and fira resolve.
This coBBunity, and alt of its representative Boards
ana coaeittees will leave no stone unturned and no avenue
unexplored in pursuit of this objective. We will not allow
any decision aakers let cost be an overriding factor when
compared to -the protection of the healtn and safety of thi-j
coeauni ty.
The Utnthrop Board of Health sincerely hopes that you
can see our probleas as they really exist.
But. on the other hand, if you can not or will not
recognize these, you will surely recognize our coaaittaent
to the placeaent of any expanded sewage treataent facility
to ita proper place on l_OMG I SI— AND .
Respectfully subaitted.
WINTHROP BOARD OF HEALTH
PAUL F. OAMSON. CHAIRMAN
EDWARD A. HAZLETT.
ARV
-Jc
ANNE H. OALRVMPLE
Subaitted as a aatter of record at the SDEIS Public Hearing
held at the Winthrop Middle School Auditorlua on Thursday
evening. February 28. 1985.
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RE: EPA PUBLIC HEARING ON THE SITING OF WASTEUATER
TREATMENT FACILITIES FOR BOSTON HARBOR
WINTHROP. MASSACHUSETTS
FEBRUARY 28, 1985
Statement by Robert L. Driacoll of the Winthrop Planning
Board
Mr. Chairman and Members of the Panel:
Hy nane la Robert L. Driacoll and I an a member of the
Winthrop Planning Board and also the Concerned Citizens. I
have been asked to address the transportation of chlorine
through our Town roads to the Deer Island facility.
As background for everyone in the audience and so you will
understand fron what point I an coning from: Chlorine gas
compressed into chlorine liquid weighing approximately 30,000
pounds is transported through the Town to the Deer Island
Sewerage Treatment Plant by truck. The schedule is based on
the activity at the Plant and ranges anywhere from a low of
three to four deliveries per week to as many as one or two
daily. The trucks used have an Insulated shell that contains
a stainless steel Inner shell which contains the liquified
chlorine. The trucks have e low center of gravity for
stsblllty and the transport and transfer is done in
accordance with Federal regulations. When the truck gets to
Belle Isle Bridge, the driver is Instructed to phone the
police station for an escort to the Island. But. If the
police are otherwise occupied, they cay be instucted to
proceed alone to the Island. A police car In front may
prevent s head-on collision - but I doubt If there is anyone
in this Auditorium who would dsre go on record to ssy that
there would never be an accident. Bishop or some incident
that could cause a chlorine spill. In your attempt to rebut
our suggestion that this poaea a potential health hazard to
the community, you will probably quote all sorts of safety
statistics. I would like to remind you, now, that such
statistics can be used by many industries and agencies - for •
example, the airline industry and the F.A.A. will talk about
the safety in flying - but the family of those killed in a
crash of a 747 night think otherwise and the Atomic Energy
Commission and Industry will, at the drop of a hat, give
their standard speech on the safety of nuclear power plants -
but I doubt If they would offer to present the speech to the
residents of Three Mile Island and up until a couple of
months ago, Union Carbide might boast of a rather good safety
record. All that was needed to change that was one incident
in a small Town in India.
So, let'a consider for just a moment what is being
trsnsported over our roads and by fcour homes on a routine
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basis:
Tour own Environmental Impact Statement has surprisingly
little to as; on the subject. It does admit to chlorine
being a hazardous aaterial (11.1 Federal and State Permit
Checklist) (BOOI) and it discusses the possibility of
chlorine concentrations exceeding safe Units to saltwater
life and even suggests that alternative disinfection methods
should be considered to minimize chlorine's toxic effect on
•arlne life (11.3 - 29). Tou spend more time in this
document worrying about chlorine's toxic effect on fish in
the water than you do in its possible effect on people on the
lend. In fact, I could only find one sentence that even
alluded to people, when on page 11.3-30 the suggestion is
made that "on alte manufacture of sodium hypochlorite — from
aea water ahould — be investigated as an alternative to
chlorine transport through populated neighborhoods".
Gentlemen, you worry more in this document about flah and
civil war cemeteries on Long Island than you do about the
20,000 people in Wlnthrop.
But, fortunately, there are other documents and services that
do discuss chlorine's potentisl danger. I refer specifically
to the "Emergency Response Guidebook for Hazardous Materials
Incidents" (BOOK) that every Fire Department in the state
must have for reference. There is also the Poison Control
Center. Let's see what they have to say about chlorine:
Even in a very diluted form, chlorine is highly irritant to
the noae, throat, lunga, akin and eyea. It can cause burns
to tissue and mucus membranes which could lead to Infection,
pulmonary edema, suffocation and cardiac arrest (heart
attack). Chlorine la poialonous and may be fatal if Inhaled
and in fact in a highly concentrated form a no oxygen
situation would result which would obviously cause death.
Contact with the liquid may cause frostbite. Runoff water
from fire control or diluting may cauae pollution. It is
possible for chlorine to Ignite other combuatable material
such aa wood, paper and oil. Something to think about in a
community where flOX or more of the buildings are wood framed
and probably over 60Z are heated by oil. If it mixes with
fuels, it msy explode and there la a possibility of vapor
explosion and a poison hazard not only Indoors but also out
doors and if it got Into sewers.
Emergency Action Procedures spell out how to Isolate end
evacuate an area - which I will get Into in just a minute -
but in the instructions on how to fight small and Isrge fires
- one sentence leaped out at me: "For massive fires — use
unmanned hose holders — if not possible to .do so withdraw
from the area and let the tire burn ". In other words, it is
too dangerous to handle and just let it burn itself out and
in the Hedical treatment information along with trying to get
the viclm to breath agsin, it mentions that the effects from
chlorine may be delayed so that the victim must be kept under
observation. Incidentally, the term "Victim" is theirs n0
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• ine.
But what really la important to thla - the Boat densly
populated Town in the Conaonwfslth (and possibly the Boat
denaly populated in the Country) with almoat 20,000 people In
a Town that la only 1 1/2 square alien - which givea you a
denalty factor of over 13,000 people per square Bile (and In
coaiparlaon, the denalty factor for the entire State of
Massachusetts - which la one of the nore denaly populated
atatea la 1300 per aquare alia - the State la 1300 and we are
13,000) and the area la 1 1/2 aquare ailes. In the Guidebook
Instructions that state the initial isolation from a small
chlorine leak la 140 feet in all directions and In the event
of a larger spill, it la 290 feet in all dlrectlona. Then
evacuate in a downwind direction 7/10ths of a nlle widthwiae
and one mile in length. I think we Just evacuated the entire
Town of Winthrop arj depending where in the Town the incident
took place, probably part of Revere - at least Beachmont and
part of East Boston and If we are lucky, maybe Logan Airport
would have to cloae down for an hour or so. There are many
in the Town that would appreciate that.
Having presented the problem the question is what if anything
can we do about it. Obviously, an Environmental Impact study
should be started on the entire process of transporting and
transferring chlorine. Alternative methods of transportation
should be iapllmented --such as barging. But before any
agency la going to do anything - you firat have to get their
attention and make then give more thought to what they may
have already decided on in their own Binds and at the same
time, and moat Important, step* Bust be taken to protect the
people in the community. Therefore, the Winthrop Planning
Board requeata that the EPA immediately ban all further
chlorine truck deliveries to Deer Island though the Town of
Winthrop. Your job is to protect the environment and
obvioualy the Town of Winthrop - but aore Importantly, the
people who live here are part of that environment. If this
ban la not iapllmented by the EPA within 24 hours we then
will requeat tht our own Town Governaewt initiate the ban and
do ao immediately.
We have tried to cooperate with the various agencies and have
lived with and allowed thia altuatlon to go on for too long a
period. Cooperation ia a two way street. We have been
reacting to problems resulting from this facilities
operation. It ia now time for ua to initiate aome action.
By banning the transportation of chlorine through our Town,
Winthrop will be exercising and fulfilling Its responsibility
to the 20,000 residents of the community. We will also be
redirecting and redefining the conaideratlon of the siting of
the new waatewater treatment facility which everyone knows
belongs on Long Island.
Respectfully submitted:
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TOWN OF WINTHROP
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Miry A. K«ll«y. Chairoan
Loll A. Buter
Mary E. Corcoran
Dcnl« D'Aoore
Peter Martlno
Thooaa McCarthy
John McCovem
John Caoavan
CONSERVATION COMMISSION
February 28. 1985
TOWN HALL
WINTHROP. MASS. O2I92
Clean water Is-one of our valuable natural resources. Cleaning up the
harbor water Is why we are here tonight. We are asked to comment on the
alternative for the siting of wastewater'treatment facilities. Deer
Island Is Incorporated. In one way or another. Into six of these seven
alternatives. Once again 1t would appear that Wlnthrop Is at the end of
the pipe.
As an oceanslde community, Wlnthrop has always been concerned about
the degradation of the harbor waters, and has supported short terra
solutions to current problems. Wlnthrop residents have always been
totally commuted to the Improvement of water quality In Boston Harbor.
We would like to be able to swim at Donovan's Beach. It's quiet, sandy,
sheltered, and always polluted. We enjoy our long stretches of sandy
beaches and are angered by the sight of scum In our waters and plastic
refuse washed up on our shores. Those residents with boats have been
disgusted by the odors emanating from, and the sight of, the waters all
around Deer Island. Clam beds are either closed or clams must be treated
prior to eating. Everyone wants to see an Improvement of water quality.
One of the criteria In the SDEIS on Siting, on which Wlnthrop Is
commenting, 1s 'Does It promote the fulfillment of the promise of Boston
Harbor.* How will 1t Improve the water quality and thus the marine
environment of the Harbor? The Wlnthrop Conservation Commission wishes to
state that this report Is Inadequate in a number of Issues related to
water quality.
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Sludge management, treatment, and disposal are Indivisible parts of
wastewater treatment. Discharge of sludge Is a significant contributor to
the pollution problem of Boston Harbor. Any wastewater facilities siting
report should contain methods for alleviating the continuing water quality
problem created by the present sludge disposal method.
Water quality will also be affected by the Impacts of tunnel versus
pipeline construction for the conveyance of wastewater. In the case of
tunnels, where they are located and the water quality effects of the
shafts used to excavate the deep rock spoils materials must be analyzed.
In the pipeline option, water quality and marine life Impacts,
construction dredging activities and disposal of the spoils must be
addressed. Because siting determines the Impact of this construction, the
supplemental draft should have addressed this problem as part of the
report.
Certainly water quality will be affected by the disposal of harbor
sediments contaminated w,1th toxic materials. These materials may be
excavated 1n the construction of shoreline and off-shore facility
components. It should be noted that biological testing of harbor
sediments In connection with other recent construction projects showed
bloaccumulatlon of PCB's In test organisms exposed to test materials to
such a high degree that ocean disposal Is unacceptable. Page 11, 2-18
mentions specifically data from Wlnthrop Harbor which shows significant
bloaccumulatlon of PCB's 1n clams exposed to harbor sediments. This needs
to be resolved before making a site decision.
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The option of satellite facilities has certainly not been fully
Investigated. We are draining our water supply from our suburban
watershed areas and are discharging It Into a salt water environment where
It Is lost to further use. We are wasting a valuable natural resource.
Satellite plants would enable us to return treated effluent to rivers and
wetlands thus reducing the stress on this resource. Satellite operations
would also affect the size of harbor wastewater facilities. This
alternative has not been given serious consideration and, because It
affects the siting process, should be studied further before a final
decision Is made.
Winter flounder Is the dominant benthlc flnflsh 1n the harbor. As you
know, the Incidence of fin erosion In this species appears to be
significantly higher In the Inner harbor. This appears to be caused by
some types environmental stress and researchers have speculated that toxic
chemicals found In harbor sediments are responsible. Fish and shellfish
can store and magnify toxicants found In their environment. Human
consumers of this seafood may be affected by these toxicants, some of
which are carcinogenic. In the SDEIS, page 11.3-6, 'Any effluent
discharge will contribute to the as yet undetermined health risk to humans
eating these fish.' In this report there Is no defined water quality
criteria related to human consumers of seafood. If In fact our goal Is to
Improve water quality. Identification and methods of removal of these
toxic and carcinogenic chemicals should have been addressed In the SOEIS.
•' f {•*. ""*- ~^
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In conclusion, the Wlnjthrop Conservation Commission requests that the
Issuer raised 1Q"bn> luiiiiyjiLMAirTbe-ttddressed. pf Iflf—to the final siting
decision. '
Respectfully submitted,
Mary A. Kelley. Chairman
Wlnthrop Conservation Commission
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Mary A. Keiley, Chairman
Lola A. Baxter
Kary E. Corcoran
Denla D'Anora
Pecer Martlno
Thoaaa McCarthy
John McGovern
John Canavan
TOWN OF WINTHROP
CONSERVATION COMMISSION
February 28, IS
The Conservation Commission for the Town of Uinthrop stands hesitantly
In favor of secondary treatment as most beneficial to the harbor waters
and community beaches. The EPA waiver decision, should secondary
treatment not be mandated at this time. Is a temporary one. As stated on
page 1-18 of Volume I of the SOEIS, this waiver may be withdrawn, and
secondary treatment ordered. In as soon as five years time. Considering
the bad experience record to date for the state's operation and
maintenance of any treatment plant, we believe it Is likely that a
secondary treatment plant will be required in the future.
The EPA has withdrawn one of the eight siting options from further
study (5.b.2 the Long Island option for Primary facilities) for three
primary reasons:
- the existing hospital
- legal and/or institutional constraints
- the possible development of Long Island as a Harbor Island Park.
However, the EPA has retained the major Long Island secondary option
(2.b.l, consolidated Primary and Secondary Long Island option) apparently
so as to alleviate the concerns of Wlnthrop as to the fairness and equity
of the SOEIS report. At the present time, the Commission would like to
offer a scenario of events to the EPA, which will indicate the reason why
the Conservation Commission is hesitant to support secondary treatment for
the harbor's benefit:
TOWN HALL
- MASS. O2192
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- EPA decides to grant waiver, secondary treatment Is postponed.
- One of the remaining three primary options Is selected, probably
4.a.2 but perhaps also 4.b.2. (These are the All Deer Island
option, and the Split Deer/Nut Island option.)
- The Commonwealth (or Boston or EPA) thereby release Long Island
from any further siting considerations.
- Long Island moves Into the Harbor Island Park Plan.
- In five years time, the EPA waiver Is not extended as the harbor
waters have gotten worse.
- Secondary treatment Is required.
- It doesn't fit on Nut Island! Deer Island either becomes leveled
for a consolidated primary/secondary facility, or It Is virtually
leveled and treats the total flow In Its secondary treatment plant.
- There will be no other choice. If the siting option Is foreclosed
on Long Island now, it will be forever lost for the future. Deer
Island will be the only treatment facility site In the harbor, and
Wtnthrop will bear the brunt.
Perhaps the EPA can understand from this logic why It Is hesitantly in
favor of secondary treatment, and not firmly supportive of a.facility
which theoretically could have a dramatic positive Impact on the quality
of the harbor's waters. Some of the Commission members feel deceived by
the possible lack of a fair and equitable treatment of this problem. The
Commission stands steadfast against any option which would have a
destructive Impact to the fabric of life in Wlnthrop. as construction
activities will most certainly have, and are equally opposed to any option
which would destroy the current visual aesthetics of Deer Island and the
drumlin.
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One of the charges of a Conservation Commission Is to strive for a
balance between development and ecology. The drunlln, long abused and
misused by the state and city. Is and has been a landmark for many years
to the commercial and pleasure boaters who use the harbor, as well as the
residents of Qulncy, Ulnthrop and Point Shirley. Removal of the drumlln,
and Industrialization of the entry point to Boston Harbor cannot be
considered.
Recovery of Boston Harbor's waters will require the sacrifice of one
of the Harbor's Islands, whether It be Deer, Nut or Long Island. A
balance clearly must be drawn.
The Commission believes the choice to be between a comprehensive
primary/secondary facility at an Island which Is only planned to be used
as a park sometime In the future, contains a hospital due for relocation
over twelve years now, versus an Island now all too closely associated
with a living but struggling community catastrophlcally overburdened with
too many of the region's 'solutions*.
The point to be made Is simple: If no secondary facility were ever to
be considered, we believe the EPA could consider Deer Island as a rational
choice. For while greatly affected now. It could still preserve some
measure of Its dignity (e.g. the drumlln).
However, (f the decision were based on the belief that secondary Is
possible In the future, which It Is. then the choice of Deer Island for
Primary siting would be the wrong choice. There would be no equity, no
balance. The Harbor's waters would be enhanced but at the expense of a
^~/
town and a visual landmark. There can be no mitigation for the
destruction of our town.
- LONG ISLAND IS THE FARTHEST POINT FROM ANY SHORELINE COMMUNITY,
(Deer/Hut Island the closest).
- LON6 ISLAND IS BEING CONSIDERED AS A FUTURE PARK, BUT 50 ARE ALL
THE OTHER ISLANDS IN THE HARBOR. (Further, the Department of
Environmental Management has stated In Volume 2. Section 12.3, page
29, that they will postpone Island park development until after the
decision Is made.)
- LONG ISLAND'S HOSPITAL IS ANTIQUATED AND UNDERUTILIZED. (It has
been considered for relocation for over twelve years. It has not
been moved due to a lack of motivation. The clean-up of the
harbor's waters should provide this motivation.)
- LONG ISLAND WILL PRESENT LEGAL CONSTRAINTS. (So will Deer Island.
We believe that political willpower Is all that Is necessary, and
the harbor's waters an adequate Incentive.)
It Is thus not an Island versus an Island, but an Island versus a
community. To sacrifice one Island (Long) to benefit all the others will
provide the balance currently missing In the SDEIS. To sacrifice an
established community Is unconscionable. Pages 4-106 and 107 describe how
a facility can be designed to be Innocuous (or even beneficial to Its
surroundings. A treatment plant on Long Island could be the centerpiece
of a clean harbor, not an eyesore. The principal beneficiary of a clean
harbor will be Boston first and the surrounding communities second. Where
1s the fairness and equity to burden one of these communities, and one of
the smallest, and one already overburdened with a jail, a malfunctioning
sewage facility and an airport. LET AN ISLAND BE DEVELOPED FOR THE COMMON
GOOD, NOT A COMMUNITY FOREVER DESTROYED.
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Finally, we find It odd that for all the concern about Long Island and
Its future. In the first section of Volume 2 there Is no statement from
DEM that Long Island Is critical to the Park Plan. Rather, there Is but a
confirmation letter from the Boston Redevelopment Authority, a severely
politically biased organization, to OEM, stating what the BRA believes Is
the OEM position. It appears evident that the City of Boston does not
want Long Island considered as a site to treat the harbor waters. Mayor
Flynn, as Mayor White before him. Is opposed to the consideration of Long
Island (26 July 1984 letter to M. Deland*). The principal (and only)
reason cited: the hospital. The hospital Is overdue for relocation/
reorganization, but the harbor Is deteriorating every day. The EPA's (Mr.
Deland'$) 18 June 1984 letter to the Boston Globe Is exemplary In that he
states other cities have treatment faclllltles designed well, built to
Incorporate recreational and aesthetic benefits. Certainly enlightened
engineering and design can conserve Items worthy of National Registration,
perhaps even showcase them. The time has come for this to be proven, and
not at the expense of a community, not at the expense of the Deer Island
drumlln.
We believe the EPA should not only reinstate option S.b.2 Into the
process, but select It as the favored site. It Is fair and equitable to
all parties, politics aside. It will provide for expansion In the future,
should It be required, for secondary treatment (2.b.l). There Is no other
choice which will bear scrutiny. It 1s the balanced choice between
positive development and further degradation of the harbor and the
destruction of a community.
Kn HcGover
Inthrop Conservation Commission
*It Is noteworthy that this July 1984 letter was In response to M.
Oeland's request by letter of 21 June 1984, one month previous, stating
that the EPA has been waiting already two months for a statement of
purpose on the Long Island Issue from the City, promised 6 April, two
months hence. After three months time, the City of Boston mentioned the
hospital. We refer the EPA to Volume I, page 2-11, the hospital should
and must be moved.
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TOWN OF WINTHROP
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Mary A. K*ll«y, Chairman
Loll A. Baxctr
Mary E. Corcoran
Danla D'Amora
Ptcar Martina
Ttiomaa McCarthy
John McGovarn
John Canavan
CONSERVATION COMMISSION
TOWN HALL
WINTHROP. MASS. O21!
February 28, 1985
The Wlnthrop Conservation Commission would like to offer
Its opinion on alternative selection criteria as suggested on page 2-26.
paragraph 2.6.
Six criteria are presented In the EIS on which comments are solicited.
The Wlnthrop Conservation Commission believes that four of those decision
criteria are not relevant to the.site selection process, and that there
are only two criteria which should carry any weight In the site selection
process.
The first and foremost Is Harbor enhancement (meaning water quality),
the second Is effects on neighbors. The Wlnthrop Conservation Commission
agrees that our main objective must be the Improvement of water quality
In the Harbor. The Boston Harbor Islands Plan.as It currently stands. Is
1n jeopardy principally due to the sub-standard quality of water 1n the
Harbor. The Department of Environmental Management has stated 1t will
formulate a final recommendation regarding a Harbor Island State Park
after Records of Siting Decisions. The development and improvement of
recreational areas In Boston Harbor Is unalterably dependent upon the
Improvement of water quality. After 10 years, the State has not made any
progress 1n Implementing the Comprehensive Harbor Island Plan, especially
the use of Long Island.
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As all the options studied will Improve Boston Harbor water quality.
Harbor enhancement Is not a true decision criterion. The aspect of
future park development Is not pertinent at this time. As the Department
of Environmental Management has stated. Improvement of water quality will
take precedence over the parks.
Therefore our concern turns to the primary criterion-Effects on
Neighbors. Certainly the proximity of the plant at Nut Island has disastrous
effect on the homes In Its general vicinity and Qulncy residents may comment
on this. Twenty-two hundred feet away from the gate at Deer Island Is a
neighborhood—a section of a densely populated community already heavily
Impacted by three of Boston's regional problems: Logan Airport, Prison,
and Treatment Facility. Within one and a half miles of Deer Island gate
live over 19,000 residents of the community of Wlnthrop. We are all
neighbors of Deer Island. We are all Impacted by the Industrialization of
Deer Island.
Long Island Is three and a half miles away from Its closest neighbors.
At most, the effects on neighbors are minimal when compared to the
catastrophic Impacts on Deer and Nut Islands.
Regarding the four other site selection decision criteria:
1. COST
For too long the Commonwealth has been In violation of environmental
laws. Existing wastewater facilities have received only stop-gap measures
or bandald procedures to remedy the pollution discharge problems in Boston
Harbor. Now is the time for the Harbor to benefit fron a well-constructed,
well-designed, modern facility. Cost should not be the driving factor in
the site selection decision.
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2. 1MREHENTABIL1TY
The best siting alternative must be considered, not the one which Is
most easy to Implement.
The objective of this project Is to most effectively clean-up the
Harbor. The Implementabtllty, If there Is such a word, of the project
or the most expedltous method to clean-up the Harbor Is not a criteria
and should not be a criterion to determine the best alternative.
3. RELIABILITY
The question of reliability cannot be one of the decision criterion,
for If It were, the satellite plans would still be under consideration.
Certainly malfunctions of one of many small facilities would not have the
S.ame devastating Impact to the Harbor as a malfunction In one or two very
large facilities. Further, the question of satellites Is perhaps the most
Important and most neglected. As It has not been Investigated properly,
the Issues related to this criterion are not complete.
4. EFFECTS ON NATURAL/CULTURAL RESOURCES
Deer Island 1s the gateway to the Harbor. It has beautiful scenery
and archeologlcal sites which seem to be down-played In relation to Long
Island. There does not seem to be an equity In the analysis of these
two sites, because both Islands are rich in cultural and natural resources
Perhaps this should not be one of the criteria In the decision making
process. If the beauty and the fulfillment of Boston Harbor promise Is
the main objective, then unfortunately It must outweigh the Impact of any
facility on natural and cultural resources.
In conclusion,rating and weighting of the criteria appear not to be
necessary to the decision process. The only crlterlonremalnlng Is the
effects on neighbors. The Ulnthrop Conservation Commission believes
Boston Harbor's promise can be fulfilled without a disastrous effect on
our TOWN. Long Island must be the selected site.
Thank you.
Respectfully submitted,
Lois A. Baxter
Wlnthrop Conservation Commission
LAB
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WINTHROP
ORGANIZATIONS
COMMENTS
2-122
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liflNTHROP LODGE NO. 1078
BENEVOLENT AND PROTECTIVE ORDER OF ELKS
191 WASHINGTON AVENUE
WINTHROP. MA 02152
February 28. 1985
Dear Governor Dukakis and Administrator Deland.
U1NTHROP LODGE NO. 1078
BENEVOLENT AND PROTECTIVE ORDER OF ELKS
191 WASHINGTON AVENUE
UINTHROP. MA 02152
I bring a message to you from the thirteen hundred members of the Wlnthrop Lodge No. 1078
of the Benevolent and Protective Order of Elks.
February 28. 1985
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The message Is:
U£ ARE UNEQUIVOCALLY OPPOSED TO THE EXPANSION OF THE DEER ISLAND
SEUIAGE TREATMENT FACILITY.
Dear Governor Dukakis and Administrator Deland,
Please Include the attached advertisement In the minutes of this public hearing. It appeared
In tha February 27th edition of the Ullnthrop Sun Transcript.
UE WILL SUPPORT THE POSITION OF SELECTMEN ROBERT DELEO, ROBERT
NOONAN, RONALD VECCHIA. AND OTHER CONCERNED CITIZENS BY WHATEVER
MEANS AVAILABLE TO US.
CONSCIENCE DICTATES THAT THE WELFARE OF TWENTY THOUSAND RESIDENTS
OF UINTHROP IS MORE IMPORTANT THAN A POSSIBLE PARK ON LONG ISLAND.
Yours truly,
Thomas M. Memmolo. Chairman
Government Relations Committee
WE VALUE THE SAFETY OF OUR CHILDREN AND OUR SENIORS. AND LIE MILL NOT
SIT QUIETLY AND ALLOU1 YOU TO SHIRK YOUR RESPONSIBILITIES TO A
COMMUNITY, UHICH HAS EXTREMELY LIMITED ACCESS BY ROADS, WHICH WERE
NOT BUILT TO ACCOMMODATE HEAVY HAZARDOUS TRAFFIC.
Yours truly.
Thomas M. Memmolo, Chairman
Government Relations Committee
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AT THEIR FEBRUARY 13th MEETING. THE OFFICERS AND MEMBERS OF THE
WINTHROP LODGE NO. 1078 OF THE BENEVOLENT AND PROTECTIVE
ORDER OF ELKS VOTED TO GO ON RECORD IN OPPOSITION TO THE
FYPANSION OF THE DEER ISLAND SEWAGE TREATMENT PLANT.
GOVERNMENT RELATIONS COMMITTEE CHAIRMAN ~
THOMAS M. MEMMOLO HAS BEEN INSTRUCTED. BY THE LODGE.
TO ASSIST THE BOARD OF SELECTMEN IN THIS FIGHT.
THE WINTHROP ELKS WILL STAND WITH SELECTMEN ROBERT DaLEO,
ROBERT NOONAN. RON VECCHIA. AND OTHER CONCERNED CITIZENS
i>". IN OPPOSITION TO THIS OFFENSIVE PROJECT.
Wli-i. YOU STAND WITH US?
PLEASE ATTEND: THE PUBLIC HEARING.
: WHICH WILL BE HELD A T: ' '
MEMORIAL AUDITORIUM
MIDDLE SCHOOL:« PAULINE STREET !
THURSDAY EVENING, FEBRUARY 28th
- AT 7:00 P.M. -
Y01 SUPPORT IS URGENTLY NEEDED,
ROTARY CLUB OF WINTHROP
ISO GROVER9 AVENUE •:• WINTHROP. MASSACHUSETTS O2I32
Regional Administrator
Michael Deland
U.S. E.P.A. Region 1
J.P.K. Building
Boston, HA 02203
February 28,1985
Dear Mr. Deland:
I am representing the Winthrop Rotary Club in our opposition
to the expansion of Deer Island. He feel that there are the
issues of fairness and safety to be considered. Winthrop is
already burdened with the hazards of the Deer Island prison
as well as Logan Airport. A new sewerage treatment plant on
Deer Island will only add to the misery presently felt by
Winthrop residents.
Of even greater importance is the safety factor involved here.
your proposals would call for many large trucks transporting
materials through Winthrop to the plant site. Not only are
these roads narrowly constructed, but also are highly residen-
tial and are not equipped to handle the traffic flow required
by this project.
If Deer Island was the only possible solution to a serious
problem we would be more sympathetic to your solution. However,
there is a more viable and neutral alternative on Long Island
that we do not feel has been adequately considered. It is most
important that existing neighborhood impacts are given the proper
consideration over a potential recreational facility that may
never come to pass. The new treatment plant belongs on
Long Island.
Yours truly.
Paul D. Coroerford
President
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James. S. HoyU '
Secretary. Executive Office
of Environmental Affairs
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TESTIMONY FOR E.P.A. HEARING FEBRUARY 26. 1985
IF A TRUCK BREAKS DOWN. OR AN ACCIDENT OCCURS ON MAIN STREET. OR SARATOGA
STREET. WE IN WINTHROP ARE TRAPPED. If we ire driving, there is no way
to go. On two-way.two-lane streets, turning around or seeking an alternate
route, la lust not possible. Getting out of Wlnthrop during rush hours
can take 20 minutes at times. We've all experienced these delaya. The
addition of more trucks and buses Bakes this situation impossible. A break-
down, even in one lane, cuts the traffic capacity in half. TRUCKS DO BREAK
DOWN. ACCIDENTS DO HAPPEN.
IP A TRUCK BREAKS DOWN ON THE NARROW, WINDING STREETS OP POINT SHIRLEY,
AN EUERG.ENey QUICKLY BECOMES A DISASTER. The residents of that thickly
settled section of town have only one nay out.
In the report, under the heading DEER ISLAND CONSTRUCTION TRAFFIC IMPACTS
none of these Important factors have been considered. The fact that all
of the roads in our one-aquare-nile town of 19.000 residents are twoiway.
two-Ian* narrow thoroughfares, through thickly settled areas, with the
exception of the short span of Veterans Road, has not been emphasized
strongly enough. The conclusion is reached. In this report, that the roads
have no capacity problems, other than the short one-way aection at Eliot
Street, and at Intersections.
Intersections are a problem now, .not only at Shirley Street and Washing-
ton Avenue, but at Kageea Corner, with its six converging streets. These
are both part of the Deer Island Truck Route. The suggestion that the
use of crossing guards and traffic controls would mitigate the problem
is unrealiatic. • It would make the problem worse. The impact of the
addition of 940 trucks and buses daily and 1300 construction workers
would be devastating. Do we really believe that staggered travel would
be Implemented ?
I would like to refer to the statement in the report on Page 12.3 - I1*-
I o.uote 'Hovever, the existing mix of autos and trucks through these two
communities ( referring to Wlnthrop and East Boston) is sufficiently high
at present, so that residents and visitors alike must exercise caution
when either walking or driving. Therefor*, the addition of the relatively
small number of construction vehicles, compared with the existing traffic
volume• would not be an appreciable change, in terms of traffic conditions,
from the current conditions.* end quote. Is It possible that the fact
that, because we in Wlnthrop must drive and walk carefully now, due to
the already congested traffic conditions on o\rf streets, justifies
the addition of more trucks and buses? Are 940 trucks and 1300 con-
struction workers a small number?
Can we really believe that difficulties due to parked cam deliveries,etc.
on the part of the street that contains stores and businesses, difficulties
which are acknowledged in this report, can be mitigated by traffic control.
personnel during rush hours? This reports states that it can. What will
happen whaa It snows, and the streets become even narrower? We shudder
to think of It. Any Wlnthrop resident can testify to the existing traffic
problems, and the possiblity of adding to then la a nightmare.
The discussion of the traffic impact on the route to Long Island on Page
12.2 18 and 19 of the report states that it would have a minimal impact
along that route.
To us, in Wlnthrop, the choice is clear. For traffic reasons alone.
in our one^uare-mlle town, not even counting the other very important
considerations mentioned here tonight, the site should be Long Island.
Cbaf&
We Invite you to travel along the Deer Island Truck^some morning, and
honestly judge for yourselves.
Thank you very much
Barbara Gloss
256 River Road
Winthrop
Concerned Citizens Committee
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WINTHROP HIGH SCHOOL PARENTS CLUB
MAIN ST. WINTHROP. MA. 02152
WINTHROP HIGH SCHOOL PARENTS CLUB
MAIN ST. WINTHROP.. MA. 02152
REi EPA Hearing, Memorial Auditorium, Winthrop, MA February 28, 1985
Gentlemeni
My name is, Laura Pelletier, and I represent the Uinthrop High
School Parents' Club.
We feel that the health and welfare of our families and com-
munity has been jeopardized as much as we can possibly allow.
Winthrop has been un-fairly treated for sometime now and the
time has come for us to say, "NO MORE."!!
We are all for Harbor Island Developement but not at the
costs and risks you are asking us to pay.
(2)
REi EPA Hearing. Memorial Auditorium, Uinthrop, MA 02.28-85
on our already congested narrow streets not to mention the effect
it will have on reducing our property values.
Placing the needed facility on Long Island seems more than
fair. We think that if you people take a close look at our town.
the home of almost 20,000 people, you will see that we have done
more than our share and it's about time for Boston to do its part.
We already have to contend daily with the noise from Logan
Airport, jet exhausts that pollute our air, beaches already too
polluted to use and constant fear of prisoners escaping.
Now, you want to place the burden of an expanded Regional
sewarage treatment facility on us too. This will only increase
our noise. Increase our air pollution and increase the traffic on
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Town of Winthrop
Town of Winthrop
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BEAUTIFICATION COMMITTEE
TOWN HALL
WINTHROP. MASS. 02152
FEBRUARY 28, 1985
CHAIRMAN
Frank Costantlno TO ALL CONCERNED PARTIES REGARDING THE DEER ISLAND
TREASURER
Joseph Franzese
COMMITTEE
Ann Baldwin
Norma Belcher
Margaret Dimes
Kathy Nelson
Christine Poor
Claire Rupp
Lewis Winter
SEWERAGE TREATMENT PLANT AND EXPANSION
Dear Federal Officials,DEA and HOC Spokesmen,State
and Winthrop Representatives,Ladies,Gentlemen and
Children,
I speak here this evening on behalf of the
members of the Winthrop Beautification Committee.
For the past three years,our group has undertaken
landscape projects on public grounds located through-
out the town.Because of our work in these three
years,each of us has grown more sensitive to and
appreciative of our local environment.
We see and feel the vitality of the earth
enhanced by our efforts.We- see and feel the joy,
delight and satisfaction our flowers,shrubs and trees
bring to people's hearts.The Beautification Committee
has assumed a responsibility and a common trust to
improve our environment,to protect its vitality,to
maintain its inherent beauty.It could be said we are
Winthrop's Environmental Enhancement Agency.
We also see and feel the vitality of the su-
rrounding sea.Our concern for the land extends beyono
its shoreline to the ocean,our expansive watery
environment.lt seems to this committee,that Winthrop
residents must assume their responsibility for
unlittered beaches;that the HOC and DEA must carry
out its mandated responsibility for unpolluted
harbor and coastal naters;that the EPA must fulfill
its legislative responsiblity for maintaining our
shining seas,and together we all must oe responsible
for preserving these vast life-sustaining waters in
BEAUTIFICATION COMMITTEE
TOWN HALL
WINTHROP, MASS. O2152
CHAIRMAN
Frank Costantlno
TREASURER
Joseph Franzese
COMMITTEE
Ann Baldwin
Norma Belcher
Margaret Dimes
Kathy Nelson
Christine Poor
Claire Rupp
Lewis Winter
a vital state.
The Winthrop Beautiflcation Committee need not
reiterate the numerous environmental hazards asso-
ciated Kith the Deer Island plant.Rather,we would
let our work,the living chorus of this season's
flowers,shrubs and trees,voice a wordless testimony
of opposition to this most inappropriate expansion.
We ask the officials here tonight,whose duty
and responsibility is to serve the public need,to
do more than protect the environment of 20,000
people.We ask that you not endanger,but enhance our
environment.
We cannot shirk the custodial responsibility
for our environment.Our neighbors,our children,our
grandchildren's children must learn of their steward-
ship through one another's example.No words regarding
this responsibility could ring more true today than
those written 400 years ago by William Shakespeare....
"And Nature does require her times of preservation,
which,per force,I.her frail son,must give tendence to."
Respectfully submitted in the spirit of
community service,
THE WINTHROP BEAUTIFICATION COMMITTEE
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The members of the Winthrop Emblem Club, part of the Supreme Emblem
Club of the United States of America, strongly oppose the expansion
of the sewerage treatment plant at Deer Island, Boston.
Deer Island, Boston, Is geographically an extension of Point Shirley
Ilnthrop by a small land filled area. The treatment plant In existence
at the present time at Deer Island Is antiquated and can not take care
of the current Incoming swill and excretment. A secondary plant might
be considered to alleviate the present Inadequate conditions. However,
the Town of flnthrop could not consider a new sewerage line to accommodate
other communities with their vast sewerage and waste. We can not,
we will not, and do not Intend to allow the expansion of this facility
at Deer Island because It Is detremental to the well being and health
of the Citizens of the Town of Winthrop.
Our surrounding waterways, ajacent to Boston Barbor and Revere Beach
have been polluted for several years; the airport, which has expanded
its territory beyond all expectations, has cut off the swift flow of
ocean water not allowing pollutants to be carried away from the coast
line, causing a dual problem with the sewerage from Deer Island and
this furthers the contamination we are receiving by the lack of natural
flushing from our ocean water currents. Winthrop could not tolerate
more sewerage with these already existing conditions.
.In addition, to enter the Town of Ilnthrop, traffic has to cross the
bridge from East Boston, or enter through a road from Beachroont, Revere.
These two entrance roads Into the Town of Winthrop are narrow and heavily
used. Heavy trucks and Increased motor vehicle traffic en route to
Deer Island would Increase safety hazzards for residents, fire apparatus,
ambulances, and emergency situations; such as, a disaster. Also, there would
be increased chemical truck deliveries to Deer Island In need of a police
escort. ; j :
For all the foregoing reasons we'emphatically oppose the proposed treat-
ment plant at Deer Island, and we strongly urge location of this plant
on Long Island, which could accoomodate proper distribution of waste due
to Its geographic proximity off the coast of Massachusetts.
1984-85 officers
Jones N. Matarazzo
John E. Zuffante
?>•«-*•,
Michael K. Matarazzo
Lillian M. Dyer
Meyer I. Blunenthal
Lucille M. Llmone
fkfcert V. Bucnqpane
Past President
Jones J. Frati
Fund Raising Chairman
fdcnard C. Idmone
WINTHROP BAND PARENTS ASSOCIATION
Winthrop High School, Main Street
Winthrop. Mauachuutt» 02162
Mr. Michael R. Deland
Regional Administrator
0.8. Environmental Protection
Agency
February 28, 1985
Mr. Jamea S. Hoyto
Secretary
Executive Office of Environmental
Altai[•
Commonwealth of Massachusetts
Dear Mr. Deland and Secretary Hoytat
The Winthrop Band Parents wishes to be on record as
opposed to the siting of any new or expanded sewerage
treatment plant on Deer Island. I would like to address
By first few comments to Secretary Hoyto, as an officer
of State government. Article I of the Constitution of
the Commonwealth of Massachusetts addresses the rights
of its citizens to equality, protection of property,
safety and happiness.1 Any expansion of the present
facilities on Deer Island appear to us to violate all
of the aforementioned teneta set forth in the Constitution
in favor of the questionable, potential development of
Long Island as a 'recreational area.* It is difficult
for my members to understand how you can carry out your
responsibilities of protecting their individual guarantees
under the Constitution by proposing, in effect, to
devalue their property and endanger the safety of their
children by bringing in hundreda of trucks and cars
through a town with narrow streets and an existing
traffic problem.
What appears to be happening, in light of the Draft
Environmental Impact Statement, i» that the Com&or.wealth
is biased against its citizens in Winthrop and that their
quality of life as well as their rights do not seem to
matter when compared to*a larger, basically devoid of
people, easily accessible Island, namely Long Island
which is available as a site.
The Winthrop Band Parents Association supports a clean
harbor and adequate sewerage treatment. We also point
out to you that we, as citizens, have rights to the
protection of our property, to safety, and to some
measure of happiness. These few facts make it difficult
for us to conceive how your agency and other state
agencies could recommend anything but Long I
the entire regional sewerage treatment facility1.4-'
LIAR 1 9 ms
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Mr. Secretory, the framar* of the Constitution of
Massachusetts placed the rights of the citizens
first. It is our belief that th« Executive office
of Environmental Affairs should placs the rights of
Winthrop residents above the property rights of those
who think that Long Island will some day be a home
to a park or to a luxury condominiums.
Mr. Deland and his agency ar* charged to assist states
in implementing clean air and water regulations. At
the same time the EPA has be«n directed to consider
the economic impact of any decision. •* In Hinthrop,
as a town, the economy will be adversely affected and
the citizens will suffer.if the plant were located at
Deer Island. The task then of balancing the need for
a clean harbor and the rights of citizens of the Comnon-
wealth form the central issue. We hope the rights
of 19,000 people will prevail in the decision.
Sincerely yours.
M. Matuazzo
Praaident
Winthrop Band Paranta •
Asaociation
JMH.sk
1 Manual ot th« Csneral Court, 1981-82. pp. 60 and 162.
* The United States Government Manual, 1984/8S.
Washington, D.C.i USQPOJ 1984, pp. 480-481.
3 Government Agencies.
Wesport, CTi Greenwood Preas, 1983, p. IBS.
Toi Environmental Protection Agency, Metropolitan District
Commissioner, Our Board of Selectmen and fellow residents.
Date: February 28, 1985 ;
As a me»a«r ot the Senior Citizens Council for the Town of
Uinthrop and the spokeswoman fur our senior citizens, I would
like to make these comments.
We senior citizens are saddened with the recent turn of
events regarding the plans for the Sewerage Treatment Plant
st Deer Island and also frightened at our future prospects
for the quality of living in the Town of Uinthrop.
We are also concerned thst our children, grandchildren and
grest-grandchildren will not have the opportunity to enjoy
the quality of life that we once enjoyed and the only reason
for many of us years ago to choose Winthrop as the community
to raise our families.
Over the years, we have observed - with an uneasy concern -
the changing character of our Town, These changes have
occurred not as a result of our choice - but under the
disguise of progress and universal need. The quality of lift
in Uinthrop has not improved because of the msssive expansloi
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at Logan Airport, the increase In the Innate popoulation at
Deer laland, nor with the sewerage treatment plant at Deer
Island. But, we have grudgingly accepted these events ss
our "good citizens" shore of the responsibility for giving a
better life for the many.
But we cannot accept thla propoaed construction. We cannot
and will not watch with apathy further deterioration of the
quality of life of our fjallles and fellow residents. Ve
should not allow this project to commence at Deer laland.
The senior citizens are dependant on and entitled to their
ability to nove about the Town - on foot - without fear of
injury or loss of life.
If the construction plans are approved for expansion of
sewerage gathering and treatment a: Deer Island, our streets
will be overwhelmed with the flow of trucks, buses and cars.
As It Is doubtful that we can physically accomodate the
thousands of construction workers and personnel assoclsted
with this project, how can we feel secure In traveling our
streets? And this condition of seine will- go on for
years. After construction Is complete the lessened flow of
traffic will still make our streets unsafe.
Tet the more subtle but significant danger will be in the
dramatic increase in the number of trucks csrrylng cholerine
to Deer Island. The amount of clorine required by the
•xpanded treatment plant is unknown to me at this time) but
it is common knowledge that chlorine in a state of liquified
gas is extremely hazardous. Its potential for destruction to
life and property is immeasurable and impossible to
imagine. But the anticipation and anxiety of an accidental
explosion will be constantly a ahadow over our heads.
Although there are many more harmful conditions that we can
expect, I cannot comment on the technical complications.
There era many more qualified speakers that you have heard
and will hear from. <
I. will conclude by stating that the Environmental Protection
Agency must not approve of any alternatives that call for
expanalon of the treatment facilities at Deer Island. To dc
so would be a tragedy to the elderly of Winthrop.
But if our pleas are not heard then we must take more drastic
measures - even if we senior citizens must move ourselves
into the streets and physically stop the trucks and people
from disrupting our quality of living
Thank you for allowing me to speak in behalf of the Senior
Citizens.
Respectfully submitted:
'-•< . ( .-- . '• ~ ' ' . '.
COUNCIL ON AGING
TOWN OF VINTHROP
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WINTHROP CONCERNED CITIZENS
tv)
STATEMENT FUR EPA HEARDW -
Presented by Arthur T. Cumming*
Concerned Citizen* Committee
February 28. 1985
The major foeu* hero thla evening 1* th* *ltlng of th* proposed
primary tod secondary esworag* treatment plant. The people of Wiatbrop
have nad* it abundantly clear that the only reasonable and Juit location
for thl* eltlnf 1* on Long Island, and not Deer Iiland.
Aa in Boat meeting*, tbar* ara hidden agenda item*. Thar* la
mention of such an item on p. 3 of the 3HBT3. I quotei "Hone of the
description* In thla Summary, or la chapter* 2 and 4, include the impact*
of the procaselng, atoraga or dlapoaal of aludgaa and other aolid waataa
that are expected to be generated by the waatewatar treatment proeeaae*.
Theee Inpaota could be alcniflcant by themselves, but the decision on
siting of the waatewatar treatment faoilltiaa i* not being drlren by a
choice of aludge option*, aine* none of the wastawatar treatment •
facility options would forecloae any alodge management eolutlon. The
impacts of eludge dlapoaal will be defined in a aaparate atudy and
daacrlbed In a aeparate Environmental Impaot Statement in the near
future, not in thle document."
I auggeat, ladlee and gentleaen, that thl* 1* like the pregnant
lady conaiderlng birthing leiaona without any plan* or preparation aa to
what will be done once the baby la delivered.
Construction of the pbyelcal plant cornea to a eoncluaion.
Management of the aludge generated by the plant extenda ad inflnltum.
The queatlon then becomea, what will be done with the aludge? Thla la
addreaaed in Vol. 2 12, 9-12 of the BIS where it atatea that th*
dlapoaal aethoda eonaldered werei
1. Compoating
2. Incineration
3. Ocean Dlapoaal
k. Landfllllng
"The laauee for eltlng of aludge facllltlea associated with
each of these dlapoaal methoda are varied according to the regulatory
and operational factors governing each method. In general, aludge
diapoaal would require additional land area, equipment and ataffing.
and coots (capital and 0AM), and would Introduce added potential
environmental Impacta including nolae, public health, odor, truck
traffic, and air quality. However, these added effects would not alter
the relative Impacta of the treatment plant altlng alternatives
discussed In Suction ».0 of Volume 1."
That's absurd!
Let'* consider for a few momenta th* ramifications of the
preferred Dsthod of aludge dlapoaal - compoating. Primary treatment on
Deer Island would produce 100 dry ton of sludge a day, while if secondary
treatment la added, thl* would accelerate to 2OO dry tea a day. It is
obvious that there would not be sufficient area to compost on Deer Island,
which la why I quote from P. 12. 9-5 (d) Traffic.
"Traffic 1* a potentially significant adverse impact insofar aa
trucking deliveries or pickups are required. la the eaae of composting
facilities, thl* may involve two to four deliveries per week of wood
chip* to a sit* and another fourteen to twenty truck* dally to pick up a
finished compost " product for distribution. Such truck volumes can be a
significant adverse impact on local residential area* closest to a alte
if the aoeeaa and local roadway conditions are not adequate to accommodate
such traffic. Barging would minimize these Impacts, and 1*, therefore,
recommended for all eludge tmnagement method* to th* "*^'-*"' extent
feeelble."
However, thl* atatenent la a contradiction to th* statement on
P. 12. 9-12 which etatee these added effects would not alter the
relative impacts of siting treatment faoilltlee ad mentioned in Volume 1.
Coajpoatlng, therefore, 1* an adjunot at beat.
Thl* leavee Incineration, aa the only viable alternative,
although the state eay* that it does not prefer Incineration. Th* fact
that th* *tat* *nd EPA did not inolud* th* impact* of a aludge management
facility on Deer laland wa* outragaoua, coneiderlng the faot that the EPA
had previously, via an EI3 Record of Decision in 1980, approved aludge
incineration at Deer laland. It ha* alao been atated by MDC personnel
that they aasume the sludge management facility belonga with th* plant.
What doe* incineration mean to Uinthropt It means a trade-
off of clean water for clean air! I quote from Volume 2, Air Quality
where air quality waa mentioned briefly and inadoquatelyi
"Odor* produced by compoetlng, or noxious gases produced by
Incineration, could affect adjacent land uaae. In Boston Harbor,
prevailing summer wind* which are from th* southwsst would tend to
carry potential odor* or gaaee produced out to sea and away from
population concentrations. However, during less frequent periods of
onshore winds, odors or gaaee may be carried toward* residential areas
and population concentrations."- (which la generally the case in the
It 1* also Important to note that these noxious gases referred
to can be toxic and carcinogenic. Air quality represents a potentially
aignlflcant impact of sludge processing and dlapoaal. Notet noxloua
gases from aludge deposits have caused paint to peel from houses In
Winthrop.
Incineration both in economic terms and in environmental terms
1* costly. More Importantly, it has the potential for aignlflcant adverse
health Impact on the reaidents of Vlnthrop and the neighboring prison
population - both guards and inmates alike. Baaed on Its track record.
If we rely on the KDC to efficiently operate, maintain, and administrate
a facility of this magnitude, we are in serious trouble. Can we possibly
have confidence in an administrative agency that would allow the present
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facility to d*t*rlorat* to today's condition* of Inafflolcnoj and •!•_
aanagamantY Although th*r* 1* a n«w authority. It wlU b* staffed with
Baojr of th* MM paraonnal.
You oannot count on Pcdtnl or Stet* A(*nel«i that t*ar down
hlatorle D*«r Island Light and than «r*ot two or mar* ISO1 lnain*rator
•taek* a* it* l*gaey!
If th* *tat* and DA nally b*llm that th* siting IMUM ar*
**parat* from th* sludg* •anageBint laiugi, th*n 1st th*m this *v*nlng
guarantm a polioy that pl*c«* *ludg* faollltl** away from th* aew«rag*
traatoant faollltl**, tharaby for*r*r *llndnatlng D**r Iiland a* th*
*it* for a aludg* manag*mant faolllty.
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TOWN OF UINTHROP
REPRESENTATIVE CITIZENS COMMITTEE
February 28. 1985
U)
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The residents of Winthrop have been extremely concerned with the
transportation of chlorine through our streets and with good reason.
Chlorine gas, an active poison, was the first gas used in chemical warfare in
World War I. It is so dangerous that the Federal Department of
Transportation will not allow chlorine to be transported by airplane.
A short-term exposure to chlorine gas may cause severe irritation
of the eyes and respiratory tract with tearing, runny nose, sneezing,
coughing, choking and chest pain. Chlorine causes human lung damage with
severe breathing difficulties which may be delayed in onset, yet result in
pneumonia. In high concentrations, chlorine may irritate the skin and cause
sensations of burning, inflanation and blister formation. Severe exposures
to chlorine may be fatal.
Presently, the Deer Island Treatment Plant receives six truckloads
of chlorine per week. Projections for the expanded primary treatment plant
at Deer Island are for 9,130 tons of chlorine per year. All to be
transported through the most densely populated town in the Commonwealth.
There is no safe route to Deer Island. All areas of the town are in danger.
The high school is less than 1,000 feet from the truck route; the hospital
about 1.300 feet; the Dalrymple school about 1.500 feet, and the Middle
School is about 2,200 feet from the route. A chlorine spill of only 800
square feet would require a downwind evacuation area 2 miles long by 1 1/2
miles wide based on a wind velocity of 6-12 MPH for maximum safety. This
dimension is larger than our town. ,
The potential for disaster is tremendous-especially for a town with
a large Senior Citizen population. Evacuating almost 20,000 people over the
two existing roadways would be almost impossible. Yet a disaster can happen,
as evidenced by the recent tragedy in India. Deer Island had numerous
chlorine leaks in 1982. In addition, 250,000 residents of Nississauga,
Ontario (near Toronto) had to be evacuated after chlorine leaked from d train
derailment. The Boston Globe on October 16, 1978 had a picture ofjclouds of
chlorine gas resulting from an accident which occurred in Youngstown,
Florida. These disasters can and do happen. I
The best solution is to consider alternative methods of
disinfection at the sewerage treatment plants. The only other solution is to
require the on-sight manufacturing of sodium hypochlorite from sea water. In
any case, the transportat ion of chlorine through the heavi1y populated
neighborhoods of Winthrop must cease.
I would like to address the SDEIS report itself. I find the report
very biased in favor of a Deer Island solution while reaching for reasons as
to why Long Island should not be used. 1 am very irritated about the Summary
Report, knowing full well the majority of people, and especially the press,
would not read the complete two volume report.
The photographs of the various sues are very biased. All photos of
Nut Island are angled to show the proximity of the p I ant to the homes. When
you photographed Deer Island, the angle was away from Winthrop giving the
impression Deer Island is only near Winthrop. The Summary report gives us a
nice photo of the Brewster Islands and a picture of people fishing from the
Castle Island pier—neither has anything to do with the issue. You also
include a picture of the Long Island cemetary and a picture of the wreck of a
treatmnt plant at Deer Island. Hardly a balanced presentation.
In Volume I. Section 3, Page 16, you include a wind flow chart
entitled "Selected Summer Winds". What are selected summer winds? Your
chart would suggest we rarely have an East or Northeast wind. Obviously your
intent was to convince us odors would be blown away from populated areas. I
am sure the residents of Point Shirley would disagree.
Finally, you describe Long Island as a major historical find
including an indiao grave and the site of old fishing shacks. The historical
significance of Deer Island has been ignored. Speaking of history, you do
not seem too concerned about heavy construction vehicles and chlorine trucks
passing our Deane Winthrop house which was built in the 1600's.
In conclusion, the siting priority must be based on safety and
nuisance impacts of a facility on a community. Winthrop can no longer bear
the impact of foul water and air from Deer Island, noise from Logan Airport,
and escapees from the House of Correction. The only solution is Long Island
which is 3 miles from any residential area.
Ernest E. Hardy, Jr.
229 Woodside Avenue
Winthrop. HA. 02152
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WINTHROP WINTHROP CONCERNED CITIZENS
Anne C. Porter, Co-Chairpersor
U>
STATEMENT AT PUBLIC HEARING
FEBRUARY 28, 1985 ,'
in response to the SDEIS document
February 28, 198S
[WINTHROP WINTHROP CONCERNED CITIZENS
k
/
For almost a year now the Concerned Citizens' Committee has been ac-
tively mobilising for this hearing. We've been cold chat chls Is our one
golden opportunity to respond Co EPA's plans for dumping as ouch of the
region's sewage ss possible on Deer Island. He had been hoping that chls en-
vironmental impact report would be fair and comprehensive. But this whole
study process has resulted In s document chat la biased, incomplete, and
cocally Inadequate In measuring Impacts.
_ We thought thac an EIS was supposed to consider all Che possible 1m-
paccs that a sewage plane could have on Ics neighbors, and Chen rate each of
Che alternative sices sccordlng Co Che level of impacts so chat a decision
could be fairly reached. But how can anyone Judge the possible Impacts when
we don't even know which method of sludge disposal will be used? The only
chlng this scudy cells us is chsc "Hone of Che sludge disposal options would
slcer Che respecclve treatment-siting alternatives' relative impact and none
of Che sewage treatment facility options would foreclose a sludge management
solution." What Is Che Scate and EFA's definition of "relative Impact"?
A major Incineration plane that burns PCB's and other Coxic wastes and con-
stsncly pollutes Che air wlch Its tall smokescacks la noc considered by these
agencies as an extremely adverse impact? A landfill operation requires elcher
large amounts of land on sice or 1C will Impact Its neighbors with the trans-
port of hundreds of trucks carrying sludge through densely-populated neigh-
borhoods. But this study ignores these and all other Impacts of sludge dis-
posal. This is Just one example of Che glaring lack of information. There
are many other areas even within the defined scope of this study, where data
is either missing completely. Is Inaccurate, or is analyzed according to
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WINTHROP WINTHROP CONCERNED CITIZENS
2.
different criteria for different options. We don't know how the Water Re-
sources Authority, or anyone else for that matter, can possibly make a fair
and informed decision based on this study!
EPA claims that they haven't given priority to any of the six criteria
that they're considering. They have already made some decisions on these
options by eliminating option Sh> 2 with a wave of the hand. The Winthrop
Concerned Citizens' Committee feels that there are some priorities that have
to be considered.
Siting a sewerage treatment facility endangers health, asfety, and
property. In regard to the property vslues of Point Shirley and Cottage Hill
' residents, the homeowners here tonight should know that their property values
are expected to decline and maybe "rebound.14 Possibly not rebound if s sec-
ondsry regional treatment plant Is built. Are they talking about a basket-
ball game or people's homes and life-time Investments? A facility that is
this dangerous threatena the LIVES of its neighbors. It must be sited as far
away from residential areas as possible! There's something Inherently wrong
with this study. It cites in great detail all of the possible "severe impacts"
to wildlife, vegetation, future picnic areas, grsvesites, etc.; but It dis-
misses any discussion of impacts on neighboring communities as "HuisancesT"
What Is a "Nuisance?" It la an Inappropriate word used here to describe
major impacts associated with building a regional sewerage facility. Is
Nuisance a peaty mosquito or a chlorine truck carrying a deadly cargo down a
narrow Winthrop residential street? Would it be a Nuisance if 19,000 people
could not possibly be evacuated in time to prevent thousands of deaths In the
event of a chlorine leak?
WINTHROP WINTHROP CONCERNED CITIZENS
3.
We're cold Chat any problen that Winthrop would suffer under any of the
Deer laland options could be "successfully mitigated." Our position Is that
the only possible mitigation In siting this facility rests In the siting
decision Itself I We completely reject the Idea that a combination of barging
and bussing would solve all our problems! And we question the Integrity of
anyone who offers these solutions without any explanation of costs, feasibility.
and the extent of their use, and without any mention of who has the authority
and the responsibility to Implement these plans. What's at stake here is much
more than a Nuisance — up to ten years with thousands of construction trucks,
heavy equipment, and personnel travelling through Wlnthrop's narrow streets
each day I
We're told that the Impacts we already suffer froa Logan Airport and the
Deer Island Prison will be considered. The State and the EPA present In this
document and I quote "The principal impact from the airport Is noise, the Im-
pacts of the House of Correction Involve traffic, visual quality and social/
psychological disruption from escapes or the reasonable fear thereof."
The WCCC contends that the principal Impact from the airport Is noise,
the secondary Impacts are the incredible smell of jet fumes, and the loss of
the use of our own recreational facility at Coughlln Park.
Have members of the decision-making agencies ever been to Coughlln Park
at Ft. Shirley with a young child when the jets are taking off or landing?
The only time the jets are HOT taking off or landing Is when there Is a North
Wind I The loud noise and Intolerable decibel level and the fact that any
teenager or adult could throw a stone and hit a plane In flight Is truly a
social/psychological Impact to my family, and very frightening and deafening
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to
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WINTHROP WINTHROP CONCERNED CITIZENS
4.
Co children.
I do not consider the tear when I lee arced guards running down my
street end in BJT neighbor's backyards a "reasonable" fear. I become quite
unreasonable when the physical safety of ay family is threatened!
With all the current problems our nsxigffcorhoods suffer from the present
facilities; they ssy, the additional impacts from a huge new sewage facility
would not be significant I Isn't this just another way to say "Dump it on
Winthrop, they won't even know the difference)"
This study completely Ignores one of the most profound impacts of these
other facilities, and Chat Is the tendency of these regional facilities to
CROW, and their Impacts Co increese dramatically.
What can a community do Co seem the tide once a facility Is built on
Its doorstep? When chese regional facilities first appeared next to Winthrop,
environmental Impact studies were not required. And because no one consid-
ered the Impacts, Wlnthrop's municipal resources have been stretched to the
limit to deal with them. We have a whole new class of unpaid, full-time
citizen activists who have had Co dedicate every spare waking hour Co Che
cause of protecting the community. We must deal with facility crafflc,
sewage dumping, land-caking and blockbusting, deafening jet noise, prison
securlcy and overcrowding, and now this which we consider the most dangerous
of allI Where does 1C stop? Who exactly Is responsible for overseeing the
fairness of this decision?
Is It up to us to force government agencies and chelr consultants Co do
their jobs? Obviously, we feel that C. E. Maguire failed In Its responsibil-
ities co boch EPA and to Che public at large. Why has EPA allowed their con-
sultants Co be so selective in deciding which data co collect in regard to
WINTHROP WINTHROP CONCERNED CITIZENS
5.
the different opclona? For example, anyone can read in chls study chac
there are 270 homes that line the truck route chrough Hough's Neck and 22S
along the route through Squantum, but why aren't they told about the THOUSANDS
of homes that line the truck route through East Boston and Winthrop? Why is
thsc data missing? Could 1C be that the density of the population in these
two communlcles la not as important to mention as, say, the estimated number
of graveaites on Long Island?
And it's not just EPA and their consultants who have stacked the decks
here. Agencies that fall directly under Che Jurisdiction of Secretary Hoyte
have provided a lot of data for this study, but we question their choice in
some of the information they've left out. The Division of Environmental
Management has contributed a lot of their resesrch on the natural and cul-
tural resources of Long Island, but when it comes to Deer Island, they have
completely written it off In terms of reaourcea and developmental potential!
Why?
Among our elected officials and government agencies, who Is responsible
for seeing that the data is collected and then analyzed fairly and consistently?
For example, if under option 2B. 1 the Deer Island Treatment Plane is reduced
and replaced wlch a much smaller headworka, who is responsible for coming up
with the Use of possible developmental uses for chac valuable harbor prop-
erty? And If that data has not been made available, how can any comparison
be made between Che potential of the Deer Island site and Che pocencial of
the Long Island sice? This study states that Long Island has clear potential
for recreationlfuses but chac Deer Island has none.
Another example. We're told that a sewage facility on Long Island would
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WINTHROP WINTHROP CONCERNED CITIZENS
6.
Impact Che "sensitive" patient* At the Long Island Hospital. But there la
no similar comparison with the impacts on the captive, overcrowded, prison
population at the Deer laland House of Correction, and no conalderatlon at
all of the abutting honeowneral
We're told that there are "more aigniflcant opportunities for mitigation"
at the Deer laland alte. What doea that Bean17 There are so many impacts,
and they are ao severe that any alligation would have to be SIGNIFICANT!
The only possible mitigation for a sewerage treatment plant la in the
aiting deciaion itself. It should be sited as far away from residential
area*, in aa isolated a spot ss possible!
We did not choose these particular alte options. But given these options,
two harbor communities — Winthrop and Hough's Neck — are threatened with
devastating conaequences which will continue to Impact these communities for
years to come. Only the Long Island alte has no immediate neighbors, and is
In fact as far from Point Shirley aa it is from Squantum! If these are the
only options — the choice is clesrl
Secretary Hoyte, we understand that 1^* is now your responsibility to
review this document to decide if it la accurate and complete enough for
the new Water Resources Authority to use it in making their final decision.
The Wlnthrop Concerned Citizens' Committee Is telling you right now. In this
public forum; that this study is biased, Incomplete, Inadequate and has a
preconceived conclusion. The sites have not received equal attention and
there are huge gapa in the information given. The most Important factor
in siting this facility, the effects it would have on existing harbor com-
munities, has not been given priority and has not been fairly applied to
WINTHROP WINTHROP CONCERNED CITIZENS
7.
each alte. Scoping decIBloos chat hav* already been made have been
baaed oo Inaccurate data and faulty logic. And the so-called "mitigations'*
that have been proposed are Inadequate, expensive, unfeaalble, and not fairly
conaldered for all sites.
We do not know how anyone can decide thla issue based on this document.
We urge you to send EPA. back to the drawing boards and to get your own
staff moving to consider the non-sewsge potential of Deer Island, and the
needs of the Wlnthrop and East Boston communities!
Deer Island &ad Uinthrop will HOT be sacrificed to solve the region's
sewage problemsI
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For almost a year now the Concerned Citizens Committee has been
activelv mobilizing for this hearing. We've been told that this
is our one golden ooportunitv to resoond to EPA's olans ior
dumping as much of the region's sewage as oossible on Deer
Island. We had been hooing that this environmental impact
report would be fair and comprehensive. But this whole studv
orocess has resulted in a document that is biased, incomplete.
and totally inadequate in measuring impacts.
We thought that an EIS was supposed to consider all the
passible impacts that a sewage plant could have on its
neighbors, and then rate each of the alternative sites
according to the level of impacts so that a decision could be
fairlv reached. But how can anyone judge the possible impacts
when we don't even know which method of sludge disposal will be
used ? The only thing this studv tells us is that "None of the
sludge disposal options would alter the respective treatment
siting alternatives' relative impact and none of the sewane
treatment facility options would foreclose a aludoe manaaement
solution." How do vou define "relative imoact" ? A maior
incineration plant that burns PCB's and other toxic wastes and
constantly pollutes the air with its tall smol:estacl s does not
have the same impact on a communitv as a oumpina station with a
deep ocean outfall ! And a landfill operation reauires either
large amounts of land on site or it will imoact its neighbors
with the transport of sludqe. We' ve had some experience mth a
small composting operation on Deer Island -and VJQ know thdt it
stinks to high heaven ! But this studv ignores these and all
other impacts of sludge disposal.
This is just one example of the glaring lack of certain
information. There are many other areas, even within the
defined ecooe of this studv. where data is either missing
comoletelv. is inaccurate, or is analyzed according to
different criteria for different options. We don't know how the
Water Resources Authority, or anyone else for that matter, can
oossiblv make a fair and informed decision based on this studv!
It is claimed that this studv has assembled data according to
the following six criteria! harbor enhancement, effects on
neighbors, effects on natural and cultural resources, costs.
reliability and implementabi1itv. And we're told that these
criteria have not been prioritized or weighted in any way. But
each site has already been assessed for a nebulous duality
called "recreation ootential". And it's according to this
criterion that each of the options are comoared in your
Executive Summary. More imoortantlv. the scoping decisions that
have already been made, especially in regard to the all- Long
Island Primary option, were obviously made based on some of
these criteria. If no priorities have been set. how is it that
the onlv alternative to expansion of the primary treatment
Plant on Deer Island was eliminated, and without tne benefit of
oublic comment and review?
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Siting » aeMage treatment facility
endangers health, safety, and prooertv. and (as long as
chlorine must be transoorted) it threatens the LIVES of its
neighbors. A facility that is this dangerous must be sited as
far awav from residential areas as oossible !
There's something inherently Mrong with this study. It cites in
great detail all of the oossible "severe imoacts" to wildlife.
vegetation, gravesites. etc.. but it dismisses anv discussion
of impacts on neighboring communities as "nuisances" ! What is
a "nuisance"? Is a chlorine truck carrving a deadly cargo down
a narrow residential street a "nuisance" ? Would it be a
Nuisance if 19OOO oeople could not possibly evacuated in time
to orevent thousands of deaths in the event of a chlorine leak
possible mitigation in siting this facility rests in the siting
decision itself ! We completely reject the idea that a
combination of barging and bussing would solve all our orablems
! And we Question the integrity of anyone who offers these
solutions, without anv explanation of costs, feasibiltv. and
the extent of their use. and without anv mention of who has the
authority and the responsibility to implement these olans ! No
one in this hall can guarantee that the project proponent will
actually institute these plans, and no one can guarantee that
the funds and the necessary institutional approvals will be
granted. And what's at stake here is much more than a nuisance
- up to ten years with thousands of constuction trucks, heavv
equipment, and personnel travelling through Winthroo's narrow
streets each day '
The effects we're discussing here are the dangers of
transporting lethal substances through crowded neighborhoods.
The devaluation of people's homes. The dangers of prolonged
heavv trucking through narrow residential streets. The
pollution of the air by the incineration of F'CB's and other
to::ic substances. These are not nuisances - thev are life
threatening dangers !
We're told that anv problem that Winthroo would suffer under
anv of the Deer Island options could be " successful 1v
mitigated". As we've said, our oosition is that the onlv
We're told that the imoacts we alreadv suffer from Logan
Airport and the Deer Island Prison will be considered. But the
data in the studv about imoacts from aircraft. and problems
with the overcrowded prison and the freouent inmate escan^s. 13
false and inaccurate. And what's worse, the onlv argument where
this data is used is an attemot bv EPA to devalue the viabilitv
of our community. We have so manv problems with the present
facilities, they sav. the additional imnacta from a huge new
sewage facility would not be significant ! Isn't this ,ust
another wav to sav "Duroo it on Winthroo. thev won't even Know
the difference" ? Let me tell vou. we know the difference !
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Page 3
This study completely ignores one of the most profound imoacta
of these other facilities, and that is the tendency of these
regional faci1i ties to GROW. Their imoacts tend to increase
dramatically. Consider first the growth of Logan Airport and
the phenomenal increase in air traffic since that first smal 1
airstrio was buiIt. Consider the gross overcrowding of the Deer
Island Prison - 463 inmates packed into a facility with a total
capacity of ! Consider the present Deer Island Primary
Treatment Plant. Because of poor original design and eouioment
failures, it can't handle the sewage it's supposed to. so we
get raw sewage dumoed in the harbor, and now these expansion
plans.
What can a community do to stem the tide once a facility is
built on its doorstep ? When these regional facilities first
appeared next to Winthrop. environmental i moact studi es were
•
not reouired. No one considered the impacta. As a result.
Winthrop*s municipal resources have been stretched to the li.nit
to deal with them. We have a whole new class of unoaid.
full-time citizen activists who have had to dedicate everv
scare waking hour to the cause of protecting the communi tv. Me
must deal with traffic, sewage dumping, chlorine trucks.
1 and-taking. blockbusting, deafening jet noise, runwav
e:; pan si on. pr i son securi ty and overcrowding, and now this. And
we confii der thi s the most dangerous of all ' Where does i t
stop 7 Who exactly is responsible for overseeing the fairness
of this deci si on ?
Page 6
Is it UD to us to force government agencies and their
consultants to do their jobs ? Obviously, we feel that C. E.
Maguire failed in its resoonsibi Ities to both EPA and to the
oublic at large. Why has EPA allowed their consultants to be so
selective in deciding which data to col lect in regard to the
different ootions ? For example, anyone can read in this study
that there are *-* homes that line the truck route through
flf
Hough's Neck and -*-*• along the route through Squantum. but why
aren't thev told about the THOUSANDS of homes that line the
truck route through East Boston and Winthroo ? Why i s that data
missing ? Could it be that tha densi tv of the pooul at ion in
these two comunities is not as important to mention as. say.
the estimated number of gravesi tes on Long Isl and ?
And it's not just EPA and their consultants who have stacked
the decks here. State Agencies that fall directlv under the
jurisdiction of Secretary Hovte have provided a lot of data for
this studv. We Question their choices in some of the bits
thev* ve 1 eft out . The Di vi si on of Environmental Management has
contributed a lot of their research on the natural and cul tural
resources of Long I si and. but when it comes to Deer Isl and.
thev have comoletel v written it off in terms of resources and
develoomental ootential ! Why ? Because thev have never
bothered to research the island's rich history ? Because thev
cannot aooreci ate the soectacul ar view from the island ?
Because thev feel that the wildlife, trees, and unmarked graves
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Page 8
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on Deer Island are less imoortant than the ones on Long Island
? Whv not ?
Among our elected .officials and government agencies. Mho is
resoonsible for seeing that the data is collected and then
analyzed fairlv and consistently ? For example, if under
00tion 28.1 the Deer Island Treatment Plant is razed and
replaced with a much smaller headworks. Mho is resoonsible for
coming up Mith the list of oossible dsveloomental uses far that
valuable harbor oropertv ? And if that data has not been made
available, how can any comoarison be made between the ootential
of the Deer Island site and the ootential of the Long Island
site ? This study states that Long. Island has clear ootential
for recreation uses but that Deer Island has none.
Another example. We're told that a sewage facilitv on Long
Island Mould imoact the "sensitive" patients at the Lang Island
Hosaital. but there is no similar comparison with the impacts
on the caotive. overcroMded. prison population at the Deer
Island Prison, and no consideration at all of the abutting
homeowners t
We're told that there are "more significant ooportuni t i es for
mitigation " at the Deer Island site. What does that mean !?!
There are so manv impacts, and they are so severe, that anv
mitigation would have to be SIGNIFICANT •
Tha only possible mitigation for a sewage treatment olant is in
the siting decision itself. It should be sited as far aMav iron
residential areas, in as isolated a spat as-possible !
We did not choose these oarticular site options. We believe
that the quality of the harbor Mater Mill imorove with a new
facilitv. But the harbor itself Mill not be enhanced if this
huge new sewage treatment facilitv is built on anv of these
three harbor sites. Given these specific options, two harbor
communities. Winthrop and Hough's Neck, are threatened with
devastating consequences which Mill continue to imoact these
communies for years to come. Only the Long Island site has no
iounediate neighbors, and is in fact as far from Point Shirley
as it is from Sauantum ! If these are the only options, we
feel the choice is clear.
§»««-» *drr,i<,ypv*e. V>« understand that it is now vour
responsibility to review this document to decide if it is
accurate and complete enough for the new Water Resources
Authority to use it in making their final decision. We're
telling vou right now. in this public forum, that this studv 15
biased, incomplete, and inadequate. The sites have not received
equal attention and there are huge gaos in the information
given. The most imoortant factor in siting this facilitv. the
effects it would have on existing harbor communities, has not
been given priority and has not been fairlv applied to each
site. Scoping decisionsithat have alreadv been made have been
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based on inaccurate data and faultv logic. And the so-called
"mitigations" that have been orooosed are inadeauate.
exoensive. unfeasible, and not fair.v considered far all sites.
Ma do not how anyone can decide this issue based on this
document. We urge vou to send EPA back to the drawing boards
and to get your own staff moving to consider the non-sewage
Dotential of Deer Island, and needs of the Winthroo and East
Boston communities !
Deer Island and Winthroo will not be sacrificed to solve the
region*s sewage orobiems ! You cannot dumo it on Winthroo !
n
TERRY VAZQUEZ
PUBUC INSURANCE ADJUSTER
STATE UCENSEO
Wlnthrop. Mats. 02152 846'6309
Uarcb 15. 1985
Ulcbael R. Deland
Regional Administrator
Region 1
U.S. E.P.A.
J.F.K. Building
Boston. Ua. 02203
Re: Public Comment Period re
SDEIS for Siting of Waatewater Treatment
Facilities
Dear Regional Administrator Deland,
This letter la In response to tbe SDEIS recently Issued, with which
your office Is Involved. I urge you to consider very seriously, the val-
idity of tbls flawed report before you make or approve of any decision on
siting a new sewerage treatment facility. Your decision will affect the
health, safety, and economic progress of tbls region for decades - at
least.
The SDEIS Is seriously biased toward siting tbe plant on Deer Island.
I feel this is now apparent to you and hope that you will not base your
siting decision on such a biased, flawed document. Tbe SDEIS bias is obv-
ious in many areas and thus tbe results are skewed toward siting the plant
on Deer Island. Tbls is a site absolutely unacceptable to me and I feel that
choosing Deer Island would be a decision that you and tbe EPA would long
regret.
The SDEIS lists 6 criteria for the siting decision (I am not at all
sure tbls list is a complete one) noting "they are in no particular order
of Importance." I hope that one - "effects on neighbors" - Is really con-
sidered to be most important. Ur. Deland, you are taking about fear, safety,
loss of value of my home, hazards to my health, etc. when you consider
"effects on neighbors." They UUST outweigh any others. Your siting decision
must be based on "people concerns" and neighborhood Impacts, not just
harbor enhancement. We In Wlntbrop want harbor clean-up as much as anyone.
Ve know all too well bow much it is needed. But we will not allow it to be
done by sacrificing Winthrop.
I don't feel enough study has been given some on the impacts. Since the
were not studied in enough detail, tbe results -i.e. impacts - do not appear
to be as severe as they really are, and will be.
1) Traffic-there will be traffic problems yes, serious ones, congestion
safety problems for all Including our elderly and our children. But this
will not only be an Impact for tbe hundreds of homes in Point Shirley
as the report considers, It will also be a very real negative impact on the
thousands of homes in all of Winthrop and East Boston! The truck route
starts when the trucks, buses, cars, etc. get off tbe highway, tunnel,
bridge, etc. and start their trip through the narrow, congested streets
of East Boston ans on through Winthrop - past schools, business areas,
playgrounds, Little League Fields, Synagogues, our only lake, our
Public Landing and marina, beaches, etc.
2)0dor and air quality- Since only some of the types of emmlsslons
were studied and considered, only those results are noted. Many types of
Water
Smoke
Windstorm
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TERRY VAZQUEZ
PUBLIC INSURANCE ADJUSTER
STATE LICENSED
P> *"*•"* Avenue
Winthrop. Mau. 02152
846-6309
n
-2-
ealsslons were not Included, such as numerous carcinogens and toxic pol-
lutants. If these potentially deadly effects on air quality were Included,
the Impact on people and the environment would seem far greater. Don't let
suffer for the SDEIS's failures or oversights. Down the road it'll be too
late.
3)Effects on Real Estate Values - No study whatsoever was done
to show how serious this Impact will be on homeowners-voters, taxpayers
and human beings. I bought a home in Wlnthrop on the day of your EPA
hearing in Wlnthrop, February 28th. I have every intention of seeing it
be a good Investment. I have faith in your system and know that Winthrop
won't be sacrificed.
Another flaw In the SDEIS which I want to point out, is
SEQUENTATION. This is a fatal flaw. By not studying sludge disposal within
the SDEIS, it falls to give you a complete, realistic picture of the
impacts of your siting decision. Sludge management is a large part of the
overall sewerage treatment picture. It is inconceivable to me that any
study could purport to be an overall one-
leading directly to a siting decision - and still omit sludge disposal
from its scope. This is ABSURD! I
Please realize that all the mitigation measures SUGGESTED in the
SDEIS and on which its findings are based, are only suggestions - not
guarantees. These mitigation measures should not be considered as a part
of your decision, since we have no guarantees they will be Implemented
or even feasible years down the road when work begins. The SDEIS is ser-
iously flawed by its reliance on these mitigation measures as a basis
for its conclusions.
Finally, I must note the Issue of FAIRNESS -
It Is not FAIR to site a regional sewerage treatment facility in
Wlnthrojts backyard-, on Deer Island. As you know, we have a prison,
the present sewerage facility, and the airport. A tiny, densely populated,
close knit community like Wlnthrop cannot and should not be asked to
be the location for all the region's unwanted facilities. We know from
our experience with Logan Airport, that these regional facilities tend to
grow as the area grows and the needs for their services increases. This
growth can and has eaten up neighbors and neighborhoods. Mr. Deland -
be fair to us - we deserve it. We have born the burden too long and
too heavily already!
The SDEIS options give you only one choice - site the facility all on
LONG ISLAND. A plant there would have the least disruptive, negative,
devastating impact on any community. I feel that should be your major
goal -i.e. to impact anyone as minimally as possible by the siting of
TERRY VAZQUEZ
PUBLIC INSURANCE ADJUSTER
STATE LICENSED
Avenue
Wlnthrop. Mau. 02152
846*6309
-3-
thls regional sewerage treatment plant.
Since I feel that the SDEIS is fatally flawed - legally, technically
and inherently - I see no reason to suggest you should be limited to the
7 options available In It. Satellite plants and other Innovative options
exist - albeit not studied sufficiently, but they do exist.Please don't
ignore these creative possibilities, which would be FAIR and minimally
disruptive to everyone.
We ask you to show innovative and creative leadership In this issue
and trust that by doing that, you will not sacrifice WINTHFtOP for the
areas waste and for some proposed biking trails on a relatively
Inaccessible Island, which even if developed might be visited and enjoyed
by a minimal percentage of the population Involved, once or twice in
their lives.
I am unalterably opposed to any expansion of the Deer Island Sewerage
Treatment Plant, and will continue working toward that goal.
Yours truly,
Terry Vazquez
Member, Wlnthrop Concerned
Citizens Steering Committee
Fire
Water
Smoke
Burglary
Windstorm
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Water
Smoke
Burglary
Windstorm
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WINTHROP CONCERNED CITIZENS
42 Franklin Street 12
Wintbrop, MA 02152
March 13, 198S
Mr. Michael Deland
U.S. E.P.A.
22nd Floor
J.F. Kennedy Building
Boston, MA 02203
Dear Mr. Delandi
'«te
"if
I am writting to you as pact of the public comment section
on the Supplemental Draft Environmental Impact Statement/Report
on the Siting of Waetewater Treatment Facilities in Boston
Barbor.
Reflecting on the convocations you have bad in your office
with members of the Hinthrop Concerned Citizens Committee,
including Anne Porter, Katby Lane, Arthur Cummings and myself
and on all the speakers you heard at the public hearing in
Nintbrop on February 28, 1985, I ao sure you are aware of our
concerns with the biases in the process and in the SDEIS/R.
One of the concerns of the HCCC is the apparent lack of
study on the feasibility of using Deer Island for recreational
purposes, when much time, effort and money has gone into the
study of the recreational possibilities of Long Island.
One of the seven options being considered in the SDEIS/R
calls for the construction of a five acre head works facility
on Deer Island and the removal of the present sewage treatment
plant from the 'island*. He feel a substantive, detailed study
of the recreational potentials of Deer Island would allow for a
more judicious analysis of this option. For you, Secretary
Boyte, Governor Dukakis and the new Massachusetts Water
Resourses Authority to reach a decision on siting a treatment
plant with what is clearly an incomplete study is not fair to
you and certainly not fair to the residents of the affected
communities.
Will a substantive, detailed study of the recreational
potentials of Deer Island be conducted and published before the
final Environmental Impact Statement is issued?
Will you considered the recreational potentials of Deer
Island in the decision process?
Hintbrop Concerned Citizens Committe
Public Comment Period SDEIS/R
March 13, 1985
Page 2
Hill you consider the need for open recreational space for
the people of Ninthrop, East Boston, Chelsea, Revere, Everett
and the entire northern metropolitan area in your final
decision?
Knowing bow fair and open you have been with tbe people of
our community, I feel certain you vill deal with and answer
these questions in an open and fair manner.
Sincerely,
-
tf
Gary/Skomro
Secretary, WCCC
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WINTHROP
RESIDENTS
COMMENTS
2-145
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en
February 28, 198S
118 Grandview Avenue
Winthrop, MA 02152
Mr. Michael Deland
Administrator
Environmental Protection Agency
Boston, MA
Sir:
This letter is to protest vehemently the alleged EIS draft that
pointedly appears to leave Deer Island as the only feasible site for
a singular sewage treatment plant in Metropolitan Boston.
The Maguire study is so biased that no professional group would
accept it as even a student classroom project. From its costs to its
lack of treatment of social impacts, the Maguire firm's document serves
only one purpose - to serve as justification for the use of Deer Island
as the plant site. The document, in short, is an outright fraud per-
petrated on and paid for by taxpayers.
Maguire1s representative told a Winthrop group on Feb. 10 that
no properties will be severely diminished in value, or maybe they
would be on a "case by case" basis. Yet the document itself says that
if secondary treatment is to be pursued, some Winthrop properties may
be severely impacted and may not fully rebound, ever. The Maguire rep
talked of the property tax question as if it were a matter of months,
instead of a matter of a decade or better that this threat will overhand
the town of Winthrop. From this question ripples the issue of tax base
and the impacts on quality of life and social interaction, a question
Maguire saw fit, apparently on purpose, not to address.
Your office is pressing the matter of getting a site selection and
design process started in the federal courts because you fear delays.
This urge to run ahead with a concept that lacks specific details such
as the question of sludge treatment indicates your wishes are prompted
more by a wish to wage regulatory power than concern for the best way
to solve the problem of cleaning up Boston Harbor. I for one would re-
commend naming the plant the Michael Deland-Raymond Flynn Crap Processing
Facility.
Other people at a public hearing scheduled for Feb. 28 in Winthrop
are sure to address details of the faults to be found with the planning
process you insist on pursuing. In general, those are: no projection
of costs (1981 dollars are used with no inflation factors), no explana
tion of why it will take 120 acres for a secondary plant on Deer Island
and only 96 acres on Long Island, poorly researched factual matter such
as the true measure of vehicular traffic on either Winthrop or Quincy
roads with local conditions factored in and the estimate of a 1:1
patient-employee ratio at Long Island Hospital, failure to address
the sludge issue, assumption that one community can be expected to
withstand the impacts of a decade of major construction within its
geographical, if not legal, boundaries, and no addressing of where
money is going to come from to pay for the Deland facility.
Maguire's overemphasis on institutional barriers to using Long
Island is a lot of balderdash. The state of Massachusetts forced the
city of Boston to turn over to it Spectacle Island, and could do the
same wr'th Long Island. The EPA could, if it wished, threaten to withhold
Page 2
Deland
2/28/85
funding (if any is available from the Federal Treasury) if the city
of Boston and the State insist on using a site besides Long Island
for major portions of a new sewage treatment facility. Your willingness
to accept Maguire'8 recommendations, which certainly was indicated by
EPA and state representatives at the Feb. 10 meeting, is a matter of
caving in before mythological issues.
You and your representatives will do your best to cast Winthrop
into the role of an offender if the town files suit to stop imple-
mentation of your already made plans at Deer Island. That, sir, will
be an outright case of fraud. Ycv bring the threat of court-ordered
delays on yourselves by refusing to base your decisions on adequately
researched information.
Finally, there is the matter of James Hoyt's participation in this
whole project. Though Mr. Hoyt refuses to acknowledge that his mind
is made up on the matter of a site selection, his position as chief <
environmental officer in the Commonwealth and role as chairman of the
selection committee constitute a basic conflict of interest. That he
resides in Quincy, the community with which the EPA and state environ-
mental agencies at odds over an unwanted monstrosity, only adds to
the skepticism that his position engenders.
All the bureaucrats .have thrown up their hands on the key issue
in this matter - the question of fairness. Winthrop has done more
than its part for the general good of the Metropolitan Boston region;
it's about time its residents were given credit for this and that
the EPA look beyond the ease of bottom line decision-making to a
more difficult question: whether or not a legal and moral obligation
is owed to the town of Winthrop.
So do as Boston Harbor Associates recommends: fix up the existing
sewage treatment plants and prove to a very skeptical public that this
new state agency can run a sewage treatment plant, or contract the
operation out to the private sector if that is the better way. But
don't embark on a program of spending hundreds of millions of dollars
until you find out whether your are going to saddle Metropolitan
Boston with another outmoded, ill conceived sewage system as was done
in the 1950s.
Sincerely,
om McNiff, 'Jr.
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Michael Deland
Regional Admlnietrator
EPA
Dear Mr. Del«nd:
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I am extremely concerned about plans to expand the sewage
treatment plant on Deer Island. To consider this expansion
In an area of dense population, is not in the best interest
of the inhsbltsnts.
Shirley Street can not handle the Increased traffic neither
during the conatructlon phrase nor to support the on-going
operation of the plant. I firuly believe construction on
Deer tslsnd will dramatically and permanently change the
character of the town; yielding a negative Impact on the
quality of life.
A better solution would be to address construction on Long
Island. This is the only cite that would not have significant
impact on the human population.
Host Sincerely,
122 Grandvlew Ave.
Ulnthrop. HA 02152
ALV/dma
Mr. Christopher M. Stevens. C.P.A.
One Sesl Harbor Road. 1802
Ulnthrop, Massachusetts 021S2
February 28. 1985
ENVIRONMENTAL PROTECTION AGENCY
Re: Expansion of the Deer Island Treatment Plant
To Whoa It Hay Concern:
I aa responding to the visual impact study surrounding the expansion of the
Deer Island Treatment Plant. Contrary to the EPA's position, there are
other residents who have s direct view of the plant.
I recently moved to the Seal Harbor Condominiums located on the water In
Wlnthrop. I moved here because of ay love for the ocesn and the magnificent
view the area had to offer. Because of the location of the Condominium
coaplex, we hsve a direct view of the shoreline of Vlnthrop. the skyline
of Boston, the islsnds of Boston Harbor, endless ocean beauty, and finally.
the atrocity off the Deer Island Treatment Plant. When guests visit my home
the conversstlon usually swings to the view of the plant.
Wlnthrop is a wonderful community! It is attractive because of Its reputation
of being one of the twelve eafeat*towns in the United States and because of
Its close proximity to Boston. Ulnthrop. like other areas has experienced
incresses in resl estste valuea. At Seal Harbor there are approximately
130 Condominiums, many of which range from $150.000 to $200,000. Phase I
end II Is completely sold out and phase III and IV la expected to begin in
tha Fall.
People like myself have Invested a greet deal of money In this town and will
not tolerate anything that would jeopardize our positions.
I urge the Environmental Protection Agency to seek an alternative site where
less people will be affected. The Deer Island Treatment Plant has been
sn Albstrose, affecting every resident. It is time for Winthrop to reach
its full potential!!
Respectfully yours,
Christopher N. Stevens
A Concerned Citizen
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Toi Michael Deland, Regional Administrator. U.S. EPA
Promt Ralph Tufo, 62 Crystal Cove Ava. , Winthrop, Ma. 02152
Subject! Testimony Concerning Sewage Treatment Plant Expansion
Date• 2/28/85
As a teacher at the Winthrop Middle School and as a parent of a two
year old boy, I am concerned with your proposals and how they will
affect the children of our town.
Our primary concern is the safety of our children. If you proceed with
your plans to expand the Deer Island plant and the amount of waste
it treats, you also will increase the number of deliveries of deadly
chlorine gas along our narrow and busy streets. In effect, you will
be Increasing the numerical possibility of a tragic mishap that would
endanger the lives of thousands of people. Can you actually guarantee' tha/
any of the following would not occur i an accident involving a chlorine
truck, a malfunction at the plant causing a leak, or some other
unanticipated dilemma for which you might not have any preconceived
safety plan. Recent reports In the news have cited that trucks carrying
dangerous and inflammable materials are not meeting safety standards
and the issue Is being investigated by the Department of Public Safety.now
Furthermore, it does not make safe sense to me to deliver and store
a lethal gas in an area directly adjacent to a prison. You must be
aware that prisoners frequently escape from the Deer Island House of
Correction. It seems that having two dangerous elements together in
one area make for an extremely hazardous situation. Furthermore, if
a chlorine leak were to occur at Deer Island or in route to Deer Island,
it would impossible to evacuate 20,000 residents via the only two
exit roads leading out of Winthrop. Accidents do happen, and I would
like your agency to do every thing possible to insure that one does not
happen here. {
The safety of our children will also be at stake when the construction
trucks and the workers' cars start arriving. The major road leading
to Deer Island is only one block away from our school and two blocks
away from an elementary school, '"his invasion of
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RECEIVE-FPA
Mr. Michael R. Deland fyU.J ... 5035
Regional Administrator
Environmental Protection Agency WiTE2fuuiuv n^Auru
J.F.K. Federal Building. Boston Ma. 02203 Date February 2B,K)9OTUIT HKANCH
John 0. Roger*
7 Siren St.
Wlnthrop Ma. 02152
Dear Sir.
I am writing to you In regard to the "Supplemental Draft Environmental
Impact Statement en "Siting of Wastewater Treatment Facilities In Boston
Harbor* which was released 12-31-64. On page 13 public comment is sought
on the adequacy and accuracy of all the material contained in this SOEIS/EIH
Including the decision making process. My occupation for the last 18 years has
been that of a licensed power plant engineer In the commonwealth. I therefore
respectfully submit the following comments based on my study of this and other
previously released documents on this most Important subject.
1.) • While extensive mitigation will be required ( $45 million ) and the long
term effects on neighbors of plant operation will be less severe than the current
Deer Island Facility, there remains concern about locating a major regional
facility adjacent to a community that I* now subject to the effects of the Deer
Island House of Correction and major flight paths to Logan Airport". 'This issue.
often described as one of ftimes*, it iff///cult to quantify, but must be considered
nonetheless.'(page 4). The President Of The United States uses the word
fairness often as a major measure to tax reform so that the burden of necessary
taxes are more evenly distributed to prevent overburdening any one segment of
wage earners. So to should proper emphasis be assigned to the "tairness'tA
burden that any abutting community must endure from Airplane noise, an over
crowded insecure prison, and an outdated, overloaded, noisey and toxic sewerage
treatment plant. Any major expansion of the existing treatment facility would
have a significantly unfavorable impact on a community that is already
Overburdened with existing adverse environmental effects.
2.) The suggestion that the impact of the of expansion of the present facility
would be "less sevtrf'Vmt\ the present operation of the existing Deer Island
sewerage plant. Is In this writers mind an unfair, biased, and Irrelevant
statement, since the general consensus of most public officials and the private
sector has deemed the present condition and mode of operation as; outdated,
overloaded and mismanaged at best.
A facility that is specificially designed to handle the treatment requirements
of 42 communities is best located on an uninhabited harbor island which has no
further unfavorable impact on two communities that are already unfavorably
impacted.
The proposal to site a secondary treatment plant (Proposal 2B-1 All
Secondary Long Island) would not only minimizeVt* adverse impacts of the
facility on both Nut Island and Deer Island neighboring communities, but would
significantly reduce present adverse conditions at both locations. What better
use for an abandon Nike Missile Site which occupies 90 of the 96 required acres
on Long Island. Compared to the other proposals this plan Is mldrange as far as
construction and operating costs.
I believe that the key to the revltallzitlon and proper use of the harbor lies
with the the Improvement of *// beech and other recreational facilities located
within the harbor. In Winthrop alone there are four major yacht clubs and
several docking areas that provide vital Income and employment for the
residents of this community. Many residents of bordering communities make use
of the local beaches of Revere. Lynn. Winthrop and South Boston which are
adversely affected by the present operation of the Deer Island Plant.
Accuracy
I seriously question the accuracy of the estimated traffic count of 20 trucks
and buses each day. Where did these figures come from? Certainly the EPA must
have had similar experience somewhere In the country that historical data on
traffic could be derived.
Adequacy
This report states that one of the required mitigation alternatives would be to
•fill In three acres of Hingham Bay.* The Report does not address the possibility
of reopening The Shirley Gut. Reopening the Shirley Gut would again serve as a
buffer zone and deterrent to prisoner escape, would Increase tidal flow to the
Inner harbor, and enhance recreational boating.
My feeling Is that the EPA was created to protect the well being of all of us.
The EPA should not be swayed by the special interest groups that assign more
Importance on preserving an uninhabited Island for possible future recreational use
as opposed to the Immediate needs of two communities that presently have a
severe negative environmental Impact.
As far as national history Is concerned. John Hancock himself built his
summer home which still stands here on Point Shirley, overlooking the prison,
the waste treatment plant and Logan airport.
Very truly yours,
-John D. Rogers
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Wlnthrop'a future la severely threatened with the proposed expansion
of the Deer Island Sewerage Treatment Plant Facility.
The thought of up to a 10 year construction period of trucks and
workers traveling the only route to and fro« thle facility! bring-
ing with thesj additional chlorine deliveries le unthinkable.
All of the above coupled with the si sable population of this
coaaunity should be reason enough not to alte Deer Island for
any expansion.
Long Island does not have any of the above reasons as it's
excuse. The only one I've heard of is it's recreational
potential. What about the recreational potential of Deer Island?.
With the good weather upon us what does Uinthrop have to look
forward tot. Polluted beaches, noxious odors, contaminated
waters and closed windows. Any expansion to the sewerage plant
will aake all of the above worse).
Can we live with that?. I say not.
Thank you.
photograph on the front cover shows an aerial
view of Boston Harbor and the islands on which
the siting studies concentrated. Logan Airport
can be seen to the left of center. Downtown Boston -> s- /) /}
la in the lower center. Ulnthrop Is In the upper ^^ f £&>*£'
left, and Quincy Is to the upper right. Cape Cod
is visible along the horizon.
Photos on the back cover show Deer Island, Long
Island, and Nut Island which are the alternative
sites being considered for new wastewater treat-
ment facilities.
mfi O9I55.
Inside the back cover is a aap of Boston Harbor
and vicinity showing place names used In the
SDEIS/EIK.
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RESIDENTIAL
COMMERCIAL
INDUSTRIAL
SERVICES
APPRAISALS
MORTGAGE FINANCING
PROPERTY MANAGIMCNT
RUSSELL F. HUGHES. P.E.
REAL ESTATE CONSULTANT AND APPRAISER
•O wooosiot AVENUE
WIMTHROP. MASSACHUSETTS 02192
TELEPHONE ...«.,.
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WINTHROP (UN-nANSCHIPT. WIONIIDAV, MARCH 6. IMS
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• LETTERS TO THE EDITOR •
Long Island the only site for incineration
Dear Edtterj lection Agency (EPA) and IDEQEI over Ins slung of a
Last Thursday's fonnsl |b. Commonweallh-a preliminary and or secon-
pubbc hearing held by Ins DepsrtmentonEnvlronmen- dsry treslmem plant for
Federal Environmental Pro U| Quality Engineering sewsge waste emitting (ram
' U dike and towns opesled
' by Ins Metropolitan Dbtrkt
Oimmlsilon (HOC) gave
some evidence thsl our peo-
ple do not fuDy understand
the difference between
prlmsry and secondary
treatment of sewsge.
I would like to clarity It f or
them. AH human bclnga
have two orgsns for dUchar-
Ing Ibetr waste. One wasU b
liquid. Ins other b seml-
solld. Twa distinctly oil-
fcrcat procauea an used la
sin tbe lerms «Uhto them.
Tbe waste Uquld b treated
by addtof chJcrma to U. Tbr
seml-eolid wsele cslled
fudge cootaus caocer caua-
log fenns known as car-
terms can only be killed by
Inceoerallon,
Both treatments, prlmsry
for liquid., and secondary
for send-solid wssle. an sh-
aolullely necosssry to
preserve our health and well
betn|. RespUory dlsessea
sra common n Udl town snd
•rowing Increasingly
danferous.
We all know what cancer
can do to us. Our an- Is
pointed by Ihe aeroplsns
emissions, cur shores ere
poDuled by Ihe shidgs that
baa been emptied Into the
harbor for years and yesrs
about BO In number. Tns
Clean Water Act ssys secon-
dary Ireatmnt by Incinera-
tion b> necesssry for nsrbors
Hie Boston and Ihe other
dlles snd towns on the North
EPA ordered the ckanup
of Boston Hsrbor In HO. Tbs
Oty of Boston b trying end
appeal te doing nerylnlng
possible to dodge secondary
treatment. Tbers b only ona
engineering alls In the
wBds harbor last couid laaa
the fl»e slacks of In-
dneraUn needed la restora
Tbsl sits b Long Island.
midway between Deer and
Nut Islsnds. east of Moon
Island Ihst has been dump-
ing raw sewerage directly
Into the harbor for years.
Respectfully
BusseDr. Hughes
P.E.
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la the laaue of a recreational potential more iaportant than
the quality of life here In WlnthropT. I think not!.
Currently thla town haa more than It'a ahare of inconveniences,
the airplanes, the prison and the atench form Deer Island, to
aention a feu.
Our futurea and those of our children are the reasons we're here toniz
There Is no question where the optinun aite for any expanded sewerage
facility is - Long Island not Deer Island.
We cannot allow 960 or aore construction vehicles to ruin our streets,
endanger the lives and safety of our children and rock our houses
fron their foundations.
run the risk of more chlorine deliveries through this
So in closing I say - Wlnthrop cannot and will not make any compromise
where the expanded sewerage treatment plant is concerned.
Thank you.
Winthrop was recently sited for being on* of the safest communities
la the country by Family Circle Magazine. One of the main attractions
sited were It's beaches. The water polluted with Billions of gallons
of raw sewerage, the beach littered with tampon applicators, and
other material. Hot such a pretty picture.
And now what lies ahead?. Proposed expansion of a facility that
does not function properly or worse an expanded facility to handle
all of the M.D.C.'s sewerage.
Currently the spring and summer quality of life ie bearable in
this town but bow long will It be If there Is to be more sewerage,
more traffic, and more odor from Ulntbrop's worst neighbor).
Ve arm lead to believe that cement, bulling materials, and construction
worker* will be barged and bussed during this proposed 10 year construe
period, at great expense to the H.D.C. They are supposedly willing
to make this sacrifice. But what about the sacrifice that Wlnthrop1 a
Residents will be forced to maket. Staying behind closed windows and
doors in good weather* Not using It's beaches. If the fish are not
safe, what about the people!.
Thnak you.
Hr. and Mrs. Robert Wynne
209 River Road
Wlnthrop, MA 02152
Mr. and Mrs. Join Stasio
45 Tafts Ave.
Winthrop. MA 02152
/
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QUINCY
OFFICIALS/BOARDS/DEPARTMENTS
COMMENTS
2-170
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Sum MO
Boston MA 02109
I617I22MI42 '
McGrath. Sylva & Associated-Ins.
: "-•• i • >". •—'
SEWAGE TREATMENT for BOSTON HARBOR
Summary and Statement of Position of Qulncy
far presentation at public hearings on the Supplemental Draft
EIS on Siting of Wastewater Treatment Facilities In Boston Harbor
March II, 1985
A set of major decisions must soon be addressed by the new Metropolitan
Water Resource Authority, relating to clean-up of Boston Harbor. Several
> - •
agencies and many Interests are Involved or affected, and the decisions are
• •
closely Interrelated and should, but are not. be Integrated. They Include:
K>
Honorable James S. Hoyte, Secretary
Executive Office of Environmental Affairs
100 Cambridge Street
Boston, Massachusetts 02202
Attention: Mr. Sam Mygatt, Director
MEPA Unit
RE: SDEIR - Boston Harbor
Dear Mr. Mygatt:
Please find enclosed the comments of the City of Qulncy, MA concern-
Ing the Draft Supplementary Environmental Impact Report on Siting of
Wastewater Treatment Facilities for Boston Harbor. The City's additional
comments to EPA on the SDEIR will be provided you as are appendix to
these comments.
For the City of Qulncy,
Respectfully Submitted,
"CS^f^3**^
David Standley, Consul
:4L
lUnt
DS/pad
Enclosures (2)
cc: Commissioner Ceary
Commissioner Anderson
Peter Koff, Esquire
The level of treatment required (primary or secondary (the '301(h) decision
by EPA)). This affect* the size. cost, and feasibility of siting a treatment
plant; the quantity and nature of sludge produced; the cost of operation;
energy consumption; and the duration of Impacts of construction.
The system or systems for. and the Ideations of. sludge treatment, utlll-
latlon, or disposal facilities. The options are composting. Incineration,
and deep-ocean dispersal. AnMWRA decision, affected by EPA and State
permitting actions.
Composting, selected by the State as the most desirable option for primary
sludge, may not be feasible for secondary sludge. Considerable land is
required for treatment, and assurance of utilization Is a problem.
Incineration, the most costly, requires tall stacks, air pollution control
equipment, and land at the treatment plant.
EPA permits for deep-ocean dispersal would require satisfaction of a number
of very restrictive Federal criteria.
•What priority to give to clean-up of near-shore sewage discharges (Combined
Sewer overflow!, system bypasses, sewer overflows), and to Improvements
In the sewage collection system.
•Whether to consolidate all treatment -facilities at one site, or utilize different
locations for parts of the process or portions of the flow. An MWRA decision,
affected by costs, feasibility of siting, reliability, management factors; and
substantially impacted by the level-of-treatirent and sludge management
decisions.
•Where to locate treatment and sludge management facilities. Which Harbor
Island or Islands to utilize for the treatment plant (iK .Should sludge be
treated at a location remote from the treatment plant(s). AnMWRA
decision, affected by the environmental review process. EPA/DEQE funding
decision, the actions of landowners (Federal Government, City qf Boston),
relative costs.
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tPA tut proposed 7 alternative: iltlng decisions; 3 for primary*treatment,
4 for secondary treatment. Three would site new facilities on Long Island, with
the larger plant occupying the southern 2/3 of the Island; two would expand the
Nut Island plant. Construction costs would range from $600 million to $800
million, with the 'all Deer Island' alternatives the least costly. Operating costs
for primary treatment are estimated at $20-$2S million per year; for secondary
treatment $45-$50 million. The construction period for primary facilities would
be 4-5 years; for secondary. 8-9 years.
These proposed siting alternatives, depending on EPA's decision about which
level of treatment to require, are listed below. The acreage requirements are
shown In parentheses.
Primary Treatment
•Consolidation of all treatment
facilities at Deer Island (60)
•Expanding the existing treatreent
plants at Deer (SO) and Nut(20)
Islands.
•Relocating and expanding the Nut
Island plant to Long lsland(20);
retaining and expanding the
Deer Island plant (SO).
Secondary Treatment
•Consolidation of all treatment
facilities at Deer Island (100+)
"Expand the primary plant at Nut
lsland(20); construct all secondary
facilities at Deer lsland(100+).
•Relocate all facilities to Long Island (80);
except for existing primary treatment
at Deer Island (SO).
•Relocate all treatment facilities to Long
Island (100).
Comparison of Secondary vs. Primary Treatment
Doubling of -acreage for treatment (exclusive of sludge)
- amount of sludge produced
-cost of operation
Tripling of energy requirements
Less reliable operation
More staff
Greater construction Impacts • ••
Water quality In Boston Harbor potentially worse than with primary
treatment and an extended outfall.
Positions of th« City of Qulncy
On Secondary Treatment
Unnecessary from water quality standpoint
Excessively costly to operate
Requires too much space, and too much energy
Seriously complicates the siting process • .
Generates, needlessly, much greater quantities of sludge
Uses resources which must be dedicated to higher priorities
On facility siting
t Facilities should be consolidated
Nut Island Is
too small
too close to residential areas
to be considered as a treatment plant site.
Long Island Is
too valuable as open space and • recreation center
too difficult to utilize
(Hospital relocation, cultural/historic remains, environmental
Impacts, cemetery, legislative .approval, Boston ownership)
too costly
to be considered as a treatment plant site.
On the EIS/EIR
• Ignores Impacts of sludge management decision on facility siting
questions
Ignores the effect of •level-af-treatment" decision on Impacts of
sludge generation and management
Tries to compare dissimilar facilities
Is seriously Inadequate In treatment of mitigation measures - their
costs, benefits, and Implementablllty for different alternatives
Fails to properly present the long-range cost Implications to
residents
Has a host of other Inaccuracies, Inadequacies, and Inconsistencies
detajled In a more extensive Qulncy statement.
On the 'decision process'
Seriously confuses and clouds the relationship between decisions on
degree of treatment, sludge management, and siting. •
Does not make clear the role of each 'party' In the several decisions.
Paul Anderson. Commissioner
Qulncy Department of Public Works
February 20, 1985
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. .Enclosure 2
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SEWAGE TREATMENT FOR BOSTON HARBOR
Comments and statements on behalf of the City of Qulncy, concerning the
Supplemental Draft EIR/EIS on Siting of Wastewater Treatment Facilities In Boston
Harbor and related matters.
Submitted to the Secretary of Environmental Affairs pursuant to the Massa-
chusetts Environmental Policy Act.
I. Introduction
This detailed statement Is prepared and submitted by McCrath, Sylva and
Associates. Inc., David Standley. PE. principal Investigator, as a supplement
to the February 20. 198S statement of Paul N. Anderson. Commissioner. Qulncy
Department of Public Works, to which It Is attached.'
II. Overview " .
A. An Integrated Approach Is an Essential Element of Rational.Decision-making.
This SDEIR/S Is but an element of the decision process and actions which
are requisite to attaining and maintaining acceptable water quality In and around
Boston Harbor, and In conforming to the Import of Federal and State laws and
regulations. In turn, attaining and maintaining water quality standards Is but
one element In the process of proper utilization and enjoyment of the resources
of Boston Harbor; which In turn Is an element In determining the quality of
life of the population of the region. In the narrowest sense, the decisions on
level of sewage treatment, management of sludge, location of sewage treatment
Including sludge management facilities, and location of discharges, are intertwined
and must logically be made with the objective of minimizing costs and other adverse
Impacts for attainment of water quality objectives. For example, the Imputed
narrowness of the basis for an EPA decision concerning level-of-treatment is
Illogical In the extreme since It falls to take into account the comparative environ-
mental benefits and Impacts of the two categories of options In the particular
case of Boston Harbor; the impact of expenditures required thereby upon accom-
plishment of higher-priority, greater-benefit actions such as reduction of extra-
neous flows In the sewer system and correction of dry-weather and combined-
sewer overflows to inland and near-shore estaurine waters; Its effect upon the
feasibility and Implementablllty of siting alternatives; and'(toot the least) the
Impact upon sludge production and management which In turn affects the environ-
mental consequences of sludge management options, limits those options further,
and affects the environmental impact of sewage treatment facilities. This EPA.
decision, pursuant to s.301(h) of the Clean Water Act, also has potential major
consequences' for the recreational uses of Boston Harbor, the aesthetics of the
treatment plant site or sites, and for the feasibility and cost of successfully
mitigating impacts of the construction and operation of resultant facilities.
B. The EIR/S Must Reflect Current Events and Situations
In late 1984. the Mass. Legislature created the Metropolitan Water Resources
Authority (the MWRA). That entity effectively replaces the MDC Insofar as
water supply and sewerage functions are concerned, establishes a new body for
end method of decision-making, materially alters the process for and sources of
funding of metropolitan water supply and sewage disposal activities, and renders
a nullity the so-called "MDC preferred option* Insofar as that °9ptlon" purports
to reflect the view of the decision-making body with responsibility In these
matters. It Is Important to recognize that the MDC. not the MWRA acting by and
through Its Board of Directors, has submitted this SDEIR/S to EOEA and EPA.
The1 commitment of the Federal government to the major.' role In funding
wastewater treatment facilities In this country has been the principal support and
encouragement for the Improvements of the past decade (including such improve-
ments as have been made In that period by the MDC). That commitment has
changed, significantly In very recent years In at least three Important ways -
reduction In Federal share of project costs, restrictions to eligibility for Federal
assistance, and reduction In the total Federal funds available. Well within the
time horizon for the actions contemplated by this SD^IR/S. the current Adminis-
tration has proposed further major reductions. In fact a phasing out, of Federal
funds. Certain provisions of the MWRA Act reflect In part these facts. While
they will not affect whether facilities should be Improved, these actions will
certainly Impact MWRA costs, and therefore have consumer Impacts." This needs
to be discussed more fully and realistically In the EIR/S. as It could affect the
decisions of the MWRA In several ways.
III. Malor Comments Concerning the Decision Processes
A. The decision to be made based on the EIR/S ere limited.
EPA and MDEQE, as a result of this process, will be enabled to Issue permits
for and participate in the funding of an MWRA decision which Is not inconsistent
with the findings and recommendations developed In and from the Final EIR/S.
It does not appear, from the documents, that an 'environmentally-preferred
option" could be so conclusively superior to some other possibilities as to rule
out both a different choice by MWRA and Its acceptance by Federal and State
regulatory and funding agencies.
B. The ranking and weighting of criteria will remain a subjective process.
The six criteria selected for the SDEIR/S need reexamination. The first .
three could arguably by subsumed into a single criterion labelled "environmen-
tal quality", which would also be affected by "reliability". If this is recognized,
attempts to numerically "weight" and "score" against the criteria are avoided, and
the limited definitions provided In Ch. 2 are kept In mind. • The criteria are
useful. However, no standards of general applicability exist, and the relative
Importance of various factors Is a wholly subjective and highly individualized
judgement. It would appear that such decisions or findings as are contemplated
by MEPA and NEPA must be reached either by an individual or as the consensus
of a group.
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C. The presentation «nd treitment of alternatives It not consistent.
There are several examples of Inconsistent presentations and treatments of
alternatives, such that attempts at comparisons are of unlike things. For
examples, we cite the following:
•Somewhat different treatment processes and trains are presented for
secondary treatment at Deer Island and at Long Island, such as to mini-
mize the apparent acreage requirements of the Long Island options by
comparison.
•In "Pptions 2b1 and 2b3*. sludge processing capability Js not represented
graphically at Long Island, but Is Included In tabulations of costs.
(See Table I. appended)
•The treatment (for cost comparisons) of existing facilities at Deer Island
and.at Nut Island Is Inconsistent. Layout plans and comments In Ch. 4
seem to Indicate, eg., that existing primary tanks at Deer Island will
remain In service with rehabilitation in every Deer Island option, but the
cost estimates seem to presume new tankage. Conversely. It appears the
digesters at Nut Island would remain In service (options 1b2. 1b2). and
there Is no cost Item for digesters at Nut Island;
The comparisons of alternatives, from'spatial and cost viewpoints, must be
for facilities providing the same level of service and functions. Additionally,
serviceable equipment with reasonable remaining service life should be credited
In any particular option.
Additionally, and very significantly. It appears that life-cycle costing
("OtMsR") data presented In the report view pumping facilities, treatment works.
and conveyance systems (tunnels and outfalls) as If they all would be expected.
to have comparable service lives. This Is Incorrect, and will have a major im-
pact on the annualized OsMsR costs of alternatives. Table 2, appended, shows
that costs of "treatment" facilities, with service lives of 20-30 years, constitute
70-80% of the total costs of "secondary" options, but only 25-30% of the total
costs of "primary'-options. This results In an Inaccurate presentation and com-
parison of long-term costs to the MWRA and Its users of the two classes of options,
tending to reduce the difference. While the EIR/S argues that comparisons are
not to b« made between the two classes.- that the decision as to primary or secon-
dary is a "301 (h)" decision, we reject that concept as representing the worst kind
of tunnel vision, regardless of by whom exercised.
D. The consideration'and evaluation of "sub-reglonal"("satellite") treatment
. facilities Is Inadequate.
While the EIR/S and documents associated with it make, the point that siting
decisions for harborrside facilities are required regardless of whether a commit-
ment to sub-regional facilities Is feasible and Is made; and also indicate that
harbor-side capacity should be provided only for present day flows; two other
points need to be stressed. First, In the*time required for planning, design-
and construction of harbor-side facilities, peak and average daily flows from
the current system could be significantly reduced by a combination of reduction
of extraneous flows 11/I removal, which is currently seen by many as an "escape
valve" for growth pressure), and the aggressive development of subregional
.treatment plants; thus potentially reducing somewhat the scale of Rarbor-side
facilities. Second, a point weakly made In the EIR/S; subregional facilities In
the longer run can provide the localized capacity to accommodate needed or
desired Increases In sewage flows, at the time when further reduction in extra-
neous flows Is no longer a feasible way of freeing up system capacity.
It Is therefore most Important in the facility planning stage that the feasibility
of III reduction be aggressively and carefully tested, and the scale of harbor-side
facilities responsibly constrained to reduce their costs and Impacts, and improve .
thereby the feasibility of their construction.
D. The .mitigation of construction and operational Impacts requires further
consideration.
It Is well-taken that both construction and operational Impacts of the WWTP
on receptor groups (residents, patients. Inmates, visitors) must be effectively
mitigated. The EIR/S discusses certain mitigations of both classes of Impacts.
However. It Is weak on the feasibility/Implementabillty of those measures. In
the area of barging during construction, -there Is little reference to the impacts
of "shore-side" terminal locations on their environments, neighbors, and access
routes. For readers of the document. Including the MWRA, to assess the feasi-
bility and overall benefits of these mitigation measures, the EIR/S should Identify
and evaluate potential sites, and sustain a greater burden of establishing the
effectiveness and feasibility of proposed measures. Otherwise, the promise of
mitigation lacks reality. Similarly, the feasibility and effectiveness of mitigation
of construction noise, and of operational noise and odors, requires validation
. beyond the cursory assurances provided In the EIR/S. Such assessment will
necessarily be part of and may affect final siting decisions. These mitigation
measures are to some extent site-specific; as to extent required, feasibility, and
cost. .For example, noise mitigation may be more Important at Nut Island, and
at Long Island (hospital). Specifics may. therefore. Influence choice.
There are significant limitations which are not adequately stressed, as well.
The leading example Is the impossibility of avoiding significant adverse Impacts,
on the staff and patients at Long Island Hospital, of either (1) several hundred
millions of construction work during a period of 4-5 years within a few hundred
feet of the hospital, or (2) relocating the facility and Its occupant! to another site
(In all probability not prior to the start of construction and not without another
visitation of the "NTHfeY" syndrome).
E. The treatment of the Interaction between sludge management decisions, the
level-of-treatment decision, and the siting decision Is inadequate and some- '
what erroneous.
As pointed out above, the decision on the requested waiver of secondary
treatment will Impact • •
1) the amount and. nature of sludge produced
2) the size. cost, and operational costs of required facilities for treatment
of sewage and management of sludge
3) the implementability of siting decisions
4) the duration of construction impacts
5) energy consumption, and
6) the irreversible commitment of resources.
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the EIR/S avers, we believe erroneously. th»t the siting and sludge man-
agement decisions are independent. The first error Is in assuming'that ocean
dispersal or landfilling are viable long-term options for disposal of all or a major
part of sludge from the Boston metropolitan treatment facilities. Wa believe, and
there Is no evidence whatsoever to the contrary, that neither will prove available.
The realistic options are composting (of primary sludge only, due principally
to marketing limitations as projected from work done to date for EOEA and MDC)
and Incineration. The latter Is most probably the only option available for the
major portion of at least the secondary sludge.
While the harbor Islands should not be utilized for sludge composting, the
feasibility of an Inland operation has not been established. Should Siting
Option la2 or 1b2 be selected, another location for composting of primary sludge
would be mandated. Should that, for any of a number of reasons, prove. Infeasible.
then the combination of level-of-treatment and siting decisions would dictate the
sludge management decision-Incineration of all sludge at Deer Island. Major addi-
tional capital as well as operating costs would be incurred, and feasibility of
Implementing the siting decision would be affected. Should option 3bl be selected,
the remainder of Long Island could subsequently be lost to sewage treatment
(composting/Incineration).
Under the present state of affairs. It Is Impossible for any decision-maker
to perceive the full significant impacts of a.decision on siting, nor of a decision
on level of treatment.
We suggest prudence directs that the waiver decision be deferred until Iti
environmental Impacts, costs, benefits, and Implementabillty can be assessed"
based on
"the waiver application.
•reviewer analysis of the application,
"the Supplementary Final EIR/S. and
"a fuller understanding of the potentials and Implications of sludge manage-
ment alternatives Is available.
We further suggest the latter can be obtained well short of the full EIR /S
process now being initiated, and without what reasonable people would consider
undue delay. "Undue delay" In this case must reflect the long history of the
matter and the time needed to Implement-decisions, against both of which a few
months Is trivial; and also that of all the actions potentially affecting harbor
water quality, those actions which will follow the waiver and the siting decisions
are less Important than
'completion of the "fast-tract" projects
•adequate staffing, proper management, and full funding for the MSD
•elimination of sludge releases . ..
•elimination of dry-weather overflows,
•effective pretreatment
•treatment of CSO's, and
•reduction In extraneous flows.
. F. An opportunity to clearly establish priorities for harbor clean-up has not
• been taken.
The EIR/S' outlines briefly and correctly the major steps which must be taken
to correct water quality problems In the harbor. However, the responsible
agencies opted to limit Its scope to the "siting Issue", and the public never
stressed the desirability of putting all these actions Into a context of relative
costs and Importance and Into a framework of priorities. The parties to the
"Qulncy v. MDC* lawsuit In State Superior Court have'made some efforts In
this direction, but both Imputs and resources have been limited. Information
In the EIR/S (Including associated documents) can be helpful In such an effort,
which should be undertaken by the MWRA In cooperation with other agencies at
the earliest opportunity.
G. The Importance of an Industrial waste pretreatment program should be
emphasized.
While a pretreatment program and Its effectiveness are more germane to the
waiver and sludge management Issues than to siting per se. the interrelation of
these three Issues requires a more extensive discussion"oTpretreatment in the
EIR/S. Elements which must be analyzed Include
•The relative effectiveness In reducing discharges of "criteria" and other
pollutants through 1) pretreatment, 2) primary treatment, and 3) secondary
treatment.
•The relative costs of the 3 approaches
•The relationship between the need for a pretreatment program and a decision
to compost sludge from primary treatment or from primary/secondary treat-
ment.
•The relationship between a decision to Incinerate sludge and pretreatment.
"Pretreatment" should be analyzed at three levels - Federal standards, current
MDC standards, and a "lowest achievable discharge rate" which Incorporates
treatment technology, raw material and process changes, attention to potential
resident lot/commercial sources, and "non-point" source control In areas where
combined sewers may affect quality of metropolitan sewage.
IV. Detailed Comments
A. Introduction
This section Is organized on a Chapter and Section basis, following the organ-
ization of the SDEIR/S.
B. Chapter 2 ' ''
1. Section 2.2 Selection of Alternatives
The arguments presented against Inclusion of Alternative 5b2 (all primary
8 Long Island) are powerful and convincing. The logic for including alterna-
tives that are more damaging to the future of Long Island as the central
recreation facility in the Harbor, more damaging to Its ecosystem, and more
difficult of implementation, are weak and unconvincing.
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K>
I
'the evidence of the SDEIR/S i< very strong in demonstrating~that Nut
Island is a wholly Inappropriate site for an expanded facility. 'In addition
to all the problems presented, there Is no demonstration of the physical
feasibility of constructing an expanded facility on this site while maintaining
the operation of the current plant, which would be essential.
This section, and Section 2.3 should recognize the constraints Imposed on
the MWRA by Its enabling legislation with respect to exercise of eminent
domain powers.
2. Section 2.3
This section must address the "implcmentabUity" of relocation of Long
Island Hospital, which Is an absolute precursor to secondary treatment
options on Long Island and a very desirable mitigating measure were a
primary treatment facility to be located there. It must take into account
the City of Boston position (expressed In Ch. to, and In the 2/27/85 posi-
tion statement of Mayor Flynn entitled "Cleaning Up Boston Harbor*). as
well as the above-mentioned constraint on the MWRA.
It should discuss realistic potentials, and time frames, for such a move,
with estimates of costs and other pertinent factors.
3. Section 2.5- Sludge
As discussed In Part III of these comments, this section Is quite inadequate,
misleading, and erroneous. It assumes without any validation that sludge
processing facilities can be located off-site. It includes two quite unrealis-
tic options, ocean dispersal and landfllling. It Ignores the major problems
that surfaced in connection with the prior "sludge EIS". In short. It must
be extensively expanded and substantially revised.
*.. Section 2.6 - Decision process
General comments appear In Part III of these comments. More specifically.
It appears from the documents that a clear distinction should be made be-
tween the construction phase and the operating phase of the facility, insofar
as defining Impacted "neighbors". For the construction phase, the list of
"neighbors" should Include (In no particular order)
°nearby residential areas
"Deer Island House of Correction
'Long Island Hospital
°areas along routes of construction traffic
'areas proximate to mainland barge transfer locations and
contractor marshalling yards.
"the area(s) of potential relocation of any facilities.
eusers of the Harbor Islands State park Including potential users of
Long Island.
For the operating phase, the Impacts on the residential neighborhoods of
Point Shirley and Squantum appear to'be minimal, and construction traffic
and construction-related barging would cease. However, staff, access,
chlorine shipments, and potentially sludge transportation would continue
or begin.
Given the mitigation measures and controls proposed (excepting .for mainland
transfer areas as Indicated above). It would appear that .the most Important
criteria are Implementablllty and cost (both of which are significantly im-
pacted by the waiver decision). Impact.on the Institutional neighbors, and
reliability, provided that alternatives 1b2 and «b2 are dropped.
C. Chapter 3
1. .General ' '
The referenced "baseline water quality report" and environmental data
presented elsewhere In the SDEIR/S establish that sludge discharges,
overf(ows and bypasses of treatment works, dry-weather, end combined-
sewer overflows, and urban run-off are the most significant degraders of
harbor water quality. Given-the assumptions about discharge locations,
these reports provide nc basis for site selection. 'However, a significant
point Is not addressed. Since any treatment facility must have an emergency
' bypass, where, for each site, would this bypass be? What would be the
environmental and public health consequences of Its activation?
2. Section 3.3
The "community profiles" section uses population .figures drawn from Chi 12,
• which falls to explain and document the process of transition from census
tract data to the figures used. (This will be mentioned again In comments
on Ch. V2) The discussion of adverse Impacts on specific neighborhoods
from sources other than waste treatment raises practical and philosophical
Issues. For one, these areas have been so Impacted for some time. Is It
legitimate to assume that, over time, adjustments to these impacts have
occurred, and the socio-economic fabric of the neighborhood represents
some form of compensatory response thereto? Were that the case, how if
at all should those external Influences not under the control of the Authority
be factored into* decision? For another, should one, unrelated, form of
potential Impact be adjusted to "compensate" for other sources of different
Impacts with different effects (eg., "fear" v. "odors")? Particularly when
the controlling entities are quite unrelated? Or should the focus of govern-
ment be on directly mitigating and compensating those other Impacts?
D. Chapter * - Alternatives and their Impacts
1. General
As pointed out above, these alternatives (and therefore their Impacts) are
not strictly comparable. If there are site-specific reasons for differences
(other than layout)-In the treatment trains for each level-of-treatment ,
these should be explained and justified. Otherwise, the trains and layouts
should be made comparable. Additionally, the layouts depicted, and there-
fore the area requirements, and Table 12.4-5 should be .consistent. These
comments apply particularly to sludge-processing and storage facilities, and
to the difference In secondary treatment train nomenclature between Deer
Island and Long Island alternatives.
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2.
Chlorine Gas Deliveries
OO
O
Consideration should be given to b»rglng of chlorine to the treatment plant.
either through • dedicated barge or through a RO/RO procedure, thereby
avoiding community Impacts and addressing safety concerns. In addition.
discussion of the relationship between a long primary outfall and the need
for chlorlnatlon of final effluent at any time should be discussed further.
Eliminating non-essential chlorlnatlon will have environmental benefits,
reduce risks to the public and to facility staff, reduce operational traffic,
and reduce costs of construction and operation, as compared to secondary
treatment .
3.
Inclusion of alternatives not otherwise addressed.*
Two "alternatives*. "Deer Island Alternative Site. Layout (Primary)", (fig. a-13).
and "Nut Island Alternative Site Layout (ISA)" (fig. 1-6). are presented with
minimal discussion of Impacts and costs. Thst Deer Island layout should be
developed to the same level as other alternatives, with respect to all decision
criteria.
4. Impacts on Hough's Neck
It Is hard to comprehend the characterization of .construction noise and -dust,
and construction and operational odors associated with alternatives Ib2 and
4b2 as anything but "severe" with respect to Hough's Neck residents. It Is
suggested the traffic hazards which would result from use of Sea Ave. are
understood In the report.
S. Impacts of Long Island alternatives
The traffic safety hazard on Dorchester Street, Squantum seems understated.
The feasibility of changing traffic restrictions on Quincy Shore Drive for an
extended period of years should have been explored with the MDC and the
City of Quincy, In order that Its availability is a mitigating measure for
traffic Impacts on E. Squantum St. could be assessed.
The characterization of odor Impacts from "Long Island alternatives*
(«9- pg* 1-36) appears to be a deliberate attempt to understate this problem -
the term "moderate" applied to sewage odors In a recreational setting Is
Improper, the use of terms "only park visitors* (240,000 visitor-days per
year anticipated) and "If the park Is developed" is Inappropriate.
The total Incompatibility of a massive WWTP, and a recreational experience
cannot be underemphasized. Selection of a' Long Island option will eliminate
Long Island as a viable and attractive centerpiece for the Harbor Islands
State Park.
i. Section 4.3- Mitigating Measures
The discussion here and elsewhere is weak, and assurances of implementa-
tion are lacking. No attention Is paid to mainland facilities associated with
barging. Of particular note is the simplistic treatment In this section of odor
potential (4.3.3(3), pg. 4-93).
.7.' Section 4.3. S - Engineering Considerations
The "Future System Expansion" section should recognize provisions of the
MWRA legislation. The EIR/S, as pointed out above, should be much
stronger on measures to reduce the size of harbor-side facilities, obviate
the need for future expansion, and conserve water resources.
As pointed out above, the site-specific Implications of overflows and bypasses
•re not delineated.
8. Section 4.3.6 - Financial Impacts
There Is • suggestion of some form of compensation payments, certainly a
desirable approach. However, the feasibility under MWRA or otherwise Is
not examined ("Implementabillty" question).
8. Section 4.J.7 - Visual Quality
This section conflicts significantly with the site-specific Impact analyses
• elsewhere In the report. The first paragraph Is best described as "polly-
anna-lsh". The real feasibility of minimizing visual impact for each alterna-
tive must be clearly set forth In the Final SDEIR/S.
10. Section «.C - Unavoidable Adverse Effects
No mention Is made of the Irreversible commitment of additional resources
for construction and operation of secondary as compared to primary treat-
ment facilities.' These Include construction materials, labor, and energy;
but most Importantly the Irrevocable commitment of at least 50 acres of
precious harbor Island and an unknown commitment of lands and other re-
sources for sludge management.
The last line on p.4-107 is an insult to reason and Intelligence..
E. Chapter 5, Unresolved Issues
1. Section S..1
Strong exception is taken to the position that these "unresolved Issues"
•do not have the potential for affecting the location or other pertinent
siting characteristics of these treatment facilities", as has been pointed
out above.
2. Section S. 2 - Sludge
The alternatives are In part unrealistic. That site-specific differences exist,
potentially affecting the MWRA siting decision, has been pointed out. That
off-site options for sludge management may exist remains to be established.
3. Section 5.3- Mainland Facilities
This section correctly (pg. 5-4. top) expresses reservations about the
feasibility of a site or sites, and cursorily recognises-potential generic
Impacts. The problem is too critical to mitigation, and therefore to "Imple-
mentablllty", to receive other than the fullest treatment.
4. Section 5.6 - Growth
The discussion of growth, and of "satellite* facilities. Is generally sound.
However, there Is considerable evidence to question the assumption that the
High Level Sewer'can in the forseeable future handle peak demands without
Interfering with Mllton/Qulncy access to It, even with an aggressive I/I
program. Conversely, were that program successful, much of the apparent
need for Infrastructure Improvement would be obviated.
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to
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CD
Th« focus on the SMSO, whll« reflective of the DEQE focus to (late, needs
to'be changed to encompass the entire system.
F. Coordination
The statements regarding the role and Impact of the Technical Advisory
Croup are misleading. This group met only a few times, and has not met nor
been consulted since late summer 1984.
C. Chapter 9 - Legislation
The MWRA legislation (Ch. 372. Acts of 1984) must be Incorporated. The
Mass. Clean Water Act and other Massachusetts water quality legislation should
also be Included.
H. Chapter 1.1 - Permits and Marine Resource Impacts
1. 'Checklist
There Is no basis, from any of the layouts, for Including the Wlnthrop
Conservation Commission In Item 3.
Item 7 appears to be an overly broad statement of the responsibility of'DEM
(See 12.11) •
There should be an Item 16 discussing the provisions of Ch. 372/1984 relative
to the exercise of eminent domain.
2. Section 11.2
The comment (pp. 11.2-12. 13) concerning construction of an offshore
Island Is most unrealistic and. In addition, would greatly affect the placement
and functioning of a dlffuser. It would be appropriate to utilize tunnel and
dredge spoils, and demolition debris, for berm construction.
3.. Section 11.3
Were EPA's contention concerning the restricted basis for a Section 30t(h)
decision realistic, then this section would be of no consequence. It Is In
significant part a comparison (misleading) of the relative effects of primary
and secondary treatment. The baseline report, as Indicated above, has
little relevance to siting decisions except with respect to emergency bypasses.
It Is clear that the impact of well-diffused primary effluent on harbor water
quality has not been established as adverse.
To the contrary, (he assumption about the effectiveness of a secondary
treatment plant of this size, treating MSD wastewaters, are unsubstantiated.
If an effective pretreatment program Is assumed. It Is probable that the
primary options have significantly less advene water quality Impacts than
the secondary options. Conclusion (1) under "A. Quality of Effluent* on
page 11.3-3 Is unwarranted based on evidence Included In the SDEIR/S.
The comments relative to metals and other toxins would be Irrelevant In the
presence of an effective pretreatment program. There is need to compare
primary/secondary treatments effects on removals compared to pretreatment
to assess the Implications for sludge management and, therefore, for
facility siting. .
•'the comment under B.3on pg. 11.3-4 raises the question of potentially
greater costs than projected for secondary treatment. Further review and
clarification Is essential.
The presentation In Figure 11.3-1 Is sorely Inadequate.
Given the options under consideration, collform reduction efficiencies
(Table 11.3-2) are Irrelevant to (1) a choice between levels of treatment
and (2) siting. The estimate for BOD removal by .secondary treatment, for
this situation, should be questioned (see note 1. pg. 11.3-11). The foot-
notes to Table 11.3-3 Indicate the 'median a/o removals* presented for
secondary treatment plants. In Table 11.3-9, are not meaningful.
In Table 11.3-10. It should be made clear that the dilution needed for
•chronic" criteria should be compared to the average dilution obtained with
a specific alternative.
On page 11.3-19, the last sentence of the first paragraph suggests a further
disadvantage to a secondary treatment, facility with discharge as proposed.
The data of Petrasek et al should be evaluated to establish relevancy.
In Table 11.3-16. trials 8-20 appear Irrelevant to the situation.
The observation, on pg. 11.3-29, concerning chlorlnatton and long outfalls
should be combined with the footnote under Table 11.3-3, and the whole
Issue of chlorlnatton of primary final effluent reconsidered.
The comments under 11.3.6 reinforce earlier comments about the site-specific
Impacts of such discharges.
I . Chapter 12 - Baseline Reports and Analyses
Materials In this Chapter have been covered generally In preceedlng sections,
and will be discussed In more detail In an Appendix to these comments which
will be submitted to EOEA not later than that date.
The attempt to disengage and disassociate the critical decisions concerning
level of treatment, sludge management, siting of facilities, and priorities affecting
harbor water quality Is environmentally and economically unsound. • If successful.
It will severely Impact the Implementabillty of siting decisions, assure the commit-
ment of time and resources to litigation, and mlsallocate scarce funds.
The SDEIR/S makes of its own weight several very significant matters quite
apparent.
"Nut Island Is the least acceptable of the several sites., from "neighborhood
Impact" and feasibility standpoints.
"Long Island Is not acceptable as a site on the basis of Implementability. cost,
environmental and archeologlcal effects, and Impacts on recreation potential.
-------
There are a number of shortcomings In the documents which must be corrected
before It will be useful to the MWRA as a decision guide.
Submitted to the Executive Office of.
Environmental Affairs for and by
direction of the City of Qulncy, MA
McCrath, Sylva ano> Associates, Inc
to
I
(-•
00
K)
by David Standley, Assocjote
March 11, 1985
Option
Sec. Treat.
ta2
(•II 01)
1b2
(Split Plr)
(Sec 001)
Jbl
(all LI)
Jbl
(Prl. 0 01)
(Prl/Sec 6 LI)
TABLE I
Comparison of Sludge Progressing Facilities by Option
Digesters (I « 01)
Crav. Thick (« • 01)
Plot. Thick « 01
0 C Gas Stor. • 01
Digesters (« • 01, < (exist) 0 Nl)
Crav. Thick (S « Dl, 2 « Nl)
Plot. Thick • 01)
DC Cai Stor. « 01
No Digesters, Thickness, or gas storage
Digesters (« 0 Dl, none • LI)
Crav. Thick (5 0 Dl, none « LI)
DC Cas Stor. 0 Dl (none « LI)
Prl. Treat.
Only
«aJ
(all Dl)
U>2
(DI/NI)
Sa2
(DI/LI)
(all LI)
Digesters (8 • 01)
Crav. Thick (6 0 Dl)
DC Cas Stor. (2 0 Dl)
Digesters (« 0 01. « (exist) 0 Nl)
Crav. Thick (5 ODI. 2 • Nl)
DC Cas Stor. (1 « Dl)
Digesters (« 0 Dl. « 0 LI)
Crav. Thick (5 8 Dl. 2 0 LI)
DC Cas Stor. (1 «DI, 1 0 LI)
Digesters (« 0 LI (large)) \
Crav. Thick (2 fl LI) I
DC Cas Stor. (1 0 LI) I
(Derived from Layout Plans; Figures *-2 to B-2*)
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TABLE I
Comparison of 'Treatment" Co«ti v». •Outfill/Tunnel" Com
Option
1a2
IbJ
Zbl
2b2
Totll
$600m
6SO
710
7*0
Out fall/Tunnel
$UOm
130
210
210
00
U)
*a2
S>2
5b2
7SO
110
870
190 (25%)
250 .(31%)
260 (32%)
240 (28%)
560
S60
S60
630
(Derived from Table 12.*-5)
- Sludge tranaport to Deer Xaland by barge la preferred to pumped transport'
via force main.
- Inatltutlon of a barging/ferry ayatem will allow the HOC to nova Boat
conatruction and operatlona materials and peraonnel by water, thereby
easing the potential for aevere tranaportation-related impacta in the
Point Shirley (Winthrop) neighborhood* adjoining Deer laland.
- Primary treatment will produce 110 dry tone of anaeroblcally digeatad
aludge per day. (Sludge Management Update Summary, pp. 1.4 - 1.7.)
The technical feaaibillty and economica of materiale tranaport alternatlvea
are preaented in Section 5.5 of the Sludge Management Update Summary. Thie
aection comparee pipeline tranaport and barging of liquid aludge from Nut
Xaland to Deer laland.
The pipeline alternative required the inatallatlon of a new 10-inch force main
from Nut laland to Deer laland, an extenalon of the exiating aludge outfall
force main to Deer Xaland, a 250,000 gallon aurge tank at Deer laland, and a
pumping atation.
The barge alternative waa deaigned to tranaport conatruction materiala,
truckfl, and liquid aludge for ocean dumping in addition to the Hut Xaland to
Deer laland liquid aludge tranafer. The barge aelected waa a combination
veaael with a 900,000 gallon hold capacity and 1,000 ton deck capacity. The
barge waa aalf-propelled, with an on-board pumping ayatem, and a travel apeed
off 1 knota. Ita aixe waa reported to be 195* x 35'.* Xt waa proposed to uae
two of the bargea daacrlbed, making 95 tripa per year to tranafer the primary
aludge load from Nut laland to Deer laland. Tola aaauaea a two-nan crew, one
ahift per day, aeven daya per week.
.•Hotel The depth la calculated to be 18* for 900,000 gallon capacity, which
iapllea an unuaually deep barge or miatatement of capacity.
The barging alternative required the conatruction of a liquid aludge loading
facility at Nut laland conalating of a finger pier extending approximately
250* from an exiating digeater. A docking facility waa propoaed for Deer
Xaland to be conatructad at an exiating cofferdam weat of the plant. A aludge
force main would be inatalled to connect the barge to a atorage tank of
approximately 500,000 gallona.
approxioataly 500,000 gallons.
A coat aumary, compiled froa aavaral tables in the re;
plp«lin« and bar9* aludge tranaport follow*t
port comparing
the
Total Capital Coat
Total Present Worth
Annual O I H
Barge
9,715,000
11.860,000
223,000
The report ettphaaizea that tha barg« coat could b* raduccd by uatng a flng«r
pi«r at Oaar laland In placa of a full dock at a aavinga of $1.7 mil lion, and
2626*
Appendix - 17
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March 15. 198S
Enclosure t
N)
I
CO
Honorable Michael R. Delano1
Regional Administrator
US Environmental Protection Agency
John F. Kennedy Federal Building
Government Center
Boston. Massachusetts 02203
Dear Mr. Deland:
RE: SDEIS - Boston Harbor
Please find enclosed the comments of the City of Qulncy. MA concerning
the Draft Supplementary Environmental Impact Stateirent on Siting of Wastewater
Treatment Facilities for Boston Harbor.
Enclosure! (2)
cc: Secretary Hoyte
Commissioner Geary
Commissioner Sylva
Peter Koff, Esquire
David Standley
RECEIVED-EPA
SEWAGE TREATMENT for BOSTON HARBOR
Summary and Statement of Position of Qulncy
tor presentation at public hearings on the Supplemental Draft
EIS on Siting of Wastewater Treatment Facilities In Boston Harbor
A set of major decision! must soon be addressed by the new Metropolitan
Water Resource Authority, relating to clean-up of Boston Harbor. Several
agencies and many Interests are Involved or affected, and the decisions are
closely Interrelated and should, but are not. be Integrated. They Include:
•The level of treatment required (primary or secondary (the "301(h) decision
by EPA)). This affects the size. cost, and feasibility of siting a treatment
plant; the quantity and nature of sludge produced; the cost of operation;
energy consumption; and the duration of Impacts of construction.
The system or systems for. and the locations of. sludge treatment, utili-
zation, or disposal facilities. The options are composting. Incineration,
and deep-ocean dispersal. AnMWRA decision, affected by EPA and State
permitting actions.
Composting, selected by the State as the most desirable option for primary
sludge, may not be feasible for secondary sludge. Considerable land Is
required for treatment, and assurance of utilization Is a problem.
Incineration, the most costly, requires tall stacks, air pollution control
equipment, and land at the treatment plant.
EPA permits for deep-ocean dispersal would require satisfaction of a number
of very restrictive Federal criteria.
•What priority to give to clean-up of near-shore sewage discharges (Combined
Sewer overflows, system bypasses, sewer overflows), and to improvements
In the sewage collection system.
"Whether to consolidate all treatment facilities at one site, or utilize different
locations for parts of the process or portions of the flow. An MWRA decision,
affected by costs, feasibility of siting, reliability, management factors; and
substantially Impacted by the level-of-treatirent and sludge management
decisions.
•Where to locate treatment and sludge management facilities. Which Harbor
Island or Islands to utilize for the treatment plant(s). Should sludge be
treated at a location remote from the treatment plantU). An MWRA
decision, affected by the environmental review process. EPA/DEQE funding
decision, the actions of landowners (Federal Government. City of Boston).
relative costs.
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en
EPA has proposed 7 alternative:siting decisions; 3 for primary treatment,
4 for secondary treatment. Three would site new facilities on Long Island, with
the larger plant occupying the southern 2/3 of the Island; two would'expand the
Nut Island plant. Construction costs would range from $600 million to $100
million, with the 'all Deer Island* alternatives the least costly. Operating costs
for primary treatment are estimated at $20-$25 million per year; for secondary
treatment $«5-$50 million. The construction period for primary facilities would
be »-5 years; for secondary, 1-9 years.
These proposed siting alternatives, depending on EPA's decision about which
level of treatment to require, are listed below. The acreage requirements are
shown In parentheses.
Primary Treatment
•Consolidation of all treatment
facilities at Deer Island (60)
•Expanding the existing treatment
plants at Deer (SOI and Nut(JO)
Islands.
•Relocating and expanding the Nut
Island plant to Long IllandOO);
retaining and expanding the
Deer Island plant (SO).
Secondary Treatment
•Consolidation of all treatment
facilities at Deer Island (100+)
"Expand the primary plant at Nut
lsland(20); construct all secondary
facilities at Deer lsland(100+).
•Relocate all facilities to Long Island (80);
except for existing primary treatment
at Deer Island (SO).
•Relocate all treatment facilities to Long
Island (100).
Comparison of Secondary vs. Primary Treatment
Doubling of -acreage for treatment (exclusive of sludge)
-amount of sludge produced
- cost of operation
Tripling of energy requirements
Less reliable operation
More staff
Greater construction Impacts
Water quality In Boston Harbor potentially worse than with primary
treatment and an extended outfall.
Positions of the City of Qulncy
On Secondary Treatment
Unnecessary from water quality standpoint
Excessively costly to operate
Requires too much space, and too much energy
Seriously complicates the siting process
Generates, needlessly, much greater quantities of sludge
Uses resources which must be dedicated to higher priorities
On facility siting
Facilities should be consolidated
Nut Island is
too small
too close to residential areas
to be considered as a treatment plant site.
Long Island Is
too valuable as open space and • recreation center
too difficult to utilize
(Hospital relocation, cultural/historic remains, environmental
Impacts, cemetery, legislative approval, Boston ownership)
too costly
to be considered as a treatment plant site.
On the EIS/EIR
Ignores Impacts of sludge management decision on facility siting
questions
Ignores the effect of "level-of-treatment" decision on Impacts of
sludge generation and management
Tries to compare dissimilar facilities
Is seriously Inadequate In treatment of mitigation measures - their
costs, benefits, and Implementabillty for different alternatives
Falls to properly present the long-range cost Implications to
residents
Has a host of other Inaccuracies, Inadequacies, and Inconsistencies
detailed In a more extensive Qulncy statement.
On the 'decision process*
Seriously confuses and clouds the relationship between decisions on
degree of treatment, sludge management, and siting.
• Does not make clear the role of each "party* In the several decisions.
Paul Anderson, Commissioner
Qulncy Department of Public Works
February 20. 198S
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Enclosure 2
SEWAGE TREATMENT FOR BOSTON HARBOR
00
0V
Comments and ititementi on behalf of the City of Qulncy, concerning the
Supplemental Draft EIR/EIS on Siting of Wastewater Treatment Facilities In Boston
Harbor and related matters.
Submitted to the Regional Administrator. US Environmental Protection Agency.
pursuant' to the National Environmental Policy Act.
I. Introduction
This detailed statement Is prepared and submitted by McCrath. Sylva and
Associates. Inc., David Standley. PE. principal Investigator, as a supplement
to the February 20, 1985 statement of Paul N. Anderson, Commissioner, Qulncy
Department of Public Works, to which It Is attached.
II. Overview
A. An Integrated Approach Is an Essential Element of Rational Decision-making.
This SDEIR/S Is but an element of the decision process and actions which
are requisite to attaining and maintaining acceptable water quality In and around
Boston Harbor, and to conforming to the Import of Federal and State laws and
regulations. In turn, attaining and maintaining water quality standards Is but
one element In the process of proper utilization and enjoyment of the resources
of Boston Harbor; which In turn Is an element in determining the quality of
life of the population of the region. In the narrowest sense, the decisions on
level of sewage treatment, management of sludge, location of sewage treatment
Including sludge management facilities, and location of discharges, are Intertwined
and must logically be made with the objective of minimizing costs and other adverse
impacts for attainment of water quality objectives. For example, the Imputed
narrowness of the basis for an EPA decision concerning level-of-treatment Is
Illogical In the extreme since It fails to take into account the comparative environ-
mental benefits and Impacts of the two categories of options in the particular
case of Boston Harbor; the Impact of expenditures required thereby upon accom-
plishment of higher-priority, greater-benefit actions such as reduction of extra-
neous flows In the sewer system and correction of dry-weather and combined-
sewer overflows to Inland and near-shore estaurine waters; its effect upon the
feasibility and Implementabillty of siting alternatives; and (not the least) the
Impact upon sludge production and management which In turn affects the environ-
mental consequences of sludge management options, limits those options further,
and affects the environmental Impact of sewage treatment facilities. This EPA
decision, pursuant to >.301(h) of the Clean Water Act, also has potential major
consequences for the recreational uses of Boston Harbor, the aesthetics of the
treatment plant site or sites, and for the feasibility and cost of successfully
mitigating impacts of the construction and operation of resultant facilities.
B. The EIR/S Must Reflect Current Events and Situations
In late 1184. the Mass. Legislature created the Metropolitan Water Resources
Authority (the MWRA). That entity effectively replaces the MDC insofar as
water supply and sewerage functions are concerned, establishes a new body for
end method of decision-making, materially alters the process for and sources of
funding of metropolitan water supply and sewage disposal activities, and renders
• nullity the so-called "MDC preferred option" Insofar as that "option* purports
to reflect the view of the decision-making body with responsibility In these
matters. It Is Important to recognlie that the MDC. not the MWRA acting by and
through Its Board of Directors, has submitted this SDEIR/S to EOEA and EPA.
The commitment of the Federal government to the major role In funding
wastewater treatment facilities In this country has been the principal support and
encouragement for the Improvements of the past decade (including such Improve-
ments as have been made In that period by the MDC). That commitment has
changed significantly In very recent years In at least three Important ways -
reduction In Federal share of project costs, restrictions to eligibility for Federal
assistance, and reduction In the total Federal funds available. Well within the
time horizon for the actions contemplated by this SDEIR/S, the current Adminis-
tration has proposed further major reductions. In fact a phasing out. of Federal
funds. Certain provisions of the MWRA Act reflect In part these facts. While
they will not affect whether facilities should be Improved, these actions will
certainly Impact MWRA costs, and therefore have consumer Impacts. This needs
to be discussed more fully and realistically In the EIR/S, as It could affect the
decisions of the MWRA In several ways.
III. Major Comments Concerning the Decision Processes
A. The decisions to bemade based on the EIR/S are limited.
EPA and MDEQE, as a result of this process, will be enabled to Issue permits
for and participate In the funding of an MWRA decision which Is not inconsistent
with the findings and recommendations developed In and from the Final EIR/S.
It does not appear, from the documents, that an "environmentally-preferred
option" could be so conclusively superior to some other possibilities as to rule
out both a different choice by MWRA and its acceptance by Federal and State
regulatory and funding agencies, (n.b. the 3/6/85 letter of Mr. Deland to Sec. Hoyte)
B. The ranking and weighting of criteria will remain a subjective process.
The six criteria selected for the SDEIR/S need reexaminatlon. The first
three could arguably by subsumed Into a single criterion labelled "environmen-
tal quality", which would also be affected by "reliability''. If this is recognized.
attempts to numerically "weight" and "score" against the criteria'are avoided, and
the limited definitions provided In Ch. 2 are kept In mind, the criteria are
useful. However, no standards of general applicability exist, and the relative
Importance of various factors is a wholly subjective and highly individualized
judgement. It would appear that such decisions or findings as are contemplated
by MEPA and NEPA must be reached either by an Individual or as the consensus
of a group.
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C. The presentation and treatment of alternatives Is not consistent.
There are several examples of Inconsistent presentations and treatments of
alternatives, such that attempts at comparisons are of unlike things. For
examples, we cite the following:
"Somewhat different treatment processes and trains are presented for
secondary treatment at Deer Island and at Long Island, such as to mini-
mize the apparent acreage requirements of the Long Island options by
comparison.
"In "Options 2b1 and 2b3", sludge processing capability Is not represented
graphically at Long Island, but Is Included In tabulations of costs.
(See Table I. appended)
"The treatment (for cost comparisons) of existing facilities at Deer Island
and at Nut Island la Inconsistent. Layout plans and comments In Ch. 4
seem to Indicate, eg., that existing primary tanks at Deer Island will
remain In service with rehabilitation In every Deer Island option, but the
cost estimates seem to presume new tankage. Conversely. It appears the
digesters at Nut Island would remain In service (options 1b2, 4b2), and
there Is no cost Item for digesters at Nut Island.
The comparisons of alternatives, from spatial and cost viewpoints, must be
for facilities providing the same level of service and functions. Additionally,
serviceable equipment with reasonable remaining service life should be credited
In any particular option.
Additionally, and very significantly. It appears that life-cycle costing
("OsM&R") data presented In the report view pumping facilities, treatment works,
and conveyance systems (tunnels and outfalls) as If they all would be expected
to have comparable service lives. This Is incorrect, and will have a major Im-
pact on the annualized OSMsR costs of alternatives. Table 2. appended, shows
that costs of "treatment" facilities, with service lives of 20-30 years, constitute
70-80% of the total costs of "secondary" options, but only 25-30% of the total
costs of "primary" options. This results in an inaccurate presentation and com-
parison of long-term costs to the MWRA and Its users of the two classes of options,
tending to reduce the difference. While the EIR/S argues that comparisons are
not to be made between the two classes, that the decision as to primary or secon-
dary Is a "301(h)° decision, we reject that concept as representing the worst kind
of tunnel vision, regardless of by whom exercised.
D. The consideration and evaluation of "sub-regkmal"("satellite") treatment
facilities is Inadequate.
While the EIR/S and documents associated with It make the point that siting
decisions for harbor-side facilities are required regardless of whether a commit-
ment to sub-regional facilities Is feasible and is made; and also indicate that
harbor-side capacity should be provided only for present-day flows; two other
points need to be stressed. First, in the time required for planning, design
and construction of harbor-side facilities, peak and average daily flows from
the current system could be significantly reduced by a combination of reduction
of extraneous flows (I/I removal, which Is currently seen by many as an "escape
valve" for growth pressure). and the aggressive development of subregional
treatment plants; thus potentially reducing somewhat the scale of harbor-side
facilities. Second, a point weakly made In the EIR/S; subregional facilities in
the longer run can provide the localized capacity to accommodate needed or
desired Increases In sewage flows, at the time when further reduction in extra-
neous flows Is no longer a feasible way of freeing up system capacity.
It Is therefore most Important In the facility planning stage that the feasibility
of I/I reduction be aggressively and carefully tested, and the scale of harbor-side
facilities responsibly constrained to reduce their costs and Impacts, and Improve
thereby the feasibility of their construction.
D. The mitigation of construction and operational Impacts requires further
consideration.
It Is well-taken that both construction and operational impacts of the WWTP
on receptor groups (residents, patients. Inmates, visitors) must be effectively
mitigated. The EIR/S discusses certain mitigations of both classes of Impacts.
However, It Is weak on the feaslblllty/lmplementabillty of those measures. In
the area of barging during construction, there Is little reference to the Impacts
of "shore-side" terminal locations on their environments, neighbors, and access
routes. For readers of the document. Including the MWRA, to assess the feasi-
bility and overall benefits of these mitigation measures, the EIR/S should Identify
and evaluate potential sites, and sustain a greater burden of establishing the
effectiveness and feasibility of proposed measures. Otherwise, the promise of
mitigation lacks reality. Similarly, the feasibility and effectiveness of mitigation
of construction noise, and of operational noise and odors, requires validation
beyond the cursory assurances provided In the EIR/S. Such assessment will
necessarily be part of and may affect final siting decisions. These mitigation
measures are to some extent site-specific; as to extent required, feasibility, and
cost. For example, noise mitigation may be more important at Nut Island, and
at Long Island (hospital). Specifics may, therefore. Influence choice.
There are significant limitations which are not adequately stressed, as well.
The leading example is the Impossibility of avoiding significant adverse impacts,
on the staff and patients at Long Island Hospital, of either (1) several hundred
millions of construction work during a period of 4-S years within a few hundred
feet of the hospital, or (2) relocating the facility and Its.occupants to another site
(In all probability not prior to the start of construction and not without another
visitation of the "NTHfeY" syndrome).
E. The treatment of the interaction between sludge management decisions, the
level-of-treatment decision, and the siting decision is inadequate and some-
what erroneous.
As pointed out above, the decision on the requested waiver of secondary
treatment will Impact
1) the amount and nature of sludge produced
2) the size, cost, and operational costs of required facilities for treatment
of sewage and management of sludge
3) the Implementability of siting decisions
«) the duration of construction impacts
5) energy consumption, and
6) the irreversible commitment of resources.
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The EIR/S avers, we believe erroneously, that the siting »nd sludge man-
agement decisions are Independent. The first error Is In assuming that ocean
dispersal or landfllllng are viable long-term options for disposal of all or a major
part of sludge from the Boston metropolitan treatment facilities. We believe, and
there Is no evidence whatsoever to the contrary, that neither will.prove available.
The realistic options are composting (of primary sludge only, due principally
to marketing limitations as projected from work done to date for EOEA and MDC)
and Incineration. The latter Is most probably the only option available for the
major portion of at least the secondary sludge.
While the harbor Islands should not be utilized for sludge composting, the
feasibility of an Inland operation has not been established. Should Siting
Option la2 or Ib2 be selected, another location for composting of primary sludge
would be mandated. Should that, for any of a number of reasons, prove Infeasible,
then the combination of level-of-treatment and siting decisions would dictate the
sludge management decision-Incineration of all sludge at Deer Island. Major addi-
tional capital as well as operating costs would be incurred, and feasibility of
Implementing the siting decision would be affected. Should option 2bl be selected,
the remainder of Long Island could subsequently be lost to sewage treatment
(composting/incineration).
Under the present state of affairs. It is Impossible for any decision-maker
to perceive the full significant Impacts of a decision on siting, nor of a decision
on level of treatment.
We suggest prudence directs that the waiver decision be deferred until Its
environmental Impacts, costs, benefits, and Implementability can be assessed
based on
"the waiver application,
•reviewer analysis of the application,
"the Supplementary Final EIR/S, and
°a fuller understanding of the potentials and Implications of sludge manage-
ment alternatives Is available.
We further suggest the latter can be obtained well short of the full EIR/S
process now being Initiated, and without what reasonable people would consider
undue delay. "Undue delay" In this case must reflect the long history of the
matter and the time needed to Implement decisions, against both of which a few
months Is trivial; and also that of all the actions potentially affecting harbor
water quality, those actions which will follow the waiver and the siting decisions
are less important than
'completion of the "fast-track* projects
'adequate staffing, proper management, and full funding for the MSD
'elimination of sludge releases
'elimination of dry-weather overflows,
'effective pretreatment
'treatment of CSO's, and
'reduction in extraneous flows.
F.
An opportunity to clearly establish priorities for harbor clean-up has not
been taken.
The EIR/S' outlines briefly and correctly the major steps which must be taken
to correct water quality problems In the harbor. However, the responsible
agencies opted to limit Its scope to the 'siting Issue', and the public never
stressed the desirability of putting all these actions Into a context of relative
costs and Importance and Into a framework of priorities. The parties to the
"Qulncy v. MDC* lawsuit In State Superior Court have made some efforts In
this direction, but both Inputs and resources have been limited. Information
In the EIR/S (Including associated documents) can be helpful In such an effort,
which should be undertaken by the MWRA In cooperation with other agencies at
the earliest opportunity.
C. The Importance of an Industrial waste pretreatment program should be
emphasised.
White a pretreatment program and Its effectiveness are more germane to the
waiver and sludge management Issues than to siting per se, the Interrelation of
these three Issues requires a more extensive discussion" oTpretreatment in the
EIR/S. Elements which must be analyzed Include
•The relative effectiveness In reducing discharges of "criteria" and other
pollutants through I) pretreatment, 2) primary treatment, and 3) secondary
treatment.
•The relative costs of the 3 approaches
"The relationship between the need for • pretreatment program and a decision
to compost sludge from primary treatment or from primary/secondary treat-
ment.
•The relationship between pretreatment and • decision to Incinerate sludge.
"Pretreatment' should be analysed at three levels - Federal standards, current
MDC standards, and a "lowest achievable discharge rate* which incorporates
treatment technology, raw material and process changes, attention to potential
residential/commercial sources, and "non-point" source control in areas where
combined sewers may affect quality'of metropolitan sewage.
IV. Detailed Comments
A. Introduction
This section Is organized on a Chapter and Section basis, following the organ-
isation of the SDEIR/S.
B. Chapter 2
1. Section 2.2 Selection of Alternatives
The arguments presented against Inclusion of Alternative Sb2 (all primary
0 Long Island) are powerful and convincing. The logic for including alterna-
tives that are more damaging to the future of Long Island as the central
recreation facility in the Harbor, more damaging to Its ecosystem, and more
difficult of Implementation, are weak and unconvincing.
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The evidence of the SOEIR/S l> very strong In demonstrating that Nut
Island Is a wholly Inappropriate site for an expanded facility. In addition
to all the problems presented, there Is no demonstration of the physical
feasibility of constructing an expanded facility on this site while maintaining
the operation of the current plant, which would be essential.
This section, and Section 2.1 should recognize the constraints Imposed on
the MWRA by Its enabling legislation with respect to exercise of eminent
domain powers.
2. Section 2.3
This section must address the "implementabillty* of relocation of Long
Island Hospital, which Is an absolute precursor to secondary treatment
options on Long Island and a very desirable mitigating measure were a
primary treatment facility to be located there. It must take Into account
the City of Boston position (expressed in Ch. 10, and In the 2/27/85 posi-
tion statement of Mayor Flynn entitled 'Cleaning Up Boston Harbor'), as
well as the above-mentioned constraint on the MWRA.
It should discuss realistic potentials, and time frames, for such a move.
with estimates of costs and other pertinent factors.
3. Section 2.5 -Sludge
As discussed In Part III of these comments, this section is quite Inadequate,
misleading, and erroneous. It assumes without any validation that sludge
processing facilities can be located off-site. It Includes two quite unrealis-
tic options, ocean dispersal and landfllling. It Ignores the major problems
that surfaced in connection with the prior 'sludge EIS". In short. It must
be extensively expanded and substantially revised.
a. Section 2.6 - Decision process
General comments appear In Part III of these comments. More specifically.
It appears from the documents that a clear distinction should be made be-
tween tin construction phase and the operating phase of the facility. Insofar
as defining Impacted "neighbors". 'For the construction phase, the list of
"neighbors" should include (In no particular order)
"nearby residential areas
"Deer Island House of Correction
"Long Island Hospital
"areas along routes of construction traffic
"areas proximate to mainland barge transfer locations and
contractor marshalling yards.
"the area(s) of potential relocation of any facilities
"users of the Harbor Islands State park including potential users of
Long Island.
For the operating phase, the impacts on the residential neighborhoods of
Point Shirley and Squantum appear to be minimal, and construction traffic
and construction-related barging would cease. However, staff, access.
chlorine shipments, and potentially sludge transportation would continue
or begin.
Given the mitigation measures and controls proposed (excepting for mainland
transfer areas as Indicated above), it would appear that the most Important
criteria are implementabillty and cost (both of which are significantly im-
pacted by the waiver decision), impact on the Institutional neighbors, and
reliability, provided that alternatives Ib2 and 1b2 are dropped.
C. Chapter 3
1. General
The referenced "baseline water quality report* and environmental data
presented elsewhere In the SDEIR/S establish that sludge discharges,
overflows and bypasses of treatment works, dry-weather and combined-
sewer overflows, and urban run-off are the most significant degraders of
harbor water quality. Given the assumptions about discharge locations,
these reports provide nc basis for site selection. However, a significant
point Is not addressed. Since any treatment facility must have an emergency
bypass, where, for each site, would this bypass be? What would be the
environmental and public health consequences of Its activation?
2. Section 3.3
The "community profiles* section uses population figures drawn from Ch.12,
which falls to explain and document tha process of transition frosi census
, tract data to the figures used. (This will be mentioned again In comments
on Ch. 12) The discussion of adverse Impacts on specific neighborhoods
from sources other than waste treatment raises practical and philosophical
Issues. For one, these areas have been so Impacted for some time. Is it
legitimate to assume that, over time, adjustments to these Impacts have
occurred, and the socio-economic fabric of the neighborhood represents
some form of compensatory response thereto? Were that the case, how If
at all should those external Influences not under the control of the Authority
be factored Into a decision? For another, should one, unrelated, form of
potential Impact be adjusted to 'compensate' for other sources of different
Impacts with different effects (eg., "fear" v. "odors")? Particularly when
the controlling entitles are quite unrelated? Or should the focus of govern-
ment be on directly mitigating and compensating those other impacts?
D. Chapter 4 - Alternatives and their Impacts
1. General
As pointed out above, these alternatives (and therefore their impacts) are
not strictly comparable. If there are site-specific reasons for differences
(other than layout) in the treatment trains for each level-of-treatment ,
these should be explained and Justified. Otherwise, the trains and layouts
should be made comparable. Additionally, the layouts depicted, and there-
fore the area requirements, and Table 12.4-5 should be consistent. These
comments apply particularly to sludge-processing and storage facilities, and
to the difference in secondary treatment train nomenclature between Deer
Island and Long Island alternatives.
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Chlorine Cai Deliveries
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Consideration should be given to barging of chlorine to the treatment plant.
either through a dedicated barge or through a RO/RO procedure, thereby
avoiding community Impacts and addressing safety concerns. In addition.
discussion of the relationship between a long primary outfall and the need
for chlorlnatlon of final effluent at any time should be discussed further.
Eliminating non-essential chlorlnatlon will have environmental benefits,
reduce risks to the public and to facility staff, reduce operational traffic.
and reduce costs of construction and operation, as compared to secondary
treatment.
Inclusion of alternatives not otherwise addressed.
•alternatives', 'Deer Island Alternative Site Layout (Primary)*
3.
Two "alternatives*, *0eer Island Alternative Site Layout (Primary)* (fig. a-13).
and "Nut Island Alternative Site Layout (ISA)* (fig.4-6), are presented with
minimal discussion of Impacts and costs. That Deer Island layout should be
developed to the same level as other alternatives, with respect to all decision
criteria.
«. Impacts on Hough's Neck
It Is hard to comprehend the characterization of construction noise and dust,
and construction and operational odors associated with alternatives Ib2 and
4b2 as anything but "severe* with respect to Hough's Neck residents. It is
suggested the traffic hazards which would result from use of Sea Ave. are
understated in the report.
S. Impacts of Long Island alternatives
The traffic safety hazard on Dorchester Street, Squantum seems understated.
The feasibility of changing traffic restrictions on Qulncy Shore Drive for an
extended period of years should have been explored with the MDC and the
City of Qulncy, In order that Its availability as a mitigating measure for
traffic Impacts on E. Squantum St.'could be assessed.
The characterization of odor Impacts from "Long Island alternatives"-
(eg. pg. 1-36) appears to be a deliberate attempt to understate this problem -
the term "moderate" applied to sewage odors In a recreational setting is
improper, the use of terms "only park visitors" (210,000 visitor-days per
year anticipated) and "If the park Is developed" is inappropriate.
The total incompatibility of a massive WWTP, and a recreational experience
cannot be underemphasized. Selection of a Long Island option will eliminate
Long Island as a viable and attractive centerpiece for the Harbor Islands
State Park.
6. Section 4.3 - Mitigating Measures
The discussion here and elsewhere Is weak, and assurances of implementa-
tion are lacking. No attention is paid to mainland facilities associated with
barging. Of particular note Is the simplistic treatment In this section of odor
potential (11.3.3(3), pg. 4-93).
. 7. Section 4.3.5 - Engineering Considerations
The "Future System Expansion" section should recognize provisions of the
MWRA legislation. The EIR/S, as pointed out above, should be much
stronger on measures to reduce the site of harbor-side facilities, obviate
the need for future expansion, and conserve water resources.
As pointed out above, the site-specific Implications of overflows and bypasses
are not delineated.
8. Section 4.3.6 - Financial Impacts
There Is a suggestion of some form of compensation payments, certainly a
desirable approach. However, the feasibility under MWRA or otherwise is
not examined ("Implementabillty* question).
9. Section 4.3.7 - Visual Quality
This section conflicts significantly with the site-specific impact analyses
elsewhere In the report. The first paragraph Is best described as "polly-
anna-lsh". The real feasibility of minimizing visual Impact for each alterna-
tive must be clearly" set forth In the Final SDEIR/S.
10. Section 4.6 - Unavoidable Adverse Effects
No mention is made of the Irreversible commitment of additional resources
for construction and operation of secondary as compared to primary treat-
ment facilities. These Include construction materials, labor, and energy;
but most importantly the Irrevocable commitment of at least 50 acres of
precious harbor Island and an unknown commitment of lands and other re- •
sources for sludge management.
The last line on p.4-107 Is an Insult to reason and Intelligence.
E. Chapter 5, Unresolved Issues
I. Section 5.1
Strong exception Is taken to the position that these "unresolved issues"
"do not have the potential for affecting the location or other pertinent
siting characteristics of these treatment facilities", as has been pointed
out above.
2. Section 5.2 - Sludge
The alternatives are in part unrealistic. That site-specific differences exist,
potentially affecting the MWRA siting decision, has been pointed out. That
off-site options for sludge management may exist remains to be established.
3. Section 5.3- Mainland Facilities
This section correctly (pg. 5-4, top) expresses reservations about the
feasibility of a site or sites, and cursorily recognizes potential generic
Impacts. The problem is too critical to mitigation, and therefore to "Imple-
mentability", to receive other than the fullest treatment.
4. Section 5.6 - Growth
The discussion of growth, and of "satellite" facilities. Is generally sound.
However, there Is considerable evidence to question the assumption that the
High Level Sewer can In the forseeable future handle peak demands without
Interfering with Milton/Quincy access to It, even with an aggressive I/I
program. Conversely, were that program successful, much of the apparent
need for infrastructure improvement would be obviated.
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The focus on the SMSD, while reflective of the DEQE focus to date, needs
to be changed to encompass the entire system.
F. Coordination
The statements regarding the role and Impact of the Technical Advisory
Croup are misleading. This group met only a few times, and has not met nor
been consulted since late summer 1984.
C. Chapter 9 - Legislation
The MWRA legislation (Ch. 372. Acts of 1981) must be Incorporated. The
Mass. Clean Water Act and other Massachusetts water quality legislation should
also be Included.
H. Chapter 11 - Permits and Marine Resource Impacts
1. Checklist
There Is no basis, from any of the layouts, for Including the Winthrop
Conservation Commission In Item 3.
Item 7 appears to be an overly broad statement of the responsibility of DEM
(See 12.11)
There should be an Item 16 discussing the provisions of Ch. 372/1984 relative
to the exercise of eminent domain.
2. Section 11.2
The comment (pp. 11.2-12, 13) concerning construction of an offshore
island Is most unrealistic and. In addition, would greatly affect the placement
and functioning of a diffuser. It would be appropriate to utilize tunnel and
dredge spoils, and demolition debris, for berro construction.
3. Section 11.3
Were EPA's contention concerning the restricted basis for a Section 301 (h)
decision realistic, then this section would be of no consequence. It is In
significant part a comparison (misleading) of the relative effects of primary
and secondary treatment. The baseline report, as indicated above, has
little relevance to siting decisions except with respect to emergency bypasses.
It Is clear that the impact of well-diffused primary effluent on harbor water
quality has not been established as adverse.
To the contrary, the assumption about the effectiveness of a secondary
treatment plant of this site, treating MSD wastewaters. Is unsubstantiated.
If an effective pretreatment program is assumed, it is probable that the
primary options have significantly less adverse water quality Impacts than
the secondary options. Conclusion (1) under "A. Quality of Effluent" on
page 11.3-3 Is unwarranted based on evidence included in the SDE1R/S.
The comments relative to metals and other toxins would be irrelevant in the
presence of an effective pretreatment program. There is need to compare
primary/secondary treatments effects on removals compared to pretreatment
to assess the Implications for sludge management and, therefore, for
facility siting.
The comment under B.3 on pg. 11.3-4 raises the question of potentially
greater cost* than projected for secondary treatment. Further review and
clarification Is essential.
The presentation In Figure 11.3-1 Is sorely Inadequate.
Given the options under consideration, conform reduction efficiencies
(Table 11.3-2) are Irrelevant to (1) • choice between levels of treatment
and (2) siting. The estimate for BOO removal by secondary treatment, for
this situation, should be questioned (see note 1, pg. 11.3-11). The foot-
notes to Table 11.3-3 Indicate the "median t removals" presented for
secondary treatment plants, in Table 11.3-9, are not meaningful.
In Table 11.3-10, It should be made clear that the dilution needed for
•chronic" criteria should be compared to the average dilution obtained with
a specific alternative.
On page 11.3-19, the last sentence of the first paragraph suggests a further
disadvantage to a secondary treatment facility with discharge as proposed.
The data of Petrasek etlal should be evaluated to establish relevancy.
In Table 11.3-16, trials i8-JO appear Irrelevant to the situation.
The observation, on pg. 11.3-29, concerning chtorlnatton and long outfalls
should bo combined with tha footnote under Table 11.3-3, and the whole
Issue of chlorinatlon of primary final effluent reconsidered.
The comments under 11.3.6 reinforce earlier comments about the site-specific
Impacts of such discharges.
Chapter 12 - Baseline Environmental Reports and Impact Analyses
1. Section 12.] - Land Use and Demographics
Relocation of the Deer Island prison to some site other than the Harbor
Islands would represent a substantial form of compensation to the Town of
Winthrop In the event that the decision were made to locate an expanded or
upgraded treatment facility on that Island. It should be pointed out that no
comparable opportunity for compensation of any other potentially affected
community Is available.
The statement (pg. 12.1-3) concerning the position of the City of Boston
concerning future use of Long Island Hospital should be checked to assure
that it accurately and fully reflects the position of that City on this very
critical matter.
It is noted that establishment or expansion of treatment plant uses on either
Deer or Long Island would require a use variance from the City of Boston
with respect to the question of implementabillty. The city's position with
respect to such a variance, and the tests that would have to be met to obtain
It, should be specified.
The statement on pg. 12.1-6 concerning Impacts to residents of the Point
Shirley area of Winthrop by Logan Airport operations, the presence and op-
eration of the Deer Island House of Correction, and the emissions from the
current MDC wastewater treatment plant are correct Insofar as the statement
extends. As indicated elsewhere In these comments, the appropriate manner
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of and responsible entitles for addressing these Impacts Is a subject for
careful consideration. As posed In the EIS/R, It would appear to be sug-
gested that certain residents of the City of Qulncy. and users and potential
users of the Harbor Islands State Park facilities, would be asked to pay a
price In recognition that other entitles, not under their control, (the Massa-
chusetts Port Authority and the City of Boston) have through their activities
Imposed burdens on certain residents of Wlnthrop. Question arises "Is that
fair?".
The question Is raised elsewhere about the procedures and criteria that
were used In deriving the population figures presented in Ch. 4 for the
•affected neighborhoods*, when the data base Is the 1980 census and the
census tracts. At this point It Is appropriate to point out that the Squantum
Naval Air Station area of Qulncy Is under development and. unlike the
Point Shirley and Hough's Neck areas, has the capacity to absorb substan-
tial additional populations. This should be factored Into the derivation of
population figures for that particular neighborhood. It Is also appropriate
to point out that the facilities on Moon Island and the uses of that Island.
described on pg. 12.1-7. have through their presence and their discharges
over the century or more of their existence had adverse impacts on Squantum
(which continue).
There are. In figures 12.1-8 and 12.1-10. certain errors In symbols which
should be corrected.
It Is unclear why some of the breakdowns of census data which are used
should be relevant to a siting decision. It would be helpful If the writers
of the document could point out the ways In which they feel that age, family
type, school enrollment. Journey to work, etc., are significant.
This section Is less than rigorous in Its utilization of the data. In some cases
It has been adjusted to the "affected neighborhood*. In other cases the en-
tire census tract totals are used. That Inconsistency makes comparisons,
assuming that the data is useful to the decision and that comparisons are
valid, not useful.
The statement Is made on pg. 12.1-15 that the proximity of Point Shirley to
Logan Airport and Deer Island "tends to supress house values". We are
aware of numerous inconclusive efforts to establish the Impact of environmen-
tal variables upon the value of housing stock. The statement should be
buttressed by evidence concerning the supression of value; and If that is
established, the "social impacts" of that effect should be described in ways
that do not constitute merely opinion.
2. Section 12.2 Traffic and Access
This section clearly establishes that good access Is not available by land to
any of the proposed alternative sites. It makes abundantly clear that barging
of construction materials will be a very Important mitigation measure, and
renders more critical the clear establishment of the feasibility of such barging
and the Impacts of that activity upon proximate mainland areas. It also
establishes in our opinion that barging of chlorine as an operational practice
should be instituted as a measure to mitigate both trucking Impacts and the
fear In the community of leakage of this hazardous material.
While it Is difficult to asses* the safety Implications of heavy trucks transiting
narrow residential streets, the EIR/S seems to Identify unique safety prob-
lems with the last stages of the land access through both Squantum and Hough's
Neck, end the Impracticability of correcting either situation. By contrast.
although no one would argue that any level of construction traffic to any site
will be without Impact, the document establishes that the low level of traffic
remaining after mitigation measures are effected will have but a small Impact
on Wlnthrop.
The lengthy discussion of alternative methods. Section 12.2-2. Is deficient
because It fails to evaluate specific site options for mainland terminals and
to assess their environmental Impacts. There are some obvious possibilities
with potentially lower Impacts than those mentioned, which have-not been
described. The discussion of bussing of workers makes the inappropriate
assumption that workers might have to be paid for bussing time. It also falls
to sufficiently stress that ('walk-ons" of construction workers to the jobsite
can and should be strictly prohibited.
Table 12.1-2 suggests the same period of construction time for trucking
activities for both primary and secondary facilities, which seems Inaccurate
based on the remainder of the document.
On pg. 12.2-18 It Is suggested that traffic on difficult or proscribed sections
of truck routes could be monitored by traffic control personnel. The mitiga-
tion measures, as was the case during the Southeast Expressway construction,
should Include direct compensation to the affected municipality for that purpose.
On the same page the use of Qulncy Shore Drive for truck traffic is discussed
and It is suggested that the MDC might be amenable to a change In restrictions
for the construction period. This, given that that period Is six to seven years.
should be explored with the MDC. who's preliminary response should be.incor-
porated to the document.
The description of roadways and roadway conditions for the Deer Island
alternative is much more comprehensive and detailed than for either Nut Island
or Long Island alternatives. This Imbalance should be corrected.
It Is noted on pg. 12.2-17 that the impact on Point Shirley of 8 trucks per day
Is described as a "moderate* Impact whereas on pg. 12.2-22 the impact of
•-8 trucks per day on the Hough's Neck Is described as a slight impact.
despite the more difficult and more extended residential portions of the Nut
Island access route.
Major efforts and measures should be undertaken to mitigate the effect of
operational traffic through Wlnthrop. As mentioned above this should include
consideration of the barging of chlorine, fuel oil, and other bulk commodities
needed for the operation of the facility. Certainly any movement of sludge or
ash away from the Island should not be by road through Winthrop. It would
seem quite feasible to bus employees of the MDC and employees of the Boston
Penal Department to the treatment plant and the House of Correction under
normal circumstances, using one of the blue line parking lots as the transfer
point. Several additional measures could be taken to mitigate the impacts of
Deer Island prison on Point Shirley. Changes in alarm practice, improvements
in security provisions, and other improvements to access means and access
control for employees, visitors, and inmates should be considered.
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Table 12.2-3 shows an existing bus trip every 20 minutes under the column
headed "Nut Island*. However the text points out that this bus traffic
proceeds only to the Intersection of Sea Street and Sea Avenue, and there-
fore does not Impact the Great Hill section of Hough's Neck.
Table 12.2-* appears to contain an Inconsistency In the maximum dally staf-
fing shown for option 4a2 compared to that shown for option 5b2.
3. Section 12.3 Recreation Resources and Visual Quality
This Is a very valuable and useful section, of great Importance to the decision
making process. Speclar attention should be paid to the anticipated visitor
capacity and visitor load for Lang Island as an element In the Harbor Islands
State Park.
The Inclusion of the highly speculative 1972 Deer Island plan, on pages 31
and 32, Is out of context with the generally accurate and factual presentations
In this section.
a. Section 12.4 Engineering Cost Estimates
The acreage requirements and costs presented In Table 12.4-1 and used
extensively elsewhere In this report should be reviewed In the light of com-
ments made elsewhere concerning the lack of comparability of the options
described, the Inconsistent Inclusion In some cases of sludge handling facili-
ties, and the treatment of existing facilities' useful life spans.
The comment on pg. 12.4-7 concerning the failure to consider an Intermediate
level of treatment was apparently the result of the failure of the MOC to in-
clude such a proposal In Its delineation of "preferred options". As argued
(above), because the MWRA rather than the MDC is now the decision making
authority and will be the applicant for any permits or grants associated with
these projects, and because the MWRA should not be considered a successor
In Interest to the MDC's "preferred options*, this matter should be referred
back to the MWRA for determination as to whether an Intermediate level of
.treatment should be proposed. This action would also be highly germaine to
the relevance of the MDC's 301(h) application.
While the efforts of the EPA contractor to establish a valid cost estimate for
secondary treatment tanks is appreciated. It would seem that the resolution
of such a significant disparity in a major cost item should have been by the
preparation of detailed design and construction specifications and the solici-
tation of cost estimates from several competent contractors; rather than
attempting to derive costs from facilities serving the same purpose but of
significantly different size.
The inclusion by error In Table 12.4-4. under option 2bl. of a second "Deer •
column Is noted.
With respect to the costs of chlorination. the EIS/R provides sufficient
speculation concerning the necessity for chlorination of primary effluent
discharge through long outfalls to warrant consideration of the acceptability
and cost Implications, as well as transportation and safety implications, of
elimination of post-chlorinatlon of primary effluent.
On pg. 12.4-27 In sub-section 5.4 there Is • purported Justification for Ignor-
ing the value of existing facilities which can be Incorporated Into new facilities
and which posses significant remaining llfespans. This (unification Is con-
sidered to be faulty. It operates to bias cost estimates In favor of newly
created facilities, and should be changed. It does not appear from Table 13.1-5,
that the statement In the last paragraph on pg. 12.4-27 Is correct.
Table 12.4-5 has been commented on elsewhere. Table 2 of these comments
compares the costs of treatment facilities to the cost of tunnels and outfalls
for each of the options"! Comments elsewhere point out that sludge handling
facilities are Incorporated In the cost estimates presented in Table 12.1-5
for each option, but the layout plans for options 2bt and 2b3 do not show
thickeners, digesters or gas storage at Long Island. The layout plan for
option la2 (only) shows a floatation thickener facility on the layout plan,
which Is not Included In the cost estimate. The statement on pg. 12.4-34
(first paragraph) concerning Inclusion of preliminary costs of sludge handling
appears In error.
5. Section 12.5 Financial Impacts
As pointed out elsewhere In these comments, the use of a 20-year operational
period for the proposed facility (pg.12.5-2) Ignores the substantially greater
life (by • multiple of 3 at least) of the proposed tunnels and outfalls associated
with each option, and therefore significantly skews the estimated cost of opera-
tion, maintenance, and replacement of facilities, with a strong bias against
the primary treatment options. This element of the EIR/S should be redone
throughout, with revised presentations reflecting the real life expectancy of
those facilities. This will require significant changes to cost estimates pre-
sented In all portions of the report.
As stated elsewhere, we take strong exception to the statement (top of
pg. 12.5-4) concerning comparisons between primary and secondary options.
These options should be compared and the decision made as to level of treat-
ment required, based on an overall and comprehensive and environmental
Impact assessment of the two levels of treatment, with potentially an inter-
mediate level also Incorporated.
This assessment must consider water quality Impacts at all points of proposed
discharge and compare those impacts; It must consider the Impacts upon land
use, recreational potential and construction activities In the Boston Harbor
area and upon the affected neighborhoods; it must take Into account the time
span required for and the Implementability for each alternative, with careful
attention to the impacts of "mitigation measures" upon other areas; and,
very importantly, must consider the operational and environmental feasibility
and Impacts of the sludge management decisions and activities which necessarily
follow the level of treatment decision.
The entire sub-section on financial Impacts on users Is erroneous and mis-
leading. If costs to users are to be presented, they must Include the entire
cost implications of the total harbor cleanup program of which this siting
decision Is a part. The City of Boston has produced and released estimates
of these cost burdens which are significantly different from those presented
In this report. A special task group should be convened forthwith to consider
the appropriate resolution of and presentation of the cost implications of
Boston Harbor cleanup and this element thereof.
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The section titled "MDC Management Structure and Administration' (begin-
ning on pg. 12.S-19) must be completely redone to reflect the MWRA legisla-
tion, the Interim rate study performed for the MWRA. and the MWRA decisions
being taken at this time concerning changes In rates.
6. Section 12.6 Noise Analysis
While the noise analyses for the different areas employed different techniques
and procedures and thus are not strictly comparable, certain general conclu-
sions can be drawn. Table 12.6-1 appears to show no noise Impact from the
current Deer Island wastewater treatment plint operations on the Point
Shirley area. The assumption that electric motor noise will not be a problem
to any neighboring municipality, however, requires the assumption that
characteristic motor whine can be effectively muffled.
The reliance on the noise regulation of the City of Boston as opposed to those
of the Commonwealth Is appropriate and should be continued.
The assumptions that construction noise can be sufficiently mitigated so as
to not have significant adverse Impacts upon 1) the Hough's Neck area,
2) the Long Island Hospital and. 3) the Deer liland House of Correction.
should be substantiated by measurement In the real world of actual construc-
tion operations of the types that would be employed for these facilities to
determine whether the assumed noise reductions can In fact be attained by
present practices.
The allusion to the need for "special mitigation measures" at Long Island
Hospital should be buttressed by evidence that such measures are available
and estimates as to their Incremental cost.
The Idea presented on pg. 12.6-20 that Hough's Neck homes might be taken
to compensate for the failure to establish adequate noise control measures
during construction and operation. Is ludicrous.
Under Section 12.6-5 Mitigations. It should be stressed that the proposed
use of noise mufflers and less noisy equipment would be most critical for
construction and operation on Long Island.
7. Section 12.7 Odor Analysis
It Is questioned whether new treatment facilities per se will affect the septl-
clty and therefore the odor generation potential of wastes from the South
Metropolitan Sewer District.
The EIS appears to conclude that diesel engines will not be used as power
sources for any new facilities. Since the facility plans have not been devel-
oped, it is not clear that this is a supportable assumption.
The equation of odor Impacts on Deer Island Prison and Point Shirley popu-
lations with Impacts on Long Island Hospital and visitor populations at Long
Island Is totally unwarranted. The latter impacts, for any given level of
odor release, will be significantly greater because of the nature and sensiti-
vity of the populations, the nature of the recreational experience presumed
for Long Island, and the prevailing wind directions. The distance factors
are also not comparable.
I. Section 12.9 Sludge Disposal Overview
As stated elsewhere, we emphatically disagree that the siting and sludge
management decisions can be disassociated and that one will not affect the
the other. Composting facilities cannot be accommodated on site at Deer
Island or at Long Island without various substantial and differential In-
creased Impacts. The comparative siting advantages and disadvantages
would be affected.
9. Section 12.10 Archaeological and Historical Resources
This section and Its findings and conclusions, strongly and adversely
affects the •Implementablllty" of the Long Island options.
10. Section 12.11 Legal and Institutional Constraints
This section must be reviewed and revised to reflect the enactment of the
MWRA legislation. One major point is the substantial limitation Imposed
upon that authority with respect to the exercise of powers of eminent domain.
Another question that should be analyzed relates to the title and ownership
of present and future real properties of the sewer system.
The Jurisdiction of DCPO In light of the MWRA legislation should also be
reviewed.
11. Section 12.12 SDEIS Screening Report
The decision to exclude the "all primary* Long Island option is correct for
all the bases cited. The decision thereafter to Include secondary options
on Long Island with substantially greater Impacts strains credulity. All
of the Long Island options should be Judged against the same set of criteria
with respect to screening, and In addition to the feasibility of relocation of
the Long Island Hospital should be a part of the screening process judgement.
The attempt to disengage and disassociate the critical decisions concerning
level of treatment, sludge management, siting of facilities, and priorities affecting
harbor water quality Is environmentally and economically unsound. If successful.
It will severely Impact the Implementablllty of siting decisions, assure the commit-
ment of time and resources to litigation, and misallocate scarce funds.
The SDEIR/S makes of Its own weight several very significant matters quite
apparent.
°Nut Island is the least acceptable of the several sites, from "neighborhood
Impact" and feasibility standpoints.
"Long Island Is not acceptable as a site on the basis of implementability. cost.
environmental and archeologlcal effects, and Impacts on recreation potential.
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(-•
MD
Ul
There are • number of shortcomings In the documents which must be cor-
rected before It will be useful to the MWRA as a decision guide.
Submitted to the Regional Administrator
US Environmental Protection Agency
for and by the direction of the City of
Qulncy. Massachusetts
McCrath, Sylva and Associates, Inc.
by David Standley. Associate
March 14. 19SS '
Option
Sec. Treat.
la]
(all 01)
1b2
(Split Plr)
(Sec « 01)
2bl
(all LI)
2b3
(Prl. «DI)
(Prl/Sec 0 LI)
TABLE I
Comparison of Sludge Progressing Facilities by Option
Digesters (6 0 Dl)
Crav. Thick (6 0 01)
Plot. Thick 8 Dl
D C Cas Stor. 0 01
Digesters (4 8 Dl. 4 (exist) 0 Nl)
Crav. Thick (S SDI. 2 0 Nl)
Plot. Thick C Dl)
DC Cas Stor. 8 Dl
No Digesters.' Thickness, or gas storage
Digesters (4 8 Dl. none 0 LI)
Crav. Thick (5 8 Dl. none 0 LI)
DC Cas Stor. 0 Dl (none 0 LI)
4b2
(DI/NI)
Sa2
(DI/LI)
f
5b2
(all LI)
Digesters (8 ODD
Crav. Thick (6 001)
DC Cas Stor. (2 0 Dl)
Digesters (« 0 Dl. « (exist) 0 Nl)
Crav. Thick (5 001, 2 0NI)
DC Cas Stor. (I 0 Dl)
Digesters (« 001, 4 0 LI)
Crav. Thick (5 0DI. 2 0 LI)
DC Cas Stor. (I 0OI. 10 LI)
Digesters (4 0 LI (large)) \
Crav. Thick (2 0 LI) I
DC Cas Stor. (I 0 LI) I
(Derived from Layout Plans; Figures 4-2 to 4-24)
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TABLE 2
K>
I
a\
Comparison of "Treatment" Costs vs. •
Option
1a2
1b2
2b1
2b2
«.2
toJ
5a2
Sb2
Total
$600m
650
710
7 1)0
750
810
B20
870
Outfall /Tunnel" Costs
Treatment
»*70m(78%)
520
500
530
190
250
260
2*0
(80%)
(70%)
(72%)
(25%)
(31%)
(32%)
(28%)
Out fall /Tunnel
$130m
130
210
210
560
560
560
630
(Derived from Table 12.4-5)
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JOANNE CONDON
COUNOLlOn - WAMD •
March 7. 1985
Quincy Bay is dying. It is dying not from neglect,
not from the effects of a distantly originating acid raid,
not because of oil spills, nor private dumping of industrial
waste. Quincy Bay is dying because of the wanton disregard and
the active and inadequate disposal techniques of our own state.
Because of an incapacity to handle industrial wastes common to
the system; because of an incapacity of the system to handle
the sewage volumes: because of an inability to handle sludge.
We are witnessing our state destroy our city's most important
natural resource.
No longer is it safe to eat our fish and no longer
can our children swim without fear of contamination for E
Coli bacteria or some amorphous, but perhaps more deadly,
industrial waste. And yet, the proposals are forthcoming --
take homes; fill more Bay; construct facilities; Long Island;
Nut Island. And what is the bottom line? The bottom line is
more sewage and more industrial waste for Quincy Bay.
We, in Quincy, have had enough. We are sick of
bearing the brunt of Metropolitan Boston's sewage problem!
We are sick of the pollution of our Bay! We are sick of not
being able to fish our shores! We are sick of sludge in our
waters and not being able to use our beaches.
Joanne Condon
March 7. 1985
Page 2
Our complaints, for years, have fallen on deaf ears.
However, when a response is finally made, that response entails
more pain for Quincy and does not look to solve the problem.
We are confronted with more Bay fill and the taking
of our homes. But what is the solution for sludge disposition?
What is the solution for chemical wastes?- Why must Quincy
continue to bear the brunt of your inability to do your job
properly? Why must Quincy stand by and watch while you continue
to destroy our Bay?
We have had enough! We-don't want Long Island! We
don't want further Bay fill! We don't want homes taken, and
we don't want any further destruction of our Bay!
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QUINCY
ORGANIZATIONS
COMMENTS
2-198
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VO
vo
(« NAME IS PAT HIDLOI niJESlDEiTT III HOUGHS NECK/
AriD I AM EMPCOTBB-AS UIHIiCTOR~OF~THE~;IOUGIfS
-.COMMUNITY C2NT
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Comments Regarding The Supplemental Draft Environmental
Impact Statement/Report
March T, 1989
Page!
Comments Regarding The Supplemental Draft Environmental
Impact Statement/Report
March T, 198S
Page!
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The Treatment Plants Effects On A Community
The report doea not significantly address the real effects on the adjacent
communities. The terms they use to describe the Impacts are "Moderately
Adverse", or possibly "Severe". The authors of the report obviously do
not know what It Is like to live next to a Treatment Plant. I doubt If any
of them have ever been awakened on a summer night and had to shut the
windows because the odors emanating from the Plant make you sick. I doubt
If any of them go to sleep with the constant pounding of Diesel Generators
In the background. I doubt If any of them can see the effluent streams
moving through the West Way. The balls of grease and Tampon applicators
end up on beaches, t doubt If any of them live on an access road where
trucks carrying liquid chlorine pass In close proximity, thus endangering
their families lives and welfare. What would happen if a chlorine truck
had an accident and the 16-ton truck was ruptured?
Unchecked Community Expansion
We recognize the fact that the present harbor facilities are old and
Inadequate, but the report does not detail how the System got In such
bad shape. Why are contributing communities allowed unlimited conn-
ections without addressing the Impacts on downstream communities?
The population projections for the South System (data obtained from
the Metcalf and Eddy Site Options Study), shows that there will be
another 146,000 people connected to the South System In the year 2010.
When will we start correcting the problem at It's source and stop building
bigger pipes and bigger Treatment Facilities?
In conclusion, I am convinced that the State and Federal Agencies have the
Harbors best Interest In mind, but we cannot under any circumstances be prisoners
of the past. There Is a tendency on the part of our society to do things the way
they were done In the past - under the premise that the "old ways are better". We
made • lot of mistakes during the early development of this area and we must now
begin to correct them.
The time has come to exercise the basic civic values of right vs. wrong. How
can the Department of Environmental Management or Coastal Zone Management
suggest they are honestly concerned about the effects on a possible recreational
facility and not give a damn about the same effects on a close knit and established
community? Underno circumstances should we protect any site - and thereby allow
It to be exploited by those who are merely concerned about their potential monetary
gains. We all must realize that the welfare of an the people must be our supreme law.
We are now trying to correct for the erroneous decisions of past generations.
We should evaluate why this has been allowed to happen and then put a-plan In place
that will provide an equable and permanent long range solution.
Reflecting on the damage we have done to the harbor, we must begin to transfer
some of the burdens of a treatment facility back to US origin. Nut bland was a mistake
from It's conception. Now Is the time to admit our mistakes and embark on a project
that will provide for an environmentally stable harbor without endangering the health
and welfare of It's host communities.
Sincerely,
Now, what are the realistic options that are available?
A. Nut Island Is only a 17-acre site vs. a 210 acre site at Deer Island and
a 213 acre site at Long Island. Does It make sense to fill the Bay or
take homes by Eminent Domain In the light of the fact that there Is
so much land available elsewhere?
Jack Walsh
Chairman, Nut Island CAC
At the present Nut Island site, there Is no separation between residential
property and a major Treatment Facility - compare that to approximately
1/2 mile at Deer Island and over 1 1/2 miles at Long Island.
If we are going to be truthful with ourselves and honestly evaluate the sites
based on proximity of neighbors, noise, odors and size of sites, there is no possible
way the nut Island site can be considered reasonable. I sincerely believe that all the
proposed sites do not have equal Impacts on adjacent communities.
/mmm
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fieck (Hammunitg (Center
1193 SEA STREET
QUINCY. MASSACHUSETTS 02169
TELEPHONE 471-8251
Francte X. McCautoy
Mayor
Juno E. Lydon
Olr*cur
ChariaiM H. Wantworttl
Coordinator
(iernumiafem .Neigljbarljoah Center
333 PALMER STREET
QUINCY. MASSACHUSETTS 02169
TELEPHONE 328-5733
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March 7, 1985
4HEREA5 THE COMMUNITY OF ROUGHS UECX A>ID ALL OF QUI:1CY .IAS "
PUT UP WITH THE JHELL A1JD POLLUTION OF OUR 3AY FOR DECADZS ADD
rfHERiAS THERE. ARE FORTY-TUBES COMMUNITIES IN THE SE/JER SYSTEM AND
JHSREAS THE SYSTSM HAS A CONSISTENT RECORD OF FAILURE AND
WHEREAS RA* SZMERAG2 FROM TIIE FORTY-THREE COMMUNITIES
IS DUMPED INTO THE 3AY UNTREATED AND
.MEREAS TRZ HOUGHS MECK COMMUNITY COUNCIL IS A VOICE OF TH3
aEjID3NT3 OP -IOUG.IS ll$CX THEREFORE:
3J IT RESOLVED THAT dE, THE EXECUTIVE 3OARD OF THE HOUGHS NECX
COMMUNITY COUNCIL ME3TING AT THE HOUGHS NECK COMMUNITY CENTER ON
TUESDAY, MARCH 5. 1985, STRONGLY URGE THZ FEDERAL E.P.A., ALL
STATo ENVIRONMENTAL AGENCIES AND EV2RYONE CONCERNED, THAT T.IE
TAXING OF HOMES AND LANDFILL OF OUR 3AY IS UNACCEPTABLE.
AND, BE IT FURTHER RESOLVED THAT A IISAD.VORXS AT NUT ISLAND JE
T:iE ONLY ACCEPTABLE ALTERNATIVE.
DANIEL A. BYTHROW
President,
HOUGHS NECX COMMUNITY COUNCIL
DAB/psr
March 7, 1985
Mr. Michael Keland, U.S.E.P.A.
J.F. Kennedy Building
Boston. MA 02203
Dear Mr. Keland:
I represent the Gennantoun Neighborhood Council. This council was
founded for the following reasons:
1) To develop a sense of commlty and community
pride among the residents of Germantown.
2) To act as a voice for the people of Germantown
to the larger communities of which Germantown
Is a part.
3) And to serve as s representative body to represent
and promote the Interests of the people who reside
and/or work In the Germantown section of the city
of Qulncy.
We too will be directly effected by whatever decision you make:
I have read and attempted to understand the proposals In your draft,
but nowhere do I see any statistics on what the other communities are
going to lose or what hardships they will endure while you possibly
take ten (10) families' homes, possibly fill In our bay and In general,
disrupt the quality of life In our communities. The final result,
ten (10) years down the road, will still be bad odors, possible over-
flows and not a clean bay.
You have pitted city against city (meaning Ulnthrop against Qulncy)
In a poor attempt to clean up the bay.
The best way to make a positive atep forward In correcting this mess
is to stop dumping anything Into the bay. Treat the sewage at Its
source. Make the other communities responsible for their own sewage.
We want, and desperately need, treatment at the source in each
community. We want our baya saved from this disease which Is. killing
It.
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Manet Community Health Center, Inc.
We have.been paying the dues for ell surrounding connunltles for
years. Isn't It time for those coonunltles to pay their own dues.
I leave you with this one lest thought:
Quincy Is known to be the "City of Presidents" and Houghs Heck Is
known for Its Flounder Fishing. It la sad to say they are now known
for "Nut Islsnd", the reason the bay no longer la overflowing with
flounder, the reason for bad odors, no •winning, and laat but not
least "Sludge".
Sincerely,
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10
_
Ann-Maria Noyes. Chairperson
Community Issues
Roger Halklns, Chairman
Germantown Neighborhood Council
AN:RH:bh
. MA 01169
471-S6IJ
9 Blthuit Strut
Quint*. MA 01169
471-4711
March 11, 1985
Mr. James Hoyte
c/o MEPA Office
Executive Office of
Environmental Affairs
100 Cambridge St.
Boaton, MA 02108
Dear Hr. Hoyte,
I am writing to you in regard to current public hearings about
siting of waste water treatment facilities in Boston Harbor. I am
the medical director of the Manet Community Health Center in Quincy.
The health center is located on Houghs Neck in close proximity to
the Nut Island sewage treatment plant. Me provide medical care to
a large percentage of Houghs Neck residents.
I am very concerned about the possibility that the Nut Island
sewage treatment plant may be expanded. Many previoua studies have
docuaented the presence of bacterial contamination in Quincy Bay.
Research has also shown that people who swim in polluted water have
increased incidence of gastroentestinal disease. This was detailed
in an EPA technical report IPB63-2S9994. According to Dr. Hillel
Schuval, a world expert in waste water management and a visiting
professor at the Harvard University School of Public Health in 1984,
it has also been demonstrated that viruses and bacteria from pol-
luted water can be carried into the air by droplets. Therefore,
people who live by the polluted water may be at risk for increased
gastroentestinal infections even if they do not swim in the polluted
water. Although this has not been scientifically proven yet, I
fear that increased contamination of Quincy Bay with bacteria and
virus would place my patients at higher risk for gastroentestinal
and other infections.
In summary, as a primary health care provider to Houghs Neck
residents, I thank you for reading my concerns about expanding the
Nut Island sewage treatment plant.
Sincerely,
cc: Hr. Michael Deland
FCD/cam
Frederick C. Oolgin, M.D.
Medical Director
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ROMA W. GOODMAN
ATTOftNKV
4*» WASMIMOTON I
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Narch 8. 198S
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Mr. Michael Deland
Region*! Administrator
U.S. Environmental Protection Agency
22nd Floor
John F. Kennedy Building
Boiton. HA 02203
RE:
SOEIS on Siting of Wastewater Treatment
Facilities In Boston Harbor
Dear Hr. Oeland:
Squantua residents turned out en masse at the public hearing
on March 7 to protest consideration of Long Island as a sewage
plant site. As you know. Squantum provides the sole land access
to Long Island. It Is the community which would be most severely
Impacted by a treatment plant on Long Island.
He bel leve that your choice of sites has come down to Long
Island versus Deer Island because of the many problems with a Nut
Island site. He In Squantun agree that Nut Island Is the wrong
site for any sewage plant. These problem were elegantly
addressed at the public hearing on March 7. 198S by other
speakers.
Therefore. In this letter, we would like to compare the
Impacts of the Deer Island site v. Long Island. As you can
guess, our position Is that, Long Island Is the wrong site for a
sewage plant, especially a secondary treatment plant. Where do
we get the proof of our position? From the SDEIS signed 12/84 by
you.
Initially, there were four alternatives Involving Long
Island. One was all primary treatment on Long Island. Your
SDEIS eliminated that alternative, but kept open secondary
treatment options on Long Island as well as a split Long
Island/Deer Island primary treatment option. For the reasons
stated In your report that you eliminated the Long Island primary
treatment option, you should eliminate the Long Island secondary
treatment options as well.
In the report, you state: *A1_1_ Primary Long I_sl__and -
suffered from compelling d1sadvantages~compared to other prfmary
treatment options." Secondary tratnent on Long Island has even
more compelling disadvantages.
o You found that "The legal and Institutional obstacles to
siting a larger (approximately 52 acres) primary treatment plant
on Long Island would be formidable and perhaps 1 nsuroountabl e"
(Underlying added for emphasis). For a secondary treatment plant
82 to 96 acres), these same legal and Institutional obstacles
would be more formidable and perhaps more Insurmountable.
o You found that "A large primary treatment plant on Long
Island would have an adverse Impact on the State Park now planned
by Massachusetts DEM for that Island." With a secondary
treatment plant the park would not be likely.
o You found that "A large primary treatment plant would
cause significant disruption to many natural and cultural
resources which are located there." Again, a secondary treatment
plant would be worse. I might add. these cultural resources
Include materials from several thousand years of prehistoric
occupation - the oldest within the Harbor Islands and the City of
Boston, not just another colonial mansion.
o You found that "A large prlaary treatment facility on
Long Island would Impact the sensitive population of the adjacent
Chronic Disease Hospital." A secondary treatment plant would
require the relocation of the hospital altogether.
o You found that "A large prlaary treatoent plant would be
from $56 million to $120 million more expensive to construct than
the other three primary options being considered." Secondary
treatment plants on Long Island would cost $110 to $143 all lion
•ore than the All Deer Island Alternative, and that does not
Include the cost of moving the hospital.
Despite your own words, you held onto the Long Island site
choice for a secondary treatment plant because you found "There
RECEIVED-
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may be gretter difficulties In siting t 115-acre secondary
treatment plint on Deer Island.*
He do not deny these difficulties: the point Is. based on
your own SDEIS none of your plans which require secondary
treataent are satisfactory. As was suggested over and over again
at the public/hearing on March 7. 1985. one solution was to go
back to the drawing board' and come up with a plan for
subreglonal treataent.
A second solution would be to waive secondary treatment
requirements. He do not believe. In any event, that secondary
treataent with an outfall In Boston Harbor will Improve water
quality compared to primary treatment with a deep ocean outfall.
We already know that with such a secondary treataent plant.
In the event of any breakdown, the harbor will once again be
filled with raw sewage. He already know that the secondary
treataent systea, as now designed, will In fact break down every
tlae there Is a heavy rain because the proposed treataent plan
does not solve the Infiltration problea. Even without heavy
rain, breakdown aust be anticipated with a secondary treataent
plant because a secondary treataent plant Is expensive and
technically difficult to aatntaln. Institutionally,
Massachusetts has provided alnlaal dollars and personnel for
sewage treataent. These Institutional probleas have not and
perhaps cannot be solved, and as a result. In the long run,
additional sewage plant breakdowns aust be anticipated.
Further, we suspect that the technical advisor. C.E.
Magulre, has no evidence that a secondary treataent plant of this
size will work. Weeks have passed since the E.P.A. was asked at
a public Information session about the existence of other
treataent plants of this proposed size, and the E.P.A. has
refused to date to answer this question.
Water quality aside, the draft evlronaental tapact report
appears Incomplete with respect to secondary treataent Impacts
because It does not describe disposal aethods for the resulting
sludge. How can the lapact of a secondary treataent plant be
evaluated If the sludge disposal plan 1s unknown!
The other Long Island choice Involves split primary
treataent on Long Island/Deer Island. The problea with this
choice Is that although It has moderate Impacts on Long Island,
It provides no real benefit to Oeer Island. For exaaple. only 10
additional acres of Oeer Island are saved. You found that 'The
siting of a 62-acre (or 52-acre) prlaary treataent plant can be
accomplished without significant adverse Impacts on
Htnthrop, provided that major mitigation measures required by
E.P.A and the Commonwealth are employed."
In closing. Squantua residents, like Wtnthrop residents and
Houghs Heck residents, are dissatisfied with all the choices you
have presented. If we must make a selection froa your awful
menu. the least distasteful site Is Oeer Island with prlaary
treatment only. Long Island should not be eaten up by a sewage
treatment plant.
Sincerely.
Rona W. fioodman,
Vice President
Squantua Community Association
RW6:ldt
Enc:
Councillor Michael Cheney
Mayor Francis X. McCauley
Councillor Patricia Toland
Commissioner Paul Anderson
Mr. Peter Koff
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SAVE QUR SHORES« INC-
Mr. Michael Deland
Regional Administrator
0. 8. Environment*! Protection
Agency - Region I
John T. Kennedy Federal Building
Boecon. MA 02203
P.O. BOX 1O3
NORTH QUINCY. MASSACHUSETTS
Kerch II. 1985
01171 SAVE 0UR SHORES. INC-
J1AR181965
Re: Supplemental Draft EIS/EIS (SDEIS)
Siting of Uastewater Treatment
Facilities for Boston Berber
Deer Mr. Deland:
Thle letter will lerve to supplement end expend upon teetlmony given et
recent public heerlnge In Cambridge and Qulncy.
Ae previously cautioned Save Our Shoree (SOS) wee formed In 1969 In
reaponee to e threat to deetroy the Bex ton Eerbor lelanda for a World'e Fair.
Throughout the yaere.SOS baa had ae lie primary focus the preeervatlon and
reetoretlon of Boeton Harbor. Ita Islands end foreehorei. It bed been our
goal to have the Boaton Harbor lelanda declared a Hetlonel Historical Monu-
ment to coincide with the Bicentennial. This, of courea, did not happen,
but w» are pleased that the Department of Environmental Management la formu-
lating plane to eee to it that theae lelende ere preserved.
In thet spirit, we strongly oppoee the destruction of yet another of
the Harbor Islands for a vaateweter treetnent facility. To use Long Island
for that purpose la a serious abuse of e resource which hss aesthetic, his-
torical, archeological end recreational value, not to mention the velue of
the chronic care hospital, and shelter for the homaleas. The value of thle
health cars facility cannot be diminished, and yet, the SDEIS aeems to do
Just that by continuing to Include Long Island alternatives es viable,
despite conclusions that "A...facility on Long Island would Impact the
eensltlve populetlon*..of the Chronic Diseese Hospital". There le e serious
shortage of care facilities of this kind, and to disregard the Impact to
employees, patlente end homeless Is unconscloosble.
Long Islsnd's rich historical and archeological value could also, per
your own report, present eome "formidable end perhaps insurmountable" legal
and inatltutlonal obeteclee, and yet, you etill hold onto Long Island as sn
alternative.
The SDEIS elso seems to dismiss the severity of the Impact
on Qulncy's neighborhoods of Atlantic and Squsntum. Last summer,
I waa contacted by e representstlve of C.E. Magulre in my capacity
aa a real estste broker/appraieer. He inquired whether I felt
siting s wastewater treatment facility on Long Island would hsve s
negative impact on real cstete valuee in Squantua. I responded
an* "
P.O. BOX 1O3
NORTH QUINCY, MASSACHUSETTS
02171
Mr. Michael Daland
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March 15, 19 85
affirmatively. I felt that siting a treatment plant on Long Island would
contribute "economic obaolesence" to the neighboring community, despite Its
somewhat more distant proximity to a proposed sewage treatment plant. (Economic
Obaolaeence la a negative effect on value fro» factors external to the property.)
I noted that residents of Houghs Beck and Hlnthrop who had purchased their
homes within the last 30 yeers were well aware of the exlatence of the treat-
ment plant prior to their purchase, and thus, made their Offers with that In
•lad. Squentum residents, however, have had no such advance information. An
unobstructed view of en industrial plant encompassing some 18 to 96 seres. Is
hsrdly a hot Item In reel estate circles! One need only look at the relatively
"low profile" Jorden Marah warehouse containing a mere million square feet to
envision the impact, (this nearly 23 ecre building dwerfs anything in the area.)
I am confident that I was not the only real eatate person contacted by C.E.
Magulre. I would be very surprised If my colleagues would have serious dla-
egreement with my premlae. It Is Intereetlng to obssrve thet while real estate
impacte were briefly mentioned, the rationale for the conclusions seems absent
from the report. I feel the direct Impact of such a facility could only be
documented were there a comparable eltuatlon available. Without in-depth
Inveatigation, I do not have peraonal knowledge that a comparable altuation
exleta. My conclusions, however, come not from mere speculation, but from the
knowledge that for comparable properties in Boughs Neck end Squantum, the
latter generally sell for more than the former. Both communities heve the
esms Bsy; both ere in cloea proximity to centers of employment, shopping snd
sducatlon. and, yet, the velues era now different.
The report itself shows Long Island to he leee dealrable In terms of
cost, disruption to the environment end the neighboring community, legal and
Inatltutlonal obateclea, time to construct snd implementablllty. The longer
we must wait for an efficient waatewater treatment facility to be built, the
longer we must suffer with a polluted Bey. Time is of the essence I Ue must
stop discussing the problems snd start doing something about them. How many
more summers must we endure e bey we cannot swim In. ssll In, host in, water
ski In, or wlndsurf in without fear of infection. How many more seasons will
we see the clambeds closedf How many more email fishermen will be put out of
business beceuse the fish in Boston Bsrbor, contaminated by pollution, have
shown signs of fin rot snd PCB'e in their intestines, snd are not salable?
.How many more balmy evenings must we spend indoors because of the odor, and
the greeae balls, human feces, sanitary products, etc. which wash ashore?
We have to start et the beginning—et the other end of the pipe I We
must not dismiss aa Impossible the idea of sub-reglonsl treatment facilities.
Ue cannot consider implementing them only for expansion. We must realize
A thstfiven the history of sewersge treatment in Baton Harbor, the ides of
_X Mosolldsting sll our sewerage in one place leshort sighted. Ue must con-
S \AV/c slder piecing limits on the amount of flow which the system
V-V\. lAVt can aecept, and encourage weter conservation by requiring builders
to use "wster-eever" showerhesds snd "low-flush"toilets, for example.
Many questions remain unresolved. For example, we have yet
to be Informed whether a plant this size exists anywhere, and
whether it functions efficiently. The battle between primary
and secondary slso has its share of unanswered questions.
5Wt.n !Hart«r 91alicnal Rtcriatim J
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SAVE Ou* SHORES. INC-
P.O.BOX ioa
NORTH QUINCY. MASSACHUSETTS
OZ171
Mr. Michael Deland
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March 13, 1985
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Some would argue that primary with a deep-ocean outfall creates less of an
Impact than secondery with a local outfall. Others argue that tbe deep-
ocean outfall ia neither "deep" nor "ocean" and would creete a "dead zone"
some 8 miles out. The question of aludge remains a myatery. Some argue
that aince aecondary creates twice the sludge, tha primery option with
"deep ocean" la tha answer tbe inner herbor is so desperately seeking, and
that tha "deed tone" elready exiata. This latter fact is seriously disputed
by secondary proponents. Whatever the enswer, the question of how and where
the sludge is to bs disposed of, end the amount of aludge to be generated by
the varloua optiona, baa been Inadequately addreaaed. Since we are told that
the only approved dump alta ia reportedly off the coest of Hew Jersey, what
about the beeurocretlc red tape aaaoclated with Army Corps permits and par-
cite between Region I and Region II, where the dump eite is located.
Of course, no discussion of the report would be complete without alluding
to the absence of data relative to the Inflow/Infiltration (I/I) problem.
He have heard flguree ranging upwarda of SOX of what goes Into the treatment
plante results from I/I. An immediate, effective end enforceable mandate
should issue to reduce the I/I within the 43 cities and towns served by the
MDC (Water Resources Authority). This measure could be implemented in
considerably less time than it would take for the creation of new fecllities.
Itwould go a long way toward mitigating some of the current problems while
everting others before they occur. The real benefit would be that the current
system would then be able to handle SOX more flow than it can now handle.
The idea of taking peoples' homes or filling is totally unacceptable.
Filling la of particular concern to SOS. Some years sgo, we prevailed In
litigation against MASSPORI for filling in the Harbor. HASSPOKT waa ordered
by the court to conduct a "Cumulative Impact Study on the Effecta of Filling in
Boaton Harbor". That study ia in the final atages of completion. Among other
things, it raveala that as a reeult of the massive filling in the Harbor, the
flushing is so bad that it takea e particle two days to reach open ocean.
The report also states that Quincy Bay la particularly bad. Ia it any wonder
that tbe pollution continues to wash back on our shores! Filling should not
be considered as e solution. Whether it la Hlngham Bay, Quincy Bay, Dorches-
ter Bay, etc., filling would only further exacerbete the problems.
In closing, it has become apparent over the lest few weeks, that we are
expected to endorse one of the alternatives aa stated in the SDEIS. It matters
not that the Harbor continue aa an open cesspool, what matters is the most
expedient solution. Actually, It ehould have been epparent long before the
Public Hearing process. The SDEIS reeds, "SITING OF WASTEWAIER TREATMENT
FACILITIES FOR BOSTON HARBOR". The Summary la a little more explicit. It says,
/\ III JQ5TOH HARBOR. Thus, the idea of sub-regional plants appears to have been
dismissed without reelly being considered. Surely, with the major
centers of leering and the corporate think tanks within such close
proximity, surely e better eolution than dumping our sewerage In the
Hsrbor can be found.
Very truly yours,
iVE OUR SHORES,. INC.
Maureen Mazrlmas, President
Mr«a an> O4i
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PREPARED COMMENTS FROM PBTEH O'CONHELL, PRESIDENT SOOTH SHORE CHAMBER/OF
7 ^-
COMMERCE, QOIHCY PUBLIC HEARING, MARCH /, 198?. ' ,^ ~ ,C
^tl* •' .
... <* I
As President of the South Shore Chamber of Commerce 'I ,yould like to /
&•• -t. ' t
go on-record with what we believe to be the only logical alternatives for
cleaning up our shores and Boston harbor, the Chamber has always had and
continues to have a committment to Improving the life of all people on the
South Shore, regardless of whether or nc1 they are In business as a member
of the Chamber or as a resident of the area. We ask that the E.P.A. take
all of the comments of all persons concerned and keep one thing uppermost
In the deliberations they will make. We ask that consideration be given
to the questions of quality of life. What would the quality of life be
for Winthrop residents after the plants ere constructed, not six or eight
years In the future, but fifteen to fifty years from now? We ask that the
E.P.A. take the time In considering what the Impacts would be on Squantum
and Houghs Neck during the same time frame. The decision you make will
affect people on the South Shore well Into the next century. Our concern
Is how life can be^breathed back into our South Shore beaches which have
been ravaged with pollution from the current treatment plant.
This Is not the first time the Chamber has stepped up to make Its
opinions known. We have been represented on the Citizens Advisory Task
Force since day one. Our board of directors went on-record at Its January
19B>f monthly meeting. Yes, that Is correct, January of 198U. At the time,
we stated that, In our opinion, Option 1*A2 should be considered for
primary treatment and If secondary treatment were required we stated that
option 1A2 should be considered. Our position has not changed. Tonight
we re-affirm our position that Deer Island Is best equipped to handle
a new primary treatmaat plant. We believe a tunnel.should be constructed
from Houghs Neck at Nut Island for use as a headvorks and that a long
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ocean outfall from Deer Island should be used after primary treatment.
If secondary treatment Is required, we reaffirm our position that option
1A2 should be considered which would use Nut Island as a headvorks,
and Deer Island as both primary and treatment plants with a tunnel
connecting Nut Island and Deer Island.
The Chamber wants you to know we are deeply committed to cleaning
up our harbor. We want you to know that we were committed to the creation
of a new separate sewer and water authority to take the responsibility
for construction and day to day running of the new plants. We gave our
support personally to Secretary of Environmental Affairs James Hoyte
when he addressed our Board of Directors last July.
In closing, we applaud the appointment of Qulncy DPW Commissioner
Paul Anderson to the new authority and we applaud the appointment of
Leo Kelly as a member of the Advisory Board. We are sure the committments
of these men and other people on the South Shore will be reflected In
the wise decision we hope Is made on the choice of a site for a new
waste water treatment plant for Boston Harbor. We urge you to act
quickly so that real progress can be made In cleaning shores along the
South Shore.
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PREPARED COMMENTS OF TERRY FANCHER, MANAGER OF BUSINESS AND TRANSPORTATION
FOR THE SOOTH SHORE CHAMBER OF COMMERCE, QOINCY,' MASSACHUSETTS. MARCH 7,
1985.
The arduous task of choosing a site for a new waste water treatment
plant for Boston Harbor is not easy. The M.D.C. has attempted it. The
Citizens Advisory Task Force has attempted it. No one has come up with a
clear front-runner as the very best site for a new sewage treatment plant
for Boston Harbor. It really is too bad that regional sewage treatment
plants cannot be built. All that has been agreed on is that the problem is
terrible and it gets worse with each passing day. You have heard from the
residents of Boston. Tonight, you are hearing from the residents of
Squantum and Houghs Neck and the South Shore. All have voiced reasons for
not allowing new sewage treatment plants near then. All have legitimate
concerns. Put yourself in their place and in our place when you go about
your deliberations about where the plants or plants should actually be
built. Sewage treatment plants are not considered a social amenity. Sewage
is not a glamourous Issue. My charge to you is to design and construct a
new sewage treatment plant that can be considered a social amenity and
which will not adversely impact the quality of life for the people who
live near it.
It is my belief , and I have made my views known to both the C.A.C.
and to my own Board of Directors, that Deer Island is the best alternative
for a new sewage treatment plant. This opinion holds true regardless of
whether it will be necessary to go secondary treatment.
I have one other very general comment; Regardless of which site is
chosen, it should be mandatory that traffic be minimized through
residential areas while the construction is going on. I suggest that this
be included in the order of conditions written. Barging should considered
whenever possible.
In closing, let me say that the worst thing that could happen here is
for nothing to be done. Think about the out-of-date diesel pumps on Deer
Island. Think about the rusted and corroded equipment on Nut Island. Think
about spring rains when rain water floods into the entire treatment
system. Look at water that Jack Walsh gave you. Look at the pictures that
Paul Anderson gave to you, and the videotapes as well. Look at the
petitions in front of you. Look at the signs in front of you which say I
love Houghs Neck. The people from this area have spoken. Listen to what
they say and take It all back home with you. I urge you to make your
decision early. I wish to go on-record as supporting option 4A2 for
primary treatment. If we have to go to secondary treatment, I wish to go
on-record as supporting option 1A2.
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'* £alt Wattr Jltkty Out.
U«» SEA STREET. HOUGHS NECK. QUINCY. MASS. O2I6B
March 20, 1985
Mr. James iloyte
Mass. Secretary of
Environmental'Affairs
jaltonstall 31dg.,
100 Cambridge St.
308ton. Ha. 02202
Oe.ir Slrt
llarvoy's Salt Water Fishing Club Inc. went onmasso carrying
their flag to the meeting held at Quincy Vo-Tech School in Quincy
on March 7, 19BS. The Club representing 200 members who fish,
dig clams, trap lobsters and swim in Quincy Jay, '.lingha.n Day and
RECEIVED
MM2666T)
OFF'CE OF THE SECRETARY
Of L..<..;j.....c.lt>L
•Teymouth, are in outright rebellion to the deplorable
conditions
which have been created by the M.O.C. and Water and Sower Division.
Creed and avarice in adding and adding more and more cities
and towns to the already overburdened .-Jut Island Pumping Station
such action being to your own profit at our expense. The boomerang
has turned and is coming back to. you a!iJ yours. Club members
were unable to speak because of the long political sp.2ech£s and
fifty others who tied up the entire evening.
There shall be no enlargement of Nut'Island Plant in any manner
and we will fight to the last ditch to stop any attempt even up to
civil disobedience. Nut Island shall be for head works only.
The future plant, if necessary should be at Oeer Island away from
any residential neighborhood.
The taking of homes ana thj filling of Qui.icy 'Jay ars two
ridiculous options. The loss CD t::_ ::o:no owners wo;ilJ be devastating
and the destruction of the ecology to the horbor as to :aarine life
would be deplorable.
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Satellite Plants are tha only solutions - •HO.;" - not
in t.ie future. 3reak down tha pipe line at various stations
and erect Satellites and Moleganito Plants.
Jliat do inland cities Jo that do not have a beautiful bay
to dump their sewaje in? Loo.': into thesa plans. What about
dryin-j the solid fill ani! co.aprossin
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QUINCY
RESIDENTS
COMMENTS
2-210
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Michael R. Deland
Regional Administrator
U.S. Envlornmental Protection Agency
JFK Federal Building
Boston, MA 02203
Kevin B. Davis
226 Rock Island Road
Qulncy, MA 02169
Subject: Comment Regarding the Siting of Wastevater
Treatment Facilities la Boston Harbor
+ satellite treatment facilities have been ruled out et this
tiae by the EPA and the Commonwealth, however, they should be explored
with earnest. The treatment of waste should be borne equally by the
cities and towns which make-up the north and south MDC Sewer system.
It is not fair that two communities, Qulncy and Wlnthrop, bear the
burden for 43 cities and towns.
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Mr. Deland,
After careful .consideration and study of the EPA'a SDEIS on the subject
matter I am in favor of site options Ia2 and 4a2. I am further unalterably
opposed to the use of the current MDC Treatment facility at Hut Island for
anything other than as a headworks for the following reasons.
+ the present facility is located in such close proximity to
the resldental neighborhood that any construction, including the present
upgrading, would cause irrepalrable harm and any benefits that would be
derrlved from the construction of such a plant or facility would be
negated.
+ the siting of either a primary or secondary treatment facility
at Hut Island would require the taking of a minimum of ten homes and/or
the filling in of 18 acres of Qulncy Bay. In the first instance It is my
belief that the taking of homes would be Illegal if not impossible to
push through the Massachusetts General Court In the case of primary treat-
ment, and in the case of secondary treatment, the taking of homes would
necessitate the taking of all of Qnlncy Great Bill up to the Qulncy Yacht
Club and or the filling In of(25 acres of Quincy Bay. Under current EPA
guidelines the filling in of any bay which Is of recreational and/or
productive value Is illegal, and in this case I so state that it is.
+ the economics of the contstructlon of a primary/secondary
treatment plant and the costs that would be assumed by the Federal and
State governments associated with road-bed, public utilities (le. electric
and water) and private home damage due to the related construction traffic
would balloon the current estimated costs well over $900 million, a burden
the taxpayer should not bear.
+ sludge management has not even been taken into consideration
in the preliminary siting options. If primary treatment were to be under-
taken at Nut Isalnd, approximately 100 dry ton of sludge would be generated,
If secondary treatment were conducted the tonnage would double to 200
dry ton. Neither adequate space nor coats involved have been investigated.
My feeling la that the management of sludge would require the taking of more
homes and/or the filling In of more acreage of Quincy Bay.
In closing, Mr. Deland I sincerely hope that you take into consideration
the points and arguments I have made for the public record In this
written testimony and those orally at the public hearings at Cambridge
and Wlnthrop.
Respectfully,
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Siting (tearing
3/7/85
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QentlemanI
Hy name is Brace Saphir from Eaat Sandwich, formerly of Squantum.
Because of «y deep love for tha harbor as I was born about 20 feet from
tha mouth of tha Neponset Biver on Dorchester Bay, I am vitally interested
In the future of Boston Harbor. I thank you for doing your duty by holding
these hearings and meetings over these many months and now permitting ua
the privilege of including our opinions in your considerations. bill you
answer some questions?
The summary on "Siting" ia a wall written report aa it always is, but
contradictory. Wa who have lived along the coaat for many yeare and lived
with Moon laland aewage, didn't move away because of it. We lived here and
loved it knowing that tha tide would alwaya go out.
We have been fighting for relief In this area for over 16 yeara after Save
Our Shores brought to light the value of this wonderful harbor. Gentlemen,
you are headed in the wrong direction and in 20 years into the future we
will be in the same predicaaent.
If you will be quite honeat, Isn't this whole plan a ruse to allow another
gigantic landfill along tha Squantum Marina, Thompson's laland, Dorchester
Bay shoreline so that transportation via land can reach Thompson's, Moon
laland etc.? Isn't It another way to place 53 acres of fill in the Nut
Island waterway aa aceeas to Paddock'a laland over land through Nut Island?
Why Is It after all your aaatinga you have been unable to convince tha
Inland cltlea and towns that they must stop pushing their sewage toward tha
harbor and instead ahould be building their own treatment plants? This
pollution lust be stopped at its source as with any other pollution.
The Haaaachuaetta Bay and Atlantic Ocean doea not need tha water but the
cities and towns upstream could benefit economically by properly rum
treatment facilitiea.
If we muat accept a aita for this problem, will you consider:
1. Deer laland should be upgraded and uaed only for Vinthrop, Boston,
Hyde Park, Dorchester, W. Boxbury etc.
2. Nut laland ahould be updated and uaed only for Cuincy, Weymouth,
Braintree, Hilton etc. to its capacity of 200,000,000 m. gal/d.
J. A aawage treatment plant ahould be built at the Squantum Karina
property to accommodate all other stations until planta are built '
in other communities.
%. No filling to be placed in any tldeland or waterway to accommodate
the proceaaing of aawage.
Thank you for the opportunity to preaent my viewa.
I AH BARBARA HC CONVILLE, 29 CHICKATABOT RD..QUINCY.
I AH ONE OP THE ORIGINATORS OP A 10.000-NAME, STATE-
WIDE PETITION TO CLEAN UP THE HARBOR. THIS
PETITION WAS PRESENTED TO SENATOR KENNEDY'S OPPICE
IN 1983.
IN ORDER TO LESSEN THE IMPACT ON QUINCY AND VINTHROP
TO LESSEN THE SLUDGE PROBLEM
TO HAVE SOMETHING DOME BEFORE THE BAYS ARE
BEYO*ND REDEMPTION.
IT IS IMPERATIVE TO:
1. WAIVE SECONDARY TREATMENT
C. CONSOLIDATE PRIMARY TREATMENT AT DEER ISLAND
3. HAVE A SMALL HEADWORKS AT NUT ISLAND.
4. CONSTRUCT 2 MAJOR PIPELINES - ONE FROM NUT
ISLAND TO DEER ISLAND - THE OTHER FROM DEER
ISLAND 9 MILES TO THE NORTHEAST TO DISCHARGE
TREATED EFFLUENT TO THE SEA WELL OUTSIDE THE
HARBOR.
5" 55 S£I??5 P SURFACE WATERS AND CONSTRUCTION
OF SATELLITE TREATMENT PLANTS IN FEEDER
BEPORE PURTHEH HOOKUPS ARE
PLEASE CLEAN UP OUR BAYS.
THANK YOU.
draco Saphlr
Founder of Save Cur Shores, Inc.
-------
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COMMENTS CN
SITING
Of
WASTEWATER
TREATMENT FACILITIES
In
Boston Harbor
submitted to
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
Region 1
and
COMMONWEALTH of MASSACHUSETTS
EXECUTIVE OFFICE of ENVIRONMENTAL AFFAIRS
by
Gary J. Cunnlff
132 Elliot Avenue
ftulncy, MA 02171
7 March 1985
RECEIVED-'P
• i;!An ! ; 1035
WA1ER QUALITY BRANCH
RECEIVED -EP/
'<'•? 11 19S5
HTB attSKEi
The comments In this paper are based on the feelings of
a resident of the Qulncy Bay area all my life and watching
the gradual deterioration of the water quality over the
past 20 years, Comments are also based on a reading of
the summary of the current report on Siting of Wastenater
Treatment Facilities In Boston Harbor, environmental
Impact statement, prepared for U.S. EPA, Region 1 and
Mass. EOEA.
There Is no reason that we should settle for any minimal
solution to the problem of wastewater treatment when there
Is so much advanced technology available to us.
I oannot recommend any siting proposal that offers only
primary treatment. Discharging partially treated effluent
only removes the problem to a less populated area (the
outer harbor Islands). There remains the possibility of
long term damage to fishing grounds and the sea bed
environment.
I cannot recommend any solution which disturbs the
Long Island Hospital or the remaining natural aspects cf
Long Island. Proposals for Long Island are also not In
accordance with the long range planned use of the area
as conservation area with recreational aspects.
Solutions that consider secondary treatment are the very
least that I could accept.
Heferring to the EIS proposal Ib. , this seems to have
some merit to It, although I have many reservations about
recommending It. To avoid confusion, proposal Ib. plans
Include primary treatment at both Hut Island and Deer
Island and then provide secondary treatment for all flows
at the Deer Island facility.
Proposal Ib. Is lacking In that It Is not attached to
a comprehensive plan. Sulney and Wlnthrop should net be
made to bear the burden of this metropolitan problem."
I would like to offer a few Ideas In the hope that you
would consider Implementing them In the final decision
making process.
Cities and towns contributing to the system should have
their sewer pipes re-lined. This will prevent the
Infiltration, Inflow and Illegal connection that plague
the system now. If pipes are not re-lined then their
continued deterioration and the population growth of the
suburbs will continue to place an unplanned for flow load
on any new facility. The result will be a situation not
unlike the present— where the sewers will be backing up
to West Qulnoy and overflowing and the treatment plant
overworked and falling to do Its Job.
-------
Some treatment at satellite plants In surrounding towns
or at pump houses along the sewer route would ease the
burden at the major treatment facilities.
I think you should consider an alternate means of
disinfecting the water during secondary treatment.
Methods exist for disinfection by passing the water by
ultra-violet lights. This Is a very clean method which
adds nothing to the water. Biological organisms are
destroyed when exposed to large doses of ultra-violet
light. This process has two Important aspects to provide;
first; It eliminates any harmful effects discharging
chlorinated water Into the harbor may have, Including the
possibility that chlorine Is causing cancer In fish, and
second; you eliminate the need to truck chlorine through
our streets and all the associated public safety Issues.
The Issue of sludge disposal seems to have low priority.
Land disposal would be attractive If It wasn't for the
fact It would Involve heavy trucks travelling on very
small residential streets. I think burning the sludge
may be a better method especially If the resulting energy
oould be used to run the plant.
tv>
I Seperatlon of solids and heavy, metals requires large tanks
^j and lots of land acreage. I think taking of homes Is
l_i not acceptable at all. However, If there were assurances
^ that all our polluted fishing grounds, clamming flats and
swimming areas would be restored, then It may be acceptable
to trade a few acres of the bay for fill to allow the
Nut la-land plant to do Its Job.
Finally, a solid committment for providing money to operate
and maintain the system must be proposed. Since we often
hear the cry !there'a no money to fix It* from officials,
this Is a legitimate concern In the long range solution.
I think only after these points have been studied and
presented In a complete package for review could a final
siting decision be Justifiably made.
Seapectfully submitted,
Gary J. Cunnlff
132 Elliot Avenue
Qulncy, HA 02171
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James B. Freel
21 Bell St.
Quincy, Ha. 02169
Mr. Michael Deland
Regional Administrator
United States Enviromental Protection Agency, Region I
J.F. Kennedy Federal Building Boston, Massachusetts 02203
Subject: 3DEI3
Dear Sir;
I an one Quincy resident who doesn't want a new plant in
Vlnthrop. I feel that the central issue here Is one of the
to sanctity of life. A new plant in Vlnthrop would continue to
I expose the prison population of Deer Island to the fumes,
IO germs, and noise. It would not be right to expose men
K> trapped in cages to such a horrible experience. Not only
,£* would that affect their minds and subsequently their
rehabllltalon, but their health as well. We can not
deliberately make them sick for efflcency, political
practicality or any other reason and still consider
ourselves fully human. Each time ve degrade the life of
even one of the scum of the earth ve degrade ourselves.
Please, for the sake of ourselves reconsider that option.
I am also opposed to the Hut Island option for many of the
same reasons above plus the fact that it would further
disrupt a very real community. Tou are not now proposing
merely the expansion of the Hut Island plant but, you are
proposing the taking away of part of Hough's Neck. There is
no historical precedent for this. The past expansions of
that place have always been done by the filling in of the
bay. Never has anyone ever suggested that they should take
homes in the Neck. In the SDEI3 there ia no mention of
culture destruction yet our culture will be for ever
affected by this act. This is a strange but different
place. There is a rythme to life here. Every child knows
the marshes and the influence of the tides upon them. Many
of our children get their college money from the digging of
clams and even flounder fishing. They do this in an urban
setting thus they are exposed to two distinctly different
ways of life. Most are working class but yet a greater than
expected number go on to higher education and beyound
despite their lack of contact with wealthier groups. There
is a rich and often fulfilling small town way of life here.
Your larger
plant coupled with the taking of homes would shatter that,
make us forever feel violated while continuing to poison the
air we breathe.
If you must take the homes here then you must take and
replace the Deer Island prison as veil for the same
reasons. I can not for the life of me understand why the Nut
Island option is even being considered. It means years of
legal battles, removal of our population, transport of goods
and materials through narrow heavily populated streets and
great mitigation, and for what? An option that does too
little on too little land. An option that angers the
population, is more visable than most and more expensive
than some. Not one other community said that they thought
that it should go here. People even came to our hearing
from Boston and elsewhere to say that they were against Nut
Island. Please study what was said and decide atleast
against the Nut Island option, and I hope for the good of
the prisoners as well. I for one will fight for the long
Island combined Primary which I believe Is best for all
populations and the future of the harbor. Later when more
money becomes available we can push for secondary treatment.
Please do make some Improvement and don't make a bad
situation worse. Move some of the treatment away from some
of the people.
Thank you for your consideration.
Sincerely,
JAMES B. FREEL
-------
Hard) 8.1985
Mr. Michaal Daland
US. It A. 22nd Floor
J.F. Kannady Building
Mr. OiUnd:
Thtrt are obvious raisons in tha EPA study to show Oaar Island is till most economically
and anviromanially satast solution.
Its not fair, but its not fair to taka and dastroy anothar natural rasourca such as Long
Island or taka jobs from thosa who work than. It b a homa and shaltar tor tha homa-
tmn nig1 chronically ill.
N>
I Plaasa saw our harbor! Allow Bonon and communitias to rabuild and maka it avail-
rO atlla to hundreds of paopla. Giva us a chanca and rebuild tha aiisting facilitias.
to
^ Thank you for your attantton.
Sincanly.
Ms. Barbara Manilar
99 Baysida Rd.
Squanluro. MA 02171
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179 Lansdowne Street
Squantum, Massachusetts 02171
12 March 1985
Mr. Michael Delaod
Regional Administration
Environmental Protection Agency
John F. Kennedy Building
Boston, Masaachuaettl 02203
Dear Mr. Deland,
Thank you from a concerned citizen for patiently siting though the
the hours and hours of statements, comments, and demands of the citizens of
Qulncy.
I hope one of the things you sav. was that Qulncy is united In the
fact that we are all concerned citizens, not only ebout where the site of
the new treatment plant Is but that you place the plant In the most technically
feasible, and coat effective area. Proa your report dated December 1984,
it Is obvious to me that the most cost effective, technically feasible
place to site the larger, more modern treatment plant, would be Deer Island.
To site the plsnt on Long Island you would have to, up front, spend
approximately $22,000,000.00 to rebuild the Long Island bridge. At present,
one takes his life In his hands, Juat to go to work or to Mass on Long
Islsnd. It la full of pot holes, some Chat are open, ao you can see the
sea beneath.
As you are probably aware, Long Island la reached through the very
congested area of North Qulncy, paat a large public high school, and then
the trucks must travel along the Squantum causeway, through a heavily
populated residential area, then onto Moon Island road, once again heavily
congested with residential property.
The Squantum causeway, s narrow single lane roadway, which is sometlmea
closed because of flooding fron exceptionally high tides, is now not only
closed because of the high tides, but it is now clogged on many days with
traffic from the 101 new condo residents going to and from their dally
activities. Soon to be added to that traffic, will be people going to and
from their Jobs In the new office park, to be built out on the Squantum
Marina site, by the many tourists, who will stay at the new eight (8) story
hotel, soon to be built. How about the traffic that will be generated by
the small Newport type shops that will alao be built out there. Please
Mr. Deland don't add anymore trafflce from employees of an expanded sewerage
treatment plant, or the traffic of the 20 or so buses and trucks that will
go out there during construction.
Mr. Michael Deland
12 March 1985
Page 2
It seems to me that the whole report needs to be scraped, and new
studies made. Have you given any attention to the satellite treatment
plants. Squantum and Qulncy have been paying long enough. What about
letting the 43 cities and towns pay, by requiring them to take care of
their own aewersge. For a start, the 43 cities and towns should immediately
be compelled, to fix all their sewerage pipes, so rain water does not
leak Into the system.
Siting the plant on Deer Island would require taking only a small
drumllo, not dlslocstlng homeless, destitute people. People who are
hopelessly 111. For some of them there would be no plance to go but the
streets of Boston. Mr. Deland, did you know that among some of those
homeless people are women with small children, and that if they didn't
have Long Island In the winter especially, they would live in abandoned
unheated houses or on the street, over grate, with only cardboard to
protect them from the winter weather. They might simply freeze to death,
but Long laland Is threre for them, at least In the winter. The children
who go there, to Long Island, with their parenta, maybe inspired to so
something with their lives, by the help they receive out at Long laland.
In closing, I am urging you in lieu of throwing out the whole report.
and starting over, to carefully read your own report. You can't miss
the fact that Long Island la an expensive proposition. Deer laland la cost
effective, and technically feaalble. If you think about the comments and
statements made, if you read over the transcripts of the meetings, you
will see, over and over again, that during all those hours of hearings,
the call was for not only a cost effective, but a technically feasible,
easy to maintain system siting, but for the 43 cities and towns to take
responsibility for their own sewerage, it la not the responsibility of
Qulncy, Squantum, Long Island, or Winthrop.
Do what is technically feasible, cost effective, and easy to maintain,
but do think about allowing the 43 cities and towns to take the responsibility
for their own sewerage.
Sincerely yours.
Sally K. Walnwrlght
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Mr. Michael Oaland
U.S. Environmental Protection Agency
22nd Floor
John P. Kennedy Building
Boaton, M 0220J
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by Friday, March IS, 1985).
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Mr. Michael Daland
0.8. Emriromaotal Protection agency
22nd Floor
John r. Kanaady Building
Boaton, Itt 0220J
Kei
relative to the location of the
'•i*a-1{V/6 oonnent on the options offered in the impact report
prepared by E.P.A. on the siting of the new treatment plant.
After listening last night to over 5 hours of discussion at
the Quincy public hearing, I'm not sure that anyone knows
what's right! I do know that I don't agree with any of the
options offered, hut, in view of the need for a decision on
one, I have to add my voice to the protection of Long Island
and Nut Island. I feel, given the choices in the report,
that the decision most be all primary treatment on Deer Island.
As many stated, it is dianaying that one or two comunities
must end up with the brunt of the sewerage problem created
by 43 oomunities, and that all those other comunities along
with the powers-at-be sean unconcerned that they, as well as
we, are losing our right to use our shoreline and ocean.
I would like to know what your post-siting-decision plans
are to pursue satellite treatment in our immediate regions?
You say it is not feasible for the present need, but can it
be implemented in addition too the currently planned plant?
One this impending decision is made, will you keep working
on the further solutions, or will your attention be diverted
-------
March 8, 1985
Michael Deland - Page 2
U.S. B.P.A.
NJ
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to antoher area, allowing another 10 years to elapse
and another gi£nt ^f * TM^** to
I oust also say that I don't envy you your job. I would
not want the responsibility of this, literally, life or
death decision for our waterfronts. I cunitaU you and your
fellow hearing board members for lasting and listening
to everyone till such a late hour on 3/1/55".
Respectfully,
Hary/ff. Blood
40 Btoonfield Street
Squantun, MA 02171
68 Bmm Ave.
Quincy, Mass. O2169
March 11, 1985
Mr. Michael R. 0*1and
U.S. E.P.A.
JFK Federal Bldg.
Boston, Mass. 022O3
Dear Mr. Delandi
Thim im to urge you to rule out Nut Imland as a possible site for
a sewage treateent plant. My reasons are as folloMsi
1. Nut Island is not QB8C • communityt 1* is iQ a community.
2. Filling the bay is not environmentally or legally
feasible.
3. Taking homes of people Mho have lived in this co«uounity
for eany generations and contributed greatly to it is not
fair.
4. There is only one narrow access road to Nut Island. This
road is used by all Houghs Neck residents, including
children in grades kindergarten through five walking to
school, riding bikes to the playground, etc.
3. The noise levels during an etftended construction period
would reach nearly dangerous levels for hundreds of
residents of the neighborhood.
6. The Nut Island options would cost eore than other
options.
The draft E. I.S. recognized all of the above factors. An
objective group of experts has concluded that Nut Island is not a
feasible site. Please heed their recoouaendations.
In a conversation I had recently with a teacher at the Atherton
Hough School, the teacher closed by saying, "If the Environmental
Protection Agency chooses to locate a plant at Nut Island, I'll
lose all faith in the Environmental Protection Agency." If the
E.P.A. continues to consider the Nut Island location, I too
will lose all faith in the E.P.A.
Sincerely,
yt_rV^xl _.-.-.
•Judith Goodman
-------
Prom i John A. Washington III
25 Island Ave.
Qulncy. Kass.
HOUGHS WTCK
GREAT HILL
March
To i Michael H. Deland
Regional Administrator
U3EPA if
Region I ^*>o
%?
Mr. Deland.
First, I would like to thank you for attending
the 3DEIS Public Hearing In Qulncy concerning the Boston
Harbor sitings for waste water treatment facilities.
Secondly, In response to your letter (an enclo-
sure to the SDEIS/R) I formally submit my comments.
^j Uoon reviewing the SDEIS/R prenared for you
I I conclude (given the only alternatives) the following*
tv)
(_j If Primary, then split primary Deer Island and
l_i Long Island i retaining and expanding
the existing facility at Deer Island
but relocating theNut Island facility
to Long Island . j
If Secondary, then split Deer Island and Lon»
Island i relocation of all treatment
facilities to Long Island eiceot
for retention of primary treatment
at Deer Island.
Furthermore, the use of Nut Island in any way
of which will result In either bay filling or the demolition
of HOMES! Is unacceptable. I am determined to terminate
such thought or action.
In conclusion, I'm dlsannolnted to realize the
limitation of alternatives. I understand your administrative
position In the overall scheme of things But this Is not
a Harbor Issue only.
The Long Term Issue requires enpraglng the
pollution/waste problem at the Source.
Please be a Leader In this Issue.
ThanXypu, sincerely.
-------
211 Park* Ave.
Squantum, '-MO. 02171
March 7, 1985
Mr. Michael Deland
U.S. Enrironmental Protection Agency
22nd Floor
John P. Kennedy Building
Boston, Hasa. 0220}
Bat S.I.B./B.I.3. on Location of th* Sewerage Treatment Plant -
Dear to, Dalandi
I car* vary much for our environment and I an upset over the pollution
of th* mtara of Boaton "arbor and Qulncy Bay.
I want to ae* the water cleaned and I ask that you do thla in the Tary
beat poaolble way. I do not think that the three optlonv propoaed in the
Impact study are acceptable as a solution^, I can only see this type of
planning as creating more pollution end cauaing greater and greater
hardship and atreas for people. |
I suggest that a massive treatment plant la not the answer.
I suggest that dealing with waate in the vicinity of origin makea more
aenae than pumping it to costal communities, with eventual discharge Ifeto
a very precious, fragile body of water. |
1 auggeat that aub-regional or satelite treatment plants be utilized.
I suggest that you explore the alternative technology that Portland,
Value la using. (Enclosed pleaae find related newspaper clip Ing)
I suggest that you use sludge as a resource, such as for fertiliser.
I suggest that you do not spoil another harbor Island by placing
a sewerage treatment on Long 'aland.
I suggest that you place a moratorium on any new aewer hook-ups
until thla current problem is solved. I suggest that you use all the
creativity, knowledge, and common sense available to transform ths
exis&ng open eewer back to the viable body of water that is was Intended
to be. I urge you and encourage you to take the visionary leadership
necessary to do it right this time. I aak this for those of us now
living and for generations who will follow.
Thank you,
*X, vfc.-~
Jean Green
LETTERS TO THE EDITOR
Harbor cleanup to cost
All thai I have read about the
new Water and Sewer Authority.
which will be responsible for the
cleanup of Boaton Harbor, dla-
tresses me. I have read about the
efforta of hardworking tegtalatara
andlawyerson behatiof rate-pay-
era, but It seem* that everyone
has accepted the cost estimates of
SI.5 billion to S3 billion. I submit
these estimates are Inflated.
Unquestionably Boston Harbor
needs help. When the MDC con-
sulted some of the largest engi-
neering firms for remedies. It
came as no surprise that the con-
ventional solutions they recom-
mended for the combined sewer
system were design- and construe-
llon-lntenjlve projects costing
hundreds of millions of dollars
and taking IS years to complete.
Right now Portland to imple-
menting alternative solutions to
problems Identical to many of Boa-
Ion's. The alternative technology
is saving Portland tens of millions
of dollars and will be completed
rapidly with a minimum of exca-
vation and construction.
(There la no "catch" to thla al-
ternative technology, such aa re-
duced effectlveneaa or Increased
operation and maintenance costs.
In fact, the reverse is true. The
catch Is that the sewer business.
as II is practiced today, makea It
extremely difficult to introduce
new technologies I
Invitations to come to Portland
to monitor progress and results
more than it should...
have been declined by the MDC
and others because. I am told. It
would be "Impractical" to revise
the consultants* 15-year plan "cv-
along."
No doubt the consulting engi-
neers would agree since that atti-
tude gives them, collectively, a vir-
tual lock on IS years of expensive
work.
THOMAS R. ADAMS. P.E.
Pontand. Maine
... but It must begin
Changing the name of the wa-
ter and sewer agency doesn't
mean Boston Harbor will be
cleaned up.
To clean the harbor requires
adopting a specific plan of action
while simultaneously Insuring
that the human talent and finan-
cial resources exist to carry out
that plan.
I hope the attention of the pub-
lic and the press will continue. We
must Insist thai the harbor clean-
up occurs now. We must not be
satisfied wtth a new bowl of bu-
reaucratic alphabet soup.
All too often the tendency to
settle tor reorganization preempts
real change In the delivery of gov-
ernment services at local, stale
and national levels. ,
CARLA B. JOHNSTON ,
Former Executive Director *
Metropolitan Area «
Planning Council i.
Cambridge
-------
7 Ailerton 3tM=et
Quir.cy. ."usjtcr.i-Et
Karch 16. l->=5
143 Sea Avenue
Qulncy. Ma. 02169
March 13. 1985
!T. rich?:, Deland.
U.S. E.T.S.
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22nd floor. J. F. Kennedy Bulldlr.g
Boston.[.'a. 02203
Dear t'r. Deland.
I v;ci:ld like to voice ay opinion of the o; tlj::s ;. r-.-ca; '..-J
r»rently 'r. Carcb-'dfje.• Winthrcp an! Qulr.cy dealing v/i*!- the clc^.-.-
up of Bus tor. liarbor.
In a few -.vcrJs, they scare me.
First to go with one pipe line for the whcle •!'ctrict ser.-.r
like putting ;'.!! your eggs in one basket. If we i.ave -'-^ »l..t jf
a t-reakJcwri or shutdown the whole syste:.-. is IK •.:••;•..tie.
I assume there will be redurdercy built irtc tr.t sy-tc::. fcr
this problem, but after living with Tut Island fcr al:-.-.st tr.lrty
years I would have little faith ir. it.
Also what are v/e aOirr to do with tho sluci.TC? I ti'.ir,-. t'-ls
is nn i'te^frr^l pn.rt or the p-rcbleT. and h^is to ''.jf- luilt -^.t'-'.. r:'.."
what has 'rie.'i said it seen.s because of the -akeuf. nf t.'.e c^.-J-c
Irclr.'.rat'on does not seer, ".o tc :-l?us'.hlc.
A '.Key ccean outfall has .ilso hfer. • ev*.!.0'oJ. I feel ..:•;,
stror.rly that to .lurcr the sludge Ir the ocerir will Lc c.e".'.':.,_ •:.:••--
•lipi't;!' v;l:'ch v/ill have to CL .itjl; ..'.'... oj ^ur cnii.ireri u..-
";rjr.ic::: Idrcii.
I feel thai if the £~.t*A. has tnc ..ower lu cur.e ir,to r;.j
community and saj cr.at w^'.etlier we want IL or r.o: ..-t .:3r. have ••-
plant built In uur nor.:.,:;.-L cy. it :;us: also have tne ,z.,<-. :>. ^.
t:- ilic oi!:er cj..t..ur.i :ies ami sa^ ci'.u'-^n is c;.j-^h.
have to build regional tr&at::.ci,t i.luiMs w.sijh tr.t E.T.A. Aiiii ;'..;'.j,
eiive ti'.tsn; a titi',;.ei i^te and ii ti.ty cu nu I :.co: tne iai-^t. t j^'.t.-
Jhut off the pi^t.
i realize yo^r problem is ii:.::.ti.Si,and I wiai, j .u «eil Lt _.i..;e
niake''ail0i.'',Jicc,':..::u.Miles~tCur t:.c'.i- Ouc c Si.arc of '.:'.= _..i':cj;.
no t Dne cr 't'/.o.
V;_rs cruly.
Mr. Mlehaal D«land
0. S. E. P. A.
22nd Floor
J. F. Kcootdy Building
Bo*too. MA. 02203
D.«r Sir.
Thia ia in roponii to cha lataat Mating, March 7.198}, by tha E.P.A.
ragardlng tha traatnant of aawaga by tha MDC.
My faaily attandad thia aaatlng bacauaa our houaa naxt to Nut laland
ia baing conaldarad aa part of tha plan for axpaoaion.
Va faal that tha aaatlng waa run poorly by Mr. Barry Lawaon. he
attavpttd to control tha paopla involvad and tha Influx of political
indivlduala, howavar. tha paopla directly involvad had to wait until
nearly aidnight before getting a chanca to apeak out In their own
behalf.
Be indicated at tha atart that each peraon would not apeak longer than
three to five ulnutea. however one appointed official had tha stand for
forty-two mlnutea. I do not conalder thia having complete control of
tha eteatlng.
I do not feel that tha E.P.A. treata each Beating with the same ground
rulea. example: Ulnthrop did not have a break in the meeting. Qulncy
did. This gave the people who are not directly Involved the chance to
leave .
Thia to ne aeeaa very unfair. After living with thla for over fifteen
yeara. certainly I ehould have the right to express myself.
Whatever you do in the next few weeka, please consider the number of
lives that are going to be shattered if the homes on Sea Avenue are
part of your plan.
Martha C. Chase
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VIEW FROM THE TOP
My ftally haa lived at 143 Sea Avenue for tw*ocy eight yeara, my parent*
bought the houaa right next to Hut Ialand bacauaa of Ita alsa for a
larga family and tha baauty of tba bay araa.
Wa bava a watched for ovar flftaan yaara tha complete and uttar
datarloratlon of tha KDC traatoant plant.
Va hava put up with odors* traffic and nolaa from poorly operating
equipment and aheer lack of concern on the part of the MDC.
We hava watched a beautiful, hiatorical city become the dumping ground
for other citlea through a pipeline of aewaga which haa been dumped Into
our bay.
My nelghbora and I hava attended meetinga for ten or more yeara
llatenlng to tha optIona and propoaala of Metcalf and Eddy.
If tha atate can afford to pay Matcalf and Eddy for ten yeara of
studies, wouldn't you think they could keep the present plant In good
repair?
With each aeetlng came a new commlealoner and a new atudy group. Each
time the imput of the people went unheard end there aeema to be no
perfect aolutlon.
Thia la America and certainly if wa can put a man on tha noon, we could
find aome better method to hendle our aewage. QUIHCY IS NOT THE WAY.
Ten yeara la a long time for ue to be aaddled with the anguish and
turmoil* not knowing if wa ware going to lose this battle to keep
our homea.
If we had let our homes become run down and completely deteriorated like
the treatmcqt plant, the city would surely have condemned our homes and
made ua pay to tear them down.
Instead we have improved the properties* remodeled* winterized end made
them attractive* with anticipation that maybe some day our children or
their children might went to live in thia same erea.
The atreeta in our area are narrow and with the present upgrading
operation we have trucks with aand, gravel, cement, lumber, equipment,
end welding materiala paaalng our homes daily. In addition we have
cars, email trucks and motocyclee carrying the construction workers.
maintenance crewa end administrative workere in at 7:00 out at 4:00,
in at 4:00 out at 11:00. in at 11:00 out at 7:00 daily end THE BEAT
GOES ON.
Ue do not went a new pipeline, we do not want a new expanded treatment
plant nor do we want anything trucked in* shipped in, or flown in, to
this arcs.
Thia city and Ita people hava put up with enough.
It la tha state and MDC who have committed a crime against our city,
polluting the bay. hurting tha fiahlng industry and keeping the
citiiena wondering what Metcalf and Eddy will produce next aa an
option*
I am a peaceful paraon by nature, I am willing to listen to both aides,
however how much are we expected to take T
I will do whatever I feel is necessary to protect my home from being
taken from me. I will support my neighbors in the same fashion.
SO HELP ME GOD.
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21 Nut Island Ave.
Qulncy MA 02169
March 12, 1985
Mr. Michael Deland
U.S. E.P.A.
22nd floor
J.F. Kennedy Building
Boston MA 02203
Dear Mr. Deland.
When I think about areas where the E.P.A. is most active, places
like Love Canal and. now, Boston Harbor, I think that perhaps the E.P.A.
is a misnomer - it should be P.P.A. - People Protection Agency. Currently,
your true charge Is to protect people from an environment rapidly becoming
toxic. In this light, I would address the prioritizing of your six criteria.
To begin your process of protection by evicting Hough's Neck residents,
or filling of our bay, just makes no sense as long as land Is available
anywhere for the proposed siting.
Peter Nielsen
Susan Lewis
125 Sea Avenue
Qulncy. MA 02169
March 14, 1985
Mr. Michael Deland
US EPA
22nd Floor
JFK Bldg.
Boston. MA 02203
Dear Mr. Deland.
Enclosed Is a copy, for the record, of the speech I gave at the final
EPA hearing In Qulncy on March 7.
I hope your decision will be for a plan that DOES NOT destroy my
family's home.
Sincerely,
. Carol K. Hallett
-------
My name Is Carol Kallett and I live at 125 Sea Avenue, four houses up
from Nut Island.
I find It hard to believe that after 10 years of study, using every
available resource - noney. technical skill, sewer treatment expertise - the
. only solution you can cone up with Is the archaic method of flushing to
the sea.
I expected something more creative and Ingenious.
THO of the plans call for demolishing several homes, one of them Is mine.
Each home that you ire considering demolishing has been owned by the same
family for an average of 25 years.
During those 25 years we have spent thousands of dollars and thousands of
hours Improving the houses so they are the safe, comfortable, attractive
l^j homes we have today.
I THIS IS NOT A TRANSIENT NEI6HBORHOODI11111
M
CO
vo Be coved here by choice not chance.
He choose to live on the water where we have a view --sunrises that make
you glad to be alive, sunsets so beautiful you could cry. sailboats on the
water In the summer, the fury of storms all year long.
There Is no land, certainly no water front, available in Houghs Neck.
WHERE CAN WE 60?????
We have become Involved In community activities. Joined the local churches.
our children have gone to school here and we have all made friends here.
WE CARE ABOUT HOUGHS NECK.
Destroy our homes you don't just destroy the place we live, you destroy
our whole way of life.
Destroy our homes and your destroy our hopes and dreams for the future.
We plan to live here til we die, or go to the home.
Our children want to live here.
You wut me to sacrifice my home so someone In Framlngham can flushi
with confidence? I
I find that totally unacceptacle. '
Thank you.
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ttZUf
March IS. 1985
uni»n-iiT*
Mr. Michael Deland
March 15. 198S
Page Two
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Mr. Michael Deland
Regional Administration
Environmental Protection Agency
John F. Kennedy Building
Boston. MA 02203
RE:
Siting of Wastewater Treatment Facilities
In Boston Harbor
Dear Mr. Deland:
This letter contains my observations of the possbile Impact of
the location of either a primary or secondary wastewater treatment
plant on Long Island In Boston Harbor.
The supplemental draft dated December 31. 1984 outlining the
Impact on the alternative location of Deer Island. Hut Island and
Long Island falls to consider the following:
1. Access to the Long Island site requires vehicular passage
over more than 3 miles of'narrow and Inadequate roads presently
unable to accommodate local traffic. East Squantum Street from
Hancock Street to Squantum has a travel surface In some places less
than 30 feet in width and winds for one mile through heavy residen-
tial Atlantic sections. That portion of the roadway presently
located on top of the Boston Main Drain pipe, also known as the
Moon Island Causeway as It passes through the Squantum Park, Is
only 20 feet In width and has curves and grades unacceptable for
any heavy traffic. The ability of the Moon Island Bridge to absorb
heavy traffic Is unknown and the roadway on Long Island Is only two
cars In width. The access to Nut Island la sufficient to stand
heavy traffic at normal speeds except for perhaps the last half mile
In which some speed reduction might be required due to curves and
grades. The access to Deer Island Is more than adequate and except
for required moderate speeds of traffic presents no access problems.
2. The Long Island site is situated at the highest elevation
of the three proposed sites and unless enormous quantities of
excavation occur would present the greatest visual blight.
3. The length of the dock due to the depth of adjacent water
would be the greatest at Long Island and present substantial
problems in accommodating the difference in elevation between the
facility and the pier.
4. Although mentioned In the Impact statement, it should be
reemphaslzed that only the Long Island site would substantially
impact proposed recreational facilities as none have been planned
or are reasonably practical on either Deer Island or Hut Island.
5. The juxtaposition of the Long Island Hospital facility
with a sewerage treatment facility and future recreational areas at
Long Island Head requiring patients and visitors to pass by or
through the sewerage facility and users of the recreational facility
to pass through the sewerage plant area seems very undesirable.
Whereas both the Hut Island and the Deer Island facility are at the
terminus and could be reached solely by the personnel at the facility.
I would hope that the foregoing might add additional reasons
for concluding that Long Island is a wholly Inadequate site for a
new sewerage treatment facility.
As an owner of land bordering on Boston Harbor and an amateur
sailor who has used the harbor for recreational boating on summer
weekends for the last SO years. I am familiar with the desecration
of the harbor principally by the 400 plus Illegal untreated sewerage
discharge pipes presently existing In Boston inner Harbor, the
periodic failure of the treatment facility both at Deer and Nut
Islands and the Inexplicable failure to carry the discharge pipes
out of the harbor and into deeper waters .
Although not the subject of an environmental statement, it
could well be argued that no additional treatment facilities are
required if the various antiquated sewerage systems In the various
municipalities were repaired and the quantity of the sewerage sub-
stantially diminished.!
Very truly yours .
„._.
DAR/pn
Doug fas A. Randall
Residential Address;
155 Crab tree Road
Squantum, MA 02170
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DEAR 9IR/MPDAME
PLEASE STOP PUMPING SEWAGE
IN TO THE BAY OR GET THE SEWAGE PLANT
FIXED. THE CLAMS ARE DYING AND THE
FISH ARE DYING.
YOURS TRULY,
BRIAN LAROCHE
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BOSTON
OFFICIALS/BOARDS/DEPARTMENTS
COMMENTS
2-269
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Cm' I IK BOSTUN • MA.sSA. 'lll'SKITS
• ITU tl'HHf MAVi;
RAYMDNDI-FLVNM
February 22, 198S
CLEANING UE BOSTON HARBOR
A Co»pr«b«nslv«, Equitable Approach
Commissioner James Gutensohn
Department of Environmental Management
Executive Office of Environmental Affairs
Commonwealth of Massachusetts
100 Cambridge Street
Boston. MA 02202
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Dear Conniiisioncr Gutensohn:
I am in receipt of your letter and concur Kith you that we should
explore the potential for recreational uses of Long Island.
The enormous potential Long Island holds for a recreational refuge for
•Boston residents has not been overlooked by my administration. I also
remain committed to the medical and homeless shelter services now located
on Long Island. I am encouraged that your proposal for a Harbor Park is
consistent with this perspective.
I suggest that our respective staff meet and begin to sort out the
details of your proposal. Mary Nee, Director of my Office of Capit.il
Planning will contact your office shortly, to coordinate this process.
Sincerely,
/>.?•.,,.-„,//<
' n-._^..J I Cl.fnn
Raymond L. Flynn, Mayor x"
Mayor Raymond L. Flynn
CITY OF BOSTON
February 27, 1985
BOSTON cm' HALL • iiNE CfTY HAI.1.11-A/A • m Vn V,' • .MASSU .HI Si. ITS Jiill • M 7 T:i.-HW
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CLEANING UP BOSTON HARBOR
A Comprehensive. Equitable Approach-
Table of Contenta
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I. Introduction p. 1
II. Guiding Principles 1
III. Implications foe Harbor Policy 3
IV. Factsheets
1. Boston Harbor as a Resource 4
2. The MDC/MWRA System 9
3. Infiltration/Inflow 13
4. Combined Sewer Overt lows IS
5. Slodge IB
6. Pretreatment 20
7. Technical Coaparlaon of
Treatment Alternatives 21
8. Ratepayer Impact of
Treatment Alternatives 24
9. The Heed foe Federal and
State Funding 28
10. Long Island's
Recreational Potential 31
11. HarborPark 35
12. Mitigation Measures 37
V. Common Sewage Treatment Terminology 38
VI. Bibliography -. 40
List of Figures
1 Boston Harbor p. 5
2 Shellfish Bads In Boston Harbor 7
3 Major Beaches of the Harbor 8
4 MDC Sewer District 10
S Ma}or Wastewater Facilities 11
6 Infiltration/Inflow 14
7 Point Source Discharges 16
8 Coablned Sewer Overflow 17
9 Primary C Secondary Treatment 22
10 Par Household Cost of Siting Options 26
11 Growth In Hater t Sewer Bills 27
12 Dependence of Rates on Federal Funding..29
13 Long Island Map 32
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Cleaning Up Boston Harbor - A Comprehensive. Equitable Approach
L Introduction
Boston Harbor It one of the great resources of the Boston
metropolitan area:
e The Harbor I* economically Important to the region,
supporting transportation, shipping, fishing, and mhellfiih
harvesting Industrie*.
e The Harbor la • valuable recreational resource, providing
boating opportunities aa well as passive and active
recreational choices available on the Harbor Islands and the
many public beaches which ring the Harbor.
e The Harbor Is an Important cultural resource, a vital element
of the history of Boston, reminding us of the who earned their
livings working on the waterfront and the many history-
shaping eventa which took place in Boston because of the
economic end political significance of the Harbor.
This resource has suffered greatly In recent decades as the
waterfront decayed and the water became more polluted. One major
cause of the pollution haa been the Inadequacy of the metropolitan
area's sewage collection and treatment systems. During the spring of
1965, Federal and State decislonmakers will substantially determine
the steps taken to correct this problem. This position paper suggests
several principles which should guide decisionmakera as they, quite
literally, determine the fate of the Harbor for the next several decades.
Finally, It concludes that:
e the new MWRA must be given Input Into the decisions It will
be required to Implement.
e ratepayers can be protected by selecting the least-cost
option for achieving the desired environmental Improvement
e the community Impact of needed facilities must be mitigated
as much as possible.
D. Guiding Principles
(1) Federal and State decisionmakers must develop a comprehensive
strategy which will get the maximum practicable cleanup of the Harbor
In the most equitable, cost-effective manner possible.
This principle suggests severe! related concerns!
e Any plan to clean up the Harbor must be balanced, including
correction of combined sewer overflow (CSG) problems, an
aggressive Industrial pretreatment program, reduction of
infiltration and Inflow (I/I) Into the system, a halt to the
practice of dumping sludge Into the Harbor, and many other
steps, as well as the construction of a new treatment facility.
e Options for the treatment facilities and other elements of
the cleanup program should be given serious consideration as
to the likely day-to-day reliability of the system, given the
harsh, salty environment which they will need to operate in.
e All options should be carefully examined for the indirect
impacts tney will create, and thus their total impact on
environmental quality.
The ratepayer* should be protected by the (election of the
least-cost alternative from among those with the same
environmental results.
A continued Federal and State commitment to funding a
significant share of the totaf cost of capital improvements
for cleaning up the Harbor Is critical.
The new Mass. Water Resources Authority and local officials
must carefully evaluate the rate Impacts of the costs
necessary to clean up the Harbor, and be prepared to
Implement alternative rate structure* (such as some sort of
lifeline rate) If needed to protect low-end moderate-Income
households.
(2) The cleanup of the Harbor should be constantly viewed In the
context of a larger effort to protect and enhance the potential of the
Harbor a* a regional resource.
•. The totel Harbor Is a multi-use resource, end thus efforts to
enhance water quality should be carefully reviewed for their
Impact oh other use*.
e The growing demand for recreational opportunities on and
around the Harbor should be encouraged by providing more
and better quality facilities.
e All of the wastewater treatment facility siting options have
the potential to Impact nearby residential communities. An
absolute commitment must be made by the State to mitigate
any adverse community Impacts.
• Many of the proposed improvement* will enhance the
economic vitality of the Harbor In addition to improving
environmental quality. Present and future planning for the
Harbor should recognize and take full advantage of these
Improvements.
(3) The Interests of the people of Boston and the region can only be
properly served If Federal and State decisionmakers work together and
coordinate their decisions, with proper Input from local communities.
key '
go fo
questions in order for the Harbor cleanup to go forward:
- primary vs. secondary treatment
- the locations) of major treatment facilities
- how to dispose of the sludge produced by those facilities
A decision on anyone of these affects the evaluation of
options for the other two. These decisions cannot be made
In isolation from the others, although admittedly they may
Rave to be sequential decisions for administrative and legal
reasons.
Two of these decisions are stated to be largely concluded
during the very period of time In which the Mass. Water
Resources Authority-trie Institution most critical to the
success of the Boston Harbor cleanup-is Just coming into
being.
-1-
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DI.
Implication! for Harbor Policy
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The City of Bo«ton has thoroughly reviewed the Harbor cleanup
and the waiver and siting Issues currently under Environmental
Protection Agency (EPA) review. The guiding principles discussed
previously were the basis for that review. Summaries of that analysis
are attached to this position paper as Fectsheets 7 through 12.
(Factshaets 1 through 6 provide a basic overview of Harbor and sewage
treatment issues.)
The following steps will greatly enhance the ultimate success of
efforts to clean up Boston Harbor and to realize the full aesthetic,
recreational, and economic potential of the Harbor:
(1) No action should be taken on the pending waiver and siting
decisions until the Board of Directors and key staff of the
new Water Resources Authority are given a chance to review
the Usuea and provide their Input to the decisionmaking
process.
(2) Long Island la the most valuable natural and recreational
resource In Boston Harbor. The City of Boston intends to
maintain the current medical and emergency shelter uses of
Long Island. The City Is 'also committed to Integrating Long
Island with other recreational uses of the Harbor, and toward
that end has begun discussions with the State Department of
Environmental Management (DEM) on possibilities for
parkland on the Island.
0) Whatever decisions are ultimately made on the waiver and on
siting, there must be an absolute commitment to mitigate the
Impacts of construction and operation on whichever
community la Impacted by the chosen site(s). Thlt
commitment should Include barging of construction materials
to the site, traffic patterns which minimize the use of
. residential streets, and strict controls on the transportation
of any hazardous materials.
(4) To protect the ratepayers' interests, EPA and the State
should select as final primary and secondary treatment
alternatives the least-cost option from among the three
primary options and similarly from among the four secondary
options contained in the SDEIS/R.
(5) A comprehensive Harbor .cleanup must begin Immediately.
There is significant doubt, however, that secondary
treatment will contribute to any real, overall Improvement in
environmental quality beyond that attainable from primary
treatment with the deep ocean outfall. We do know,
however, that a comprehensive cleanup plan Including the
primary treatment alternative will most benefit the inner
Harbor—the environment closest to the people who must pay
for the cleanup. EPA should carefully consider these issues
before deciding the waiver issue.
FACTSHEET1
BOSTON HARBOR AS A RESOURCE
Boston Harbor's size, history, natural resources and recreational
value make It unique among major American Seaport*. Fed by three
major tributaries—the Mystic, Charles, and Neponset Rivers—Boston
Harbor encompasses an area of about SO square miles and contains
between 107,000 and 180,000 million gallons of water depending on the
tides. In addition to Its twice daily tidal flows, the Harbor1* major
tributaries flush SOD million gallons of water Into the Harbor each day.
Natural resources which make this harbor unique among other
urban port* Include Its natural beauty, a park consisting of IS
essentially undeveloped Islands, thousands of acres of salt marsh and
Intertldal habitat, MOO acres of shellfish beds, commercially productive
lobster habitat, and an abundance of flnflsh. The waters and the
shoreline of Boston Harbor offer a profusion of recreational pleasures.
Urban dwellers, an estimated 250,000 people on an average summer
day, have the opportunity for recreation at the more than 30 salt water
beaches. Island parka, and fishing and boating area* withtng the Harbor.
Throngs of people In sailboats and other pleasure craft enjoy
recreational boating In the Harbor. Some 3,000 boat* are presently
moored In the harbor at private yacht clubs, commercial marinas and in
anchorage areas. Other boaters make use of the public launching
facilities In the Harbor and an additional 30,000 vessels or more enter
the Harbor annually through the locks at the dams on the Charles River
and Mystic River. Ferry-boat excursion* offer lunch, cocktail,
moonlight and business cruises. Commuter and Excursion boats travel
from Boston to Quincy, Hlngham, Hull, Gloucester, Provincetown, and
the Harbor Island*. • The Boston Harbor Islands offer the public a
number of opportunities for camping, fishing, picnicking, hiking and
exploration of historic military fortification* and other remains.
Accessibility to the Islands la the key to the expansion of recreational
opportunities In this heavily-used Harbor surrounded by the densely-
populated Boston metropolitan area.
Water quality In Boston Harbor la best around the outer harbor.
By contrast, the water* In the Inner part of the Harbor often have the
highest concentrations of pollutants. Inner Harbor waters and other
near shore waters frequently fail to meet minimum water quality
standards. Periodic sewer overflows result in near shore violation of
standards In Dorchester and Quincy Bays and in Belle Isle Inlet.
The most significant harbor uses which are Impaired or precluded
by poor water quality are swimming and shellfishlng. The quality of
water In the Inner Harbor (northwest of Castle Island) Is such that
swimming and other primary contact recreation I* always prohibited.
During the summer, Boston Harbor beach posting* should be a regular
occuiience during and after rainfall events which trigger combined
sewer overflow* In East Boston, Dorchester Bay, and the Inner Harbor.
Mechanical failures and flow overloads at both Nut Island and Deer
Island waatewater treatment plants occasionally result In raw sewage
discharge* that have contributed to beach postings. Progressive
deterioration in these plants' treatment capacity In combination with
unregulated development and poor maintenance have Increased the
occurance of such bypassing events in recent years.
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Sport fishing and recreational fishing occur* thoughout the Harbor
and may turn up winter flounder, Atlantic mackerel, itriped bau,
rainbow tmelt, atlantlc cod haddock, pollock, Atlantic tomcod and red
hake. Winter flounder It the dominant benthlc (bottom feeding) finfish
In Boston Harbor, and alto one of the moit popular fish catches. The
Incidence of fin erotlon In winter flounder appear* to be higher, in
Boston Harbor than In flounder population* outside the harbor.
Biologist* have theorized that the disease I* caused by some type or
combination of environmental stress. Researcher* have alto speculated
that toxic chemical* found In relatively high Concentration* in harbor
sediment* may be responsible for flounder fin erosion. Additional
research I* being done on the high numbers of fish caught with
cancerous tumor* and lesion* In Boston Harbor. These fish seem to be
located mostly at the point at which Sludge I* discharged Into the
Harbor.
Another potential use of Boston Harbor I* the growing and
harvesting of shellfish, principally the soft-shell clam. Overflows and
bypasses of raw sewage from local community systems, poorly treated
wastewater from treatment facilities, and storm drainage have all been
Implicated a* source* of bacterial contamination In shellfish areas.
Unfortunately, due to contamination all of the more than 4,000 acres of
clam beds within the Harbor are now closed to private recreational use;
commercial use Is permitted In limited areas only. This contamination
of shellfish beds represents a loss of approximately $12 million to the
local economy. Clam* are filter-feeder* which draw In water though a
tube called an Incurrent siphon, extract food particles, and expell
excess water and any waste through an axcurrent siphon. Because
clam* pa** through a large amount of water In the course of feeding,
they tend to accumulate, In their digestive tract, pollutants found in
the water overlying them. These pollutant* Include bacteria present In
raw sewage. When the shellfish are themselves eaten, the bacteria in
their digestive tract* may cause diseases to the human digestive tract.
Each State must classify the shellfish beds within It* boundaries
according to established criteria. In Massachusetts, the classification
of shellfish growing area* I* done by the Department of Environmental
Quality Engineering. The Department has classified all shellfish beds in
Boston Harbor as either closed to shellfish altogether or restricted to
commercial diggers. Currently, approximately 2285 acres of the
Harbor shellfish beds are classified as restricted to commerlcal diggers;
the annual harvest from these Is estimated to be worth 15,712,000.
Another 2416 acres In Boston Harbor are completely closed at present
to shellfishing. The potential annual harvest from these is estimated to
have a value of $6 million. Clams from restricted areas must be
brought to a purification, or depuration, plant in Newburyport before
being sold. The plant, operated by the Hasschusetts Division of Marine
Fisheries, provides for the flushing of contaminated clams with fresh
tea water. After approximately 48 hours, of this processing the
pta-ifled clams may be sold for human consumption.
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FACTSHECT2
THE MOC/MWRA SYSTEM
History
The Metropolitan Sewer district (MSO), which wu created by the
Commonwealth In 1889 to operate sewage collection and discharge
facilities serving the metropolitan area. Is the oldest metropolitan
service district In the United States.
At one time there were three discrete systems for collection,
transport, and disposal of sewaga In the metropolitan area. The Boston
Main Drainage System, completed In 1884, collected from the City of
Boston raw sewage that had previously been discharged st a number of
points to the Harbor and the Charles River. The system Included 25
miles of main and Intercepting sewers, a pumping station at Calf
Pasture, an outfall sewer from there to Moon Island, and several holding
tanks on the Island with a total capacity of 50 million gallons. Raw
sewage from Moon Island was released to Boston Harbor during the ebb
tide. This century old system Is still used periodically.
Geography, tidal flows, and shipping routes divide the Harbor Into
a northern half, consisting of the Inner Harbor, Dorchester Bay,
Wlnthrop Bay and the portion of the Outer Harbor north of Long Island,
and a southern half, composed of Hlngham Bay, Qulncy Bay, and the
Outer Harbor south of Long Island. This division was continued with the
establishment of the northern Metropolitan Sewerage system completed
In 1894| It collected sewage from treat of the Charles River and
brought It to Deer Island for coarse screening of large solids followed
by discharge to the Harbor. The southern system, completed in 1904,
conveyed sewage from Coitions of the Charles River Watershed, the
Neponset River Watershed, and adjacent areas south of the Boston Main
Drainage System to Nut Island. As at Deer Island, sewage at Nut Island
received only coarse screening prior to discharge to Boston Harbor.
These systems served 18 cities and towns which sent sewage to Boston
Harbor.
In 1939, an engineering study recommended that treatment works
be built at the terminus of each of these collection and discharge
systems; plants were to be constructed at Deer Island, Nut Island, and
at Moon Island. Primary sewage treatment plants ware subsequently
constructed at Nut Island In 1952 and at Deer Island In 1968. The
regular use of Moon Island to hold and discharge untreated wastewater
continued until 1967 when the Boston Main Drainage System was tied
into the northern Metropolitan Sewerage System. The following year,
the Deer Island treatment plant began'giving Primary Treatment to
these, and to all flows In northern system.
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LEMNI2:
. Ruwte Headword*
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MAJOR WASTElrVATER
WC
AND
TREATMENT FACILITIES
AROUND BOSTON
Current Status
The MDC System It still divided Into two unconnected lewer
districts. The Northern Metropolitan Sewer District (MSO) l» composed
of 22 member communities with e sewered population of approximately
1.250,000 •line South MSO collect* flow from 21 communities with'a
sewered population of approximately 630,000. *2 Average dally
wastewater flow within the complete MDC sewerage system is
.approximately 435,000,000 gallons with 3/4 of that flow within the
North MSD and 1/4 In the Southern MSD. OVER "50% OF" THIS FLOW IS
UNCONTAMINATED WATER which results from ground, rain surface
and sea-water infiltration and Inflow Into local and regional collector
systems.
•1 In the northern Metropolitan Sewerage System, interceptors
carry sewage from member communities to one of three
neadworka which have screens to remove large debris and grit
chambers to settle out heavy solids. After passing through the
headworka, the wastewater drops down vertical shafts Into one of
two deep rock tunnels (each 300 feet deep) which carry wastes to
the treatment plant. At Deer Island, • large pumping station lifts
all Incoming sewage from the two submarine tunnels up Into the
treatment facility. The exception is sewage from Cast Boston and
Wlnthrop which reaches the treatment plant by overland pipeline
rather than by deep rock tunnel. There It Is screened at the
Wlnthrop Terminal Facility before entering the plant.
•* The southern system also carries sewage from local sewers to
MDC Interceptors, with pumping stations as necessary to lift
wastewater Into the larger sewers. When these Interceptors reach
the Nut Island primary treatment facility, • pumping station lifts
the wastewater some ten feet from the Interceptors Into the
plant. The Incoming sewage undergoes screening and grit removal
aa It* enters the treatment plant rather then in Individual
headworks along the Interceptor route.
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FACTSHECT J
rNFlLTRAT10N/WT-OW
The quantity of flow which can be delivered to the Nut Island and
Deer Island treatment plants Is a function of the design capacity of the
pipes which lead to the plants and the efficiency of pumps. The high
level sewer to the Nut Island Treatment Plant can deliver a maximum
of 310 million gallons per day (MGD) of flow. The Boston Main
Drainage Tunnel and the North Metropolitan Relief Tunnel to the Deer
Island facility can deliver a maximum of 805 MGD. In addition, the
North Metropolitan Trunk Sewer, which feeds Into the Wlnthrop
Treatment Facility at Deer Island, can carry a maximum of 124 MGD.
The Dorchester Bay Tunnel to Moon Island can carry a maximum flow
of 180 MGD.
The levels of flow In the MDC sewer system are affected by
changes in population levels and patterns of water use In MOC member
communities, new connections to or extensions of existing sewer lines
and, most significantly, the levels of Infiltration and inflow.
INFILTRATION Is defined as surface water or ground water which
enters a sewer system through defective pipes, joints, connections, and
manhole walls.
INFLOW la defined as the quantity of water discharged Into a sewer
I*J system from the roof loaders, foundation and surface drains, streams,
I catch basins, tidal overflow weirs, etc. Large quantities of Inflow also
r^> enter sewer systems through Illegal connections to sanitary sewers.
00 The term Infiltration/inflow (1/1) refers to the total quantity of
water from Infiltration and Inflow without distinguishing the source.
The overall sewerage collection jnd transmission system of the MDC
' Includes 5,400 miles of sewers owned by the 43 member communities,
thai approximately 3,000 miles of privately owned house laterals and 230
miles of Trunk sewers owned and maintained by the MDC. -In reality
there era actually 3 Interconnected and Integrated portions of the MDC
— Sewer system that are artificially divided along ownership lines
(MOC,MunIcipal and Private). This division In system ownership causes
significant difficulties when devleoplng a program of system-wide flow
reductions.
The North MSD Includes 5 core Cities (Boston, Cambridge,
SomervlUe, Chelsea and Brookllne) which have significant areas of
combined sewage and drainage. During rainstorms the flows discharged
to the North System's Deer Island wastewater treatment facility
(WWTF) Increases to over 800,000,000 gallons/day and all excess flow is
bypassed through over 100 municipally owned Combined Sewer
Overflows (CSO) to either Boston Harbor or tributary watercourses.
The CSO situation significantly confuses the problems of I/I reduction
within the North System. Consultants for the MDC have extensively
studied the CSO problems and have recommended over 30 separate CSO
projects (3 have been built and 3 others are under design) which will
deal with the 6-8 billion gallons of combined sewage discharged yearly.
The South MSD on the other hand is theoretically a separate system,
but unfortunately It reacts to rainfall events like combined system with
flow quickly Increasing to over 300,000,000 gallons per day. It is also
important to note that there are numerous sanitary (sewage)
connections to storm water pipes In the separated portions of the
system which cause continuous untreated sewage discharges to the
harbor and rivers.
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Figure 6
TYPES OF DEFECTS
. Crushed lateral
a Disconnected lateral
• Broken joints
• Roots intrusion
• Poor connection to collection sevow
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FACTSHEET4
COMBINED SEWER OVERFLOWS
The City of Boston and the surrounding communities of Brookllne,
Cambridge, Chelsea and Somarvllla have combined sewers which were
constructed generally between I860 and 1900. 'The construction of
combined sewer* wai an accepted rneana of waatewater and stormwater
dlipoaal for may citlea In the put, for the Beaton Harbor area prior to
about 1900. Combined uwert are common In older eaitem uaboard
. cities. They were dealgned to collect unitary waitawater, a> well aa
atormwater runoff from (treats and rooftop*. A combined sewer Is one
which collects and transports raw aewage and storm water In the same
pipe. (See Figure) Combined systems are dealgned with capacity for all
of the sewage and a small portion of the stormwater runoff from a
drainage area. In these system*, overflow structures are provided to
release mixed stormwater and sanitary wutewater exceeding the
capacity of downstream Interceptor* during storm event*. During
storms the total combined flow may exceed the hydraulic capacity of
the combined sewer causing a discharge to nearby water bodies. This I*
the cauae of public health and aesthetic problem* associated with
extreme pollution during heavy rainstorms.
The MDC completed the Eastern Massachusetts Metropolitan
Area (EMMA) Wastewater Engineering and Management Study in 1976
which among other solution* to water quality problems In Boston Harbor
prioritized CSO controls needed. An existing plan prepared in 1978 for
the MDC for CSO abatement covered a total of about 32,900 acres with
• population of 800,000.
Thai overall effect of CSO** depend* upon the quality and the
quantity of the overflow* and on the location and condition of the
receiving water*. These parameter*, In turn, are Influenced by a
number of factor*, such aa land use In the drainage areai the Intensity,
duration' and frequency of rainfall; and the amount of sediment
deposited In the combined sewer* between rainstorms and flushed out
during a later storm.
The major pollutant* in CSO1* are pathogenic microorganism*
(indicated by total and fecal conform), floating material*, oil and
grease and suspended end seltleable solids. Other significant pollutants
Include biochemical oxygen demand (BOO la a measure of organic
material) nutrients and heavy metal*. Combined sewage often has BOO
which is approximately the same a* that of raw sewage, coliform counts
which are one-fourth to one-half those of raw sewage,and concentration
of suspended solids up to ten times that of raw sewage.
About 5,700 million gallon* of combined sewer overflow are
discharged to Boston Harbor and It* tributary riven and stream* each
year.
Storm related combined (ewer overflow* occur about 50 to 100
time* per year, depending on location, and these overflows very in
length from several minutes to several hours. Included in the areas
Impacted most severely by CSO*s are Inner city Swimming beaches,
recreational boating - and shellfish.
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Flgure 7.
feint Source V\
HArksir
Kfiy. x «iu^«
•^ A *i*eryr*y bypot*
Vote: All areas rc£fiv«
Urban runofP- _^.
* HMf C«7» ar» lt»am
«n HarpOT" tributan«» (wrMiaui In
U th>« A'«ue.
0123
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FACTStCET 5
SLUDGE
The wastewater treatment process removes pollutants from the waste stream to
yield a cleaner liquid effluent. The process produces a variety of solid or
semi-solid Dy-products which can be divided into four basic waste groups:
1. Grit:
2. Screenings:
3. Scu»:
4. Sludge:
•and, gravel, cinders, eggshells, bone chips, seeds,
coffee grounds and otner heavy solid materials.
rags!, paper,
•aterlals.
plastics, oood and other similar
lighter floatable materials such as oil, grease, soap,
cork and vegetable debris.
Organic and inorganic materials wnicn settle out by
gravity in settling tanks.
Sludge la • by-product of sewage treatment. The more thorough the treatment
process in removing solids from wastewater, the greater the amount of sewage sludge
produced. Primary treatment generates approximately 0.3 dry tons of sludge for
•very Billion gallons of sewage; secondary treatment essentially doubles the amount
of sludge for a total of 0.6 dry tons per million gallons of wastewater. By this
measure, secondary treatment of the S66 MGD projected for the Metropolitan Sewage
District by the year 2000 would result In the generation of approximately 350 dry
tons of sludge per day.
Primary sludge is tna residue wnicn settles out of wastewater during the
sedimentation step of primary sewage treatment. Although it is from 95-98X water,
primary sludge contains virtually all the settleaole solids Initially present in
sewage, as well as approximately one-half of the suspended solids, one-third of the
blocnemlcal-oxygen-demand, and significant, if variable amounts of toxic
materials. The toxics include heavy metals, which generally occur in association
with suspended solids and are, therefore, concentrated with them in the sludge.
Because of the concentration of these pollutants from raw sewage in the sludge, the
resulting product is offensive and polluting material. Sludge is not without value
in the form of nutrients which sustain plant growth and also for the potential heat
energy of its organic matter. Some of the value may be recovered tnrougn
appropriate sludge management.
Both Nut Island and Oeer Island provide primary sewage treatment, a process of
screening, sedimentation, and skimming designed to remove settleable solids (i.e.,
those large enough to settle rapidly out of solution by gravity alone) and to
reduce the concentration of suspended solids. Sedimentation tanks are used to skim
floating grease and scum and separate heavier materials which settle at the
bottom. The current anoint of wastewater processed by each of the plants and the
Quantity of sludge produced Is shown below:
1982 Data
Flow (MX)
Raw Sludge (tons/day)
29)
75
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125
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Fallowing separation frog the wastwater, the sludge at both facilities Is
treated Dy anaerobic digestion. Tnis process allows bacteria to change organic
natter in the sludge to methane gas, thus reducing the total solids content. The
gas produced during digestion Is stored and used as a source of energy for power
and heating. The volume of digested sludge produced at each plant and the-solids
content of raw and digested sludge are shown below: •
FACTSHEET 6
01
3
43
3
A3
NI
50
3
30
Raw Sludge (%)
Reduction of Solids
during Digestion 00
Digested Sludge Solids (X)
Digested Sludge (tons/day)
Although the anoint of total solids is reduced during anaerobic digestion,
heavy metals are not destroyed during the process. The metals actually become
concentrated in the remaining solids. Therefore, the metals content of digested
sludge Is greater than the metals content of raw sludge. MDC sludge is analyzed
for heavy metals on a monthly basis.
After cnlorination, the sewage effluent and digested sludge are discharged to
tne Harbor through submerged outfalls. At Deer Island, two outfalls with a
' combined capacity of 400 MGO discharge the chlorinated effluent-sludge mixture to
tne President Roads snipping channel at a 30 foot depth. Three relief outfalls are'
utilized at flows In excess of 400, 300, an £00 MGO. I
Nut Island has two main outfalls, each extending about 6,000 feet from the
Island's snore, which discharge to tne Nantasket Roads snipping channel. A short,
1,4000-foot relief outfall and a 480-foot near-shore overflow outlet are also used
when plant effluent exceeds certain levels. Nut Island sludge Is carried along a
4.2 alle outfall across the Harbor to Long Island where it Is discharged close to
Deer Island's sludge discharge point In President Roads.
At tne present time, with the existing level of wastewater treatment, the two
M3C treatment plants produce tne equivalent of some 75 dry tons per day of sludge.
This sludge Is anaeroolcally digested to reduce Its volume and putresciblllty and
it is discharged to the harbor on the outgoing (eoo) tides.
Under secondary treatment alternatives (if the 301(n) waiver is denied by EPA)
treatment facilities will generate about 200 dry tons of sewage sludge per day.
Primary treatment facilities will generate about 110 dry tons of sludge per day.
Discharge of this sludge to the harbor, as presently occurs, Is against tne law.
The HOC Is under an Administrative Order from the EPA to cease tne discharge of
sludge to Boston Haroor. Currently, both interim and long-term planning for sludge
management is being carried out by the HOC, Massachusetts DEQE, EOEA. and tne EPA.
The EPA and the Comonwealth are aiming for the elimination of all sludge
discharges to the Harbor in the next two to four years. Interim and long-term
solutions being studied for the management of sludge, grit, screenings and
skimnlngs Include: composting, landfllling, Incineration, and ocean disposal at an
EPA designated site.
PRETREATHENT
2.
2.
-In addition to the so-called sanitary wastes which they are designed to treat,
publicly-owned treatment plants receive a great variety of other waste products
from residential and commercial, and especially from industrial sources. The
Introduction of industrial wastes may cause significant environmental problems
and/or difficulties in operating the treatment facilities to wnlcn they are
discharged; tne principal problems are the following:
1. Industrial wastes, such as toxic chemicals, may directly Interfere
•itn or Inhibit tne operation of the treatment work. They are likely
to disrupt the biological processes used In secondary treatment of
sewage.
Industrial wastes may simply pass through a treatment plant untreated
In Quantities that can be harmful to the environment.
Seme industrial wastes are removed by sewage treatment In the sense
that they settle in tne sludge. Heavy metals, for example, often
settle out In association with suspended solids. However, the
' presence of heavy esetal present problems for the reuse of tne sludge
for recovery of its nutrient value. Thus, options for sludge
management nay be limited and costs Increased accordingly.
Pollutants which cause any of these problems when discharged to a sewage treatment
plant are said to be Incompatible.
A pretreatment program must provide the necessary legal authority, procedural
mechanisms, and funding to enforce the National Pretreatment Standards and
requirements. Specifically, each treatment authority must be able to do tne
following:
— Identify Industrial discharges and the character and volume or
pollutants In their discharge;
— Control discharge by Industries through a permit, a contract, or other
means;
— Ensure appliance with applicable pretreatment standards through
self-monitoring and reporting by industries and by independent
inspection and monitoring Dy the treatment authorities; and
— Enforce In the event of industrial non-coupliance.
The HDC's industrial pretreatment program is an Important part of the Harbor
cleanup yet lacks enforcement ability because of inadequate staff. The program
reculres Industries to treat their wastewater before discharging to the HOC sewer
system. The Industrial pretreatment program is seen as the best opportunity to
reduce toxicants In wastewater effluent and sludge but must nave tne necessary
employees to Inspect and enforce the program.
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FACTSHEET 7.
TECHNICAL COMPARISON OF TREATMENT ALTERNATIVES
Glvan tha dozens of volumas of material which have baen
prepared foe the many stadias dona on tha Hacboc Cleanup Issue
ovac tha past tan to 15 years. It Is lapcactlcal to try to present
here any kind of detailed technical analysis of the engineering.
chealcal. biological, oceanographlc. and., other Issues which are
raised by any compaction of tha seven options In the SOEIS/R.
Bather, this factsheet will highlight several Issues which cast
doubt upon tha Initial pcesuaptlon that secondary treatment Is
necessarily superior 'to primary treatment. In sum. these Issues
will suggest that, while In an Ideal, abstract world secondary
treatment would clearly be hatter than primary alone. In the
complex system encompassing Boston Harbor. Massachusetts Bay, and
the built environment constituted by tha 43 communities which send
their sewage down tha pipe to Boston Harbor, there may be little
chance of attaining that Ideal. There Is a widely held school of
thought which advocates an approach of optimizing tha total system
within the constraints which we now face.
Reliability
One of tha many issues which Is raised by, the primary versus
secondary argument Is that of reliability. In other words, what
t^j will be tha actual operating efficiency as compared to the design
I specifications of tha system. Figure S illustrates the basic
M • processes of primary and secondary treatment. I It Is Important to
00 understand that secondary treatment is a separable process which
to follows after primary treatment. It Is also a substantially
different process In that it is ba&«d on biological treatment
. rather than simply on-physical processes. There is apparently no
operating experience for a plant of the scale required in Boston
Harbor under the conditions which such a plant would encounter, so
there is a wide range of professional opinion on what the
operating efficiency of secondary treatment would turn out to be.
The present MDC sewerage system is characterized, among other
things, by substantial variability in flow, a high and fluctuating
degree of salinity in the sewage treated at Deer and Nut Islands
due to infiltration of aeawatar Into the Influent, and rattier high
and also variable levels of various toxic metals and organlcs.
Assuming for tha moment that the aggressive industrial pretreatment
program needed for the success of either primacy or secondary
treatment Is In fact fully Implemented, the other two factors
still pose a significant threat to the reliability of secondary
treatment. This Is true because of the biological nature of the
treatment process — drastic variations in the Influent being
treated can kill off tha bacteria on which tha process depends.
causing an 'upset* which make take 30 to 45 days to recover from.
In the event of an upset, the secondary phase of treatment
would be bypassed, so the affluent being discharged to the Harbor
would have received primary treatment only. If this turned out to
be a rare event, then the reliability Issue is obviously minor.
If. however. It were a common event, then the effluent would have
a greater Impact than that from primary with a deep ocean outfall.
due to the more concentrated and restricted area of discharge.
firlnuuy$4*&n
Primary
PI Ante
jrtFSSiol ¥ w^
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Other Operating Concerns
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In addition to tha potential lack of reliability of a secondary
treatment plant. there aca additional features of tha tacbnology
which aca calavant to evaluating tha pcobabla pecfocBanea of tha
a/stan. Ona of tbasa la tba energy-Intensive nature of secondary
treatment — tba annual OSM coats ara no re than twice those of
prlaary. and more than half of the total OSM cost-for secondary
goes foe energy. This Is of concern for .several reasons. First.
as the energy crises of the 1970s demonstrated, a supply problem
can cause tbe price of energy to rlsa at a rate much greater than
tha general rate of Inflation. For secondary treatment especially.
this would causa the O&M costs to rise substantially, creating a
temptation to cut back operations to a level which would remain
within tbe budget. Second. In tbe event of an actual energy
supply Interruption, a choice might have to be made between the
substantial energy needs of the treatment plant and other
competing priorities. the 'solution', bypassing the secondary
treatment process, would result In the same water quality Impacts
as the possible upsets described previously.
In additional operational Implication of choosing tha secondary
treatment option Is the substantially larger amount of sludge which
would need to be disposed of. From an environmental standpoint.
It Is clear that tha present practice of discharging sludge Into
Boston Harbor must be discontinued. As Factsheet 5 described, the
current amount of sludge generated Is 125 tons per day. Whatever
the method of disposal eventually loplementad (conposting.
Incineration, ocean dumping, etc), the operational Implications of
doubling the amount to be handled are substantial. In addition.
If the chosen disposal method were Incineration, a significant
amount would potentially be added to the total energy consumption
of the treatment facility.
FACTSHEET 8
RATEPAYER IMPACT OF TREATMENT ALTERNATIVES
In addition to evaluating the 7 option* Included In the SOEIS/R for
their environmental Impact and technical feasibility, It li important to
properly understand the cost Implications of each as well. Both the
magnitude and the predictability of costs are Important to' this
understanding. The SDEIS/R has addressed the Issue by providing In the
summary the following cost measures for each option:
(1) capital cost (not Including mitigation measures)
(2) annual operating & maintenance
O) total ennuallzed cost (O&M plus debt service)
(4) per household cost
EPA provided all of these figures In 1984 dollars, which is partly
defensible given the difficulty of forecesting Inflation In addition to ell
the other estimate* required. However, this approach has two
problems: first. It seriously understates the cost differences between
the various options In terms of what the ratepayer will actually see on
his/her bill, end second, It neglects to present for consideration the size
of the bill to which the Incremental cost Is being added.
The City of Boston has employed a computer modal which wes
originally designed to estimate total water and sewer costs for Boston
households to produce some Independent estimates of the incremental
cost of each of the 7 options. The model was run using two sets of
assumptions: first, with the capital costs presented In the SDEIS/R and
second, with the updated capltel costs from the 1982 Site Options Study
(taken from Table 12.4-3 of the SOEIS/R). This procedure was used In
order to give some Indication of the sensitivity of rates to changes In
capital costs. The result* of this analysis ere presented In Table 1.
Figure U presents a comparison of the Incremental cost of each option
over the cheapest option In terms of the 199S averege household bill.
Figure II presents an estimate of the growth In per household bills from
1985 to 1995, Isolating the Incremental cost of the cheapest option, and
the range of additional cost which other options would add.
-23-
-2*-
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a
a.
O
a.
o
o
O
o
3
I riftun.10
HOUSEHOLD COST OF SITING OPTIONS
IncrraMital Effect on 1995 Bill (In Inflated dollara)
PrlMry Treatment Optlona
(ASD «
coat flRtirea)
Secondary Treat »ent Opctona
| ^^
coat fifturea (ram 1982 study)
§
|
f~
fc
§
i i
I i
i i
9335555
SSSSS5S
1
§
"25S52
805S35|
'^=5353
!?m«
iilii!
§
aj
e
i
5
8 w
2-284
-------
= " uS c
J2|5 S
• f " •»•
a "i8SS
. 5211.
»S J Mhji
I I2^i
L* >s^.§
C •- '
c • u u "u *" ' •v i
3S 8 Ijllli
t> *- .o Q.S
Pliura 11
K-eoo
WATER AND SEWER BILLS
Growth In Inflated Dollars
^200
1985 1986 1987 1988 1989 1990 1991 1992 1993 1994- 1995
KEY I
a Shir* of hill resulting tram
vatar And sewer costs other
than treatment nlnnt
Share of hill resulting
frn« Deer Talond/Prlnuirv
Treatment Plane option
Additional cost from
Secondary Treatment on
on Peer & l.nnn Talonda
2-285
-------
SK3« sis;
M& Ijl!
ife* HI
ililll? If;
Fr«p«rid by t
City of Boston
Attain. 8«tvtc«B
2/16/81
I
12.
WHOLESALE SEWER RATES IN BOSTON
Dependence on Levels of Federal Funding
»l JU -
$160-
$150 -
$140 -
S~ $1 30 -
1 S110-
| $100-
X $90-
g $80-
c $70 -
« $60-
E $50-
^ $+0-
$30-
$20 -
$10-
tn -
ll
•
•
y
1
s t
/
x'
7
^
/
X
|
y*
^
S
1985
CURRENT
FundfnR levels
1987
1989
1991
.IN CONSTANT 1985 DOLLARS
NO FED FUNDS [?Z?|
• (aaauMa apeclal state funding
reaalna avnllalile at S30O ullllon)
1993 1995
SPECIAL GRANT
($500 Billion over 10 years)
in addition to current funding
2-286
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FACT SHEET 10
LCNG ISLAND'S RECREATIONAL POTENTIAL
K)
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-J
Long Island, approximately 213 acres In size, Is tne largest'.Island In Boston
Harbor. It Is fade 141 of 3 separate drunlins, Long Island head, tne hospital area
and tne West head. A druslln Is a streamline nil! or ridge composed of glacial
drift left by tne last advance of tne glaciers. It Is owned Oy tne City of Boston
and Is connected to Moon Island and Qulncy Dy a causeway and a two-lane bridge
built in 1991.
The Long Island Cnronlc Disease Hospital, operated by tne City Department of
Health and Hospitals, occupies about 60 acres on the middle drunlln of tne Island.
The hospital facility is used to serve tne chronically ill, noneless, elderly, and
alcoholics. This Island site has been used to care for and house tne City's
Indigent and sick since 1882. Some of the structure In the hospital's 28-tuildlng
complex date froo this period.
The southern part of Long Island Is occupied by an abandoned Nike missile base
of approximately 12 acres, and a historical cemetery area of over four acres. It
is reported that as many as 2,000 graves exists within and beyond the area now
generally designated as a cemetery. The Island has served as a Burial ground
several times In its history. These include graves of thirty-six British soldiers
killed during tne Revolutionary War, 79 Civil War veterans moved from Ralnsford
Island, former patients and Inmates of the facilities on the island, and possiDly
•any of the former inhabitants of the Island dating from tne late 17tn to 19th
centuries.
The balance of the southern part of tne Island is presently undeveloped and in
.a natural state. This area of Long Island also Includes about five acres of
freshwater wetland, and about 11 acres of salt marsh. Salt and Fresh Water Marshes
produce material to the food chain which supports the fish, shellfish and wildlife
population in the harbor. These wetlands can also remove certain watereome
pollutants by uptake through the marsh plants. This end of Long Island also has
1,900 feet of federally designated barrier beach which is a low-lying strip of land
generally consisting of coast beaches and coastal dunes extending rougnly parallel
to the trend of the coast. It Is separated from the mainland Dy a narrow booy of
fresh, brackish or saline water or marsn system. It is a fragile carrier that
protects landward areas from coastal storm damage and flooding. Tne varied
topography and vegetation of tne Island serve as habitat for a variety of wildlife
found In tne naroor area.
The northern part of the Island encompasses Long Island Head and former Parade
Ground area of Fort Strong. It contains concrete fortifications that date Back to
tne turn of tne century. A lighthouse Installed in 1819 Is still in operation.
Significant archaeological resources have been identified in several areas on
Long Island which relate to the historical and prenlstorlcal usage of the Island.
Tne City of Boston has recently prepared a comprehensive plan for all significant
archaeological sites within its boundaries. This (draft) City plan identifies a
Broad range of policy issues relative to preserving and maintaining links with tne
City's historical and archaeological past. The primary significance of Long Island
is identified In the plan as related to tne Early Arcnaeic (8,500 to 5,000 years
ago) evidence found on tne Island, tne only sucn archaeological sites witnin tne
boundaries of the City of Boston.
-31-
Concept Plan
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to
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CO
00
Long Island offers special potential for the Boston Harbor Islands Park Because
of:
o Its size
. o Its historical significance
o Its diversity of natural habitat and landforns
o Its central location in tne Harbor .
o Its connection to tne mainland, wnicn would allow use over an extended
season.
Long Island offers tne City of Boston a significant opportunity to add to Its open
space, wril.cn is Inadequate according to federal standards. Tne park can Include
the Head, which contains an historic ligntnouse and oajor gun emplacement from Fort
Strong, and union has excellent views of the Harbor and tne naln snip channel.
The southern half of Long Island has the Beat areas for hiking and nature study.
It offers opportunity for one of the best beaches in the Harbor, whlcn If
supervised, could serve up to 600 persons per day, an environmental visitor center
overlooking the wetlands, combined hiking and bike trails with overlooks, and a
youth camp at the former Nike site and the beach area.
CITY OF BOSTON • MASSACHUSETTS
OFFICE OFTHE MAJOR
BAXMONDL.FUNN
February 22. 1985
Commissioner James Gutensohn
Department of Environmental Management
executive Office of Environmental Affairs
CooBonw*alth of Manacbuetti
100 Cambridge Street .
Boston. MA 02202
Dear Commissioner Gutensohn:
I am In receipt of your letter and concur with you that we should
explore the potential for recreational me* of Long Island.
The enormous potential Long Island holds for a recreational refuge for
Boston residents has not been overlooked by my administration. I also
reejiin committed to the medical and homeless shelter services now located
en Long Island. I am encouraged that your proposal for a Harbor Park Is
consistent with this perspective.
I suggest that our respective staff meet and begin to sort out the
details of your proposal. Mary Nee, Director of my Office of Capital
Pluming will contact your office shortly. Co coordinate this process.
Raydond L. Flynn. Mayor
BOSTON On HALL • ONE OTY HALL PLAZA • BOSTON • MASSACHUSETTS 022)1 • M' TO- «JOO
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FftCTS£ET 11
10
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HARBORPARK
The City, through the Boston Redevelopment Authority, has Initiated a
comprehensive Haroor planning process called "Harborpark." The unifying principle
of Harborpark 1* public access. Harborpark guarantees that a balance will be
•truck between the nrr1!? health of the City and Its inner life—Its need for
places when people can gather for social events, cannon recreation, or the c*iiet
enjoyment of life and nature.
Harborpark, outlines the Important planning principles that will guide the
future growth and development of the Harbor; tnese principles endorse public
access, urban design standards, and a set of public benefits — recreational,
cultural, educational,' and economic — which should flow from development
activities. Harborpark planning is the beginning of an Important public process.
It will produce new approaches to planning, design and development policies that
will assist policy development for other areas of the City. It can help forge a
genuine spirit of cooperation between the public and private sectors on the issue
of balanced growth and development. It can provide for the citizens of Boston, and
for the Billions who visit our City each year, full enjoyment of continuous public
access to the City's greatest physical asset, the Harbor. Finally, it will
produce, through the process of open and informed public debate, a community more
aware of the need to Improve and preserve what it holds in trust for the continuing
benefit of future generations.
Perhaps one hundred years from now, people will celebrate the natural beauty
and splendor of the Harbor the way we now appreciate the unique benefits of the
Common, the Arooretun, Jamaica Pond, and the other parks and open spaces which were
. planned tor our benufit and use one hundred years ago.
Boston
Redevelopment
Authority
Stephen K CoytaOrecksr
•October.23, 1984
Commissioner James Guten«ohn
.Department of Environmental Management
100 Cambridge Street •
Batten, HA 02202
Dear Commissioner Cutensobni
Z am writing to confirm understandings arrived at between
yon and representative* of. the City of Boston to the effect
that the Hynn Administration places the highest priority on
integrating Long Island into the Boston Harbor Island* State
Park. •
. The approximately 160 acre* of the Island not occupied
by the Long Island Hospital have the potential to offer
unparelleled recreational opportunities to resident* of the
City aad region. The Mayor baa asked me, a* part of the
Harborpark planning initiative to begin discussions that will
lead ultimately to the use of .the undeveloped portion* of the
_X«land for park.and recreational development.
. It i-a" ay understanding that you will be seeking capital
fund* for development of the Island a* part of your fiscal
year 1986 capital outlay request, and it la therefore necessary
to expedite these discussions.
The City of Boston looks forward to working with you on
• the development of Long Island as a major center in the Boston
Hart)or Islands State Park.
Sincerely,
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SC/e
fcpcn. fv*3sooxce
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FACT 9CET 12
MITIGATION
It is Imperative that the comnunities who host the treatment works observe
immediate and unrelenting efforts to euro and ultimately cease tne shameful
conditions which have resulted from tOC's performance as operator.of tne Nut and
Deer Island plants. It is important to inventory and quantify these conditions so
that their improvement can be documented. The general list includes:
A. odors
B. diverse floatables
C. airborne pollutants
0. fires
E. traffic
F. near-snore discharges and plumes
G. chlorine shipments
Items A, B, C, D, and F would be addressed by improvements of plant 0 4 M, some
capital investment in new equipment, and reduction of flows to the plants.
Me recommend that traffic impacts lessened by moving to waterbome
KJ transportation of personnel and deliveries. This oust be done for any major
I construction, and tne marginal cost of pursuing this technique for tne balance of
M tne traffic Is more than offset by Improved community attitudes toward tne
£ facilities.
Some substitute must be found for the current technology of chlorine
disinfection. In the short term, 2-5 years, a safer form of chlorine could be
used. The long-term approach should be tne application of ozonation, radiation, or
some other disinfectant technique.
It is vital to Improve the nelghborllnass of these facilities - they can be
essentially harmless. Tne ability of MWRA to improve this situation may result in
savings of tens of millions of dollars in plant relocation costs.
Common sewage treatment terminology
_- . —
•raaak mum bom aawaft by tu-
inlfai -It with air sad addttf bio-
lotJcaQr ion* dodo.
ia was.
aavtafdM npor or
Whan dM Itaam b returned
Adaandaa b aa advaacad ny of JSutaMa'' """^ *"" ****
aaaaai nsats as which actlniad can mnd^nato!?**
Ubaaal b dM liquid thai comas out
of a traatmani plaat after compto-
AaraaVaa Taak aarraa ag a dumbar naa of dM maimaal process.
far mjacaai aa* iau wattr.
~^^ Has*odlaiyab b a procata which
AJtas an ptaan which paw ta ma- uoina dinct carnal aad aa arraap-
Hi watera. Thay an o food tot fob. Mai of permaable-acliva mamhraaat
aad nan aaaatic aaimala aad. Uka «> achieve .-par»uoo of the sotubla
all pUaa. pa ozytxa ia dM mar. ^iou** tram dM ntar.
awnaria m tma Ural orpabma no* b a damp of aoUda brmad m
whka ofarn rons-ima dM orfaak coo- tawaaja by bsoioiictl or ****™i^' ac*
rucculadoe, b tba process by which
damps of loUds ia sewage an ouda
• iacreaaa ia site by chemical, phya-
eaior I
an null. I
-ehta
ia| Diana »luca auy play a imful
mla ia iricUmi fllur maaam op-
>• IOD, or biochemical oiyfea demand.
b dM dissolved azytca nquind by
arpabmt for the aerobic dtcomposi-
boa of orfaaic Butter prasaal la
waiar. U b utad aa a o-wasan ia da*
emnimna dM afaaaacy of • atwaaa
t b a dark* far iddiai
chlorine pa k. amaa la kiO ta/ce- bdaarmdoa coatbtt at buraiai dM
sludea w remove dM watar aad n*
daca dM remaiaial ntiduaa la a
i fa dM dompiae tsa-Kber tafa, afls-bumabM elk. The ash
of solids lo mala dMm HUM out of can dxo ba dbposad at aafary oa
dM sanaa lattar. Coae-ilanaa at land, ia soma man. or into eaves
aolsda b bn-uttl about with Iha us. or odMT aadarfrouad tocstioas.
of cartaia rtiamirah such at lima,
atom aad iiaa tahx laisusasar aawan la a comhinad
systam coatrol tba flow of OM
Caaablaad Sswar csrrio bolt saw- sawaaa lo dM trouaaal pUal. la
aia aad storm waiar ruiMct. a storm, dtay allow soma of dM
sawaia to Bow directly iato a n*
CajimasMor b a device far the caiviai stream. This protects dM
caicbifii aod tbrcddini at heavy trcauncal plaal from beiag over*
solid maner ia Ike primary state of te«kd ia case of a suddea surca
u. of wain mu Ihe sewen. laiar-
cepton sn also used ia separate
b 'a tscbaioua by saaitatioa sytiems lo collaci dM
whica air aader prettun b forced Bows from maia and trunk, sawan
iato asnee ia aa aeniioo laak. 'aad carry them la the pouts of
Tba tar b pumped dowa iato the maunem.
Lagaoaa an ponda, usually aiaaHnada
to rifid ipaciacaiioaa. ia which fua-
liCht. alsaa. and oiycaa imaract to
rattan waiar U a naaonibfci ttala of
Macanakal AaraOoa oacs mechanical
aaariy to mjecl air mto water. caosiBl
dM irasla stream lo aboaorb oxyiea
boas dM atmospban.
Mkroaea an miauta plaal or aas*
mal Ufa. Some microbes which may
caaaa diaaaaa aiisl ia sawaaa.
Mb-ad Uajaor b a minan of acU-
valed thtdfe and waters coataiaiai
ortaoic matter ttaderfoiaa. activatad
thtdp mamicai ia dM aeratioa tank.
Onaak Mailer b dM carbonaceous
waste coataiaed ia plaal or aaimal
mailer aod on|inatia| from domasuc
or industrial sources.
O-ddadoa b the addition of oaypa
which bnaks dowa orfaaic wastes
or chemicals ia sewage by bacterial
OHdattoa Poad b a auanisada Uka
or body of water m which wasica
used most frequendy with other
waste malmeai processes. Aa oai-
dalioo pood b basically dM same aa
sawaie through a pipa and escapes
out dtrousb bolea ia dM side of dM
Ptintla. W tlodre takaa place ia
tanks whea dM materials decompose.
nsulliai bi partial casiacaiion. lique.
of pol-
b aa akcthcany chararf aiam
or aroup of aiama wbkb caa ba
drawa from watia waiar duriaf dH
alactrodUlyiia procaia.
Latenl arwcn an dM pipaa dial
ma j^a Un nncia of a city aad
iaia wbkb amply dia
homaa or buunaiica.
Maury Tnaaaaal
mutriil chat fltMti or will sculi n
uwart. U b Accomplished by u»-
in| Krttns to catch the 0oaun|
objects and tanks (or OM heavy
matter to settle in.
PoUeUioe, mula «tkcn animal. v«gcu-
bte, mineral or heal wastes or dis-
charges reach waicr. malins it less
desirable for domestic, recreation, in-
dustry, or wildlife uses,
Polyetectroli'ies are synthetic cncmi*
cab used to speed the removal of
sobdi from sewage. The chemicals
cause the solids lo BoccuUte or chtmp
together more rapidly than chcmkais
tik* alum or line.
•tecetvte« Watvn art rivers, bkes.
oceans, or other waur courses that
receive treated or ami-fated waste
waters.
-J7-
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MB an me aunenla last vaan- Stem Seven an a aeparala synam
picks up as U pasaes through the of pipai mat carry ooly raaoffs
air. over aad under the pound, and from buUdlnu aad land daring a
through bouaehold sad mdusaul norm.
*""' Steffinaoo b d» deorocnoa af aO
faad flea lemon aoa» impaoded »*« organisms. In cootmt. dliin-
eoUda tram sevaea. Air aad bacteria facaoa b me daatrocliaa of most of
decompose ~MJ^—i wau glurns '
liillirr SnpiA bi •
tta. in pip« ia ft cny lots arty
only •t""*—*i* WUM «•&?. Tb*
BBCD mttr raoca » aba can
al try • Haw* mua at (ipo.
Trktttaa FDttr b I tapoon a»dU tor
bacuiul vnwdl. uoulhr > ted at
ncka or •tones. Tbo MWftgo b oickM
vm d» brt «o Hn bacuria eu boat
down dka organic wutci. Tbo bacuria
collect oa iho aooa tbrouih nptaud
oai of d» Blur.
WMM TraaABtal Plaal if a mritt
of tanka, Kncrn. Alura. and otter
aroccu** by wfaich pollgtinti in
Rtaovcd Erom waur.
Vina b laa maUcn term of micro.
or|aaum capabla of causiai duaaH.
I
fO
vo
•m b wbkfc bactui* axmmx HM
, at 0* «u«v U b
or brattai ik. am.
bacarift tepthfr ki crick-
filun or la d)a
liilanaiaitoa Taaka bala raonna
aolidi trom maa>. Ti« nau nan
b poapad to d» taaka vbara Ika
•olidl aatda to dM bottom or Boat oa
IBB top aa team. Tha icBm b trtmmad
at dM top. aad aolid. oa d» booom
"nntiooor
,of aaal dla-
SVfOc Taaka an «aed lor domeatk
wacua wtwa a ar»«r Uaa b DM avail-
abla to carry mem 10 a manual
plant. The mtea an piped to oa-
danrooad ttnii diractty tram ma
boma or boom. The bacteria in me
vattca dcrnmpoaa the orraek vaata
aad me iludfe atolaa oo [be bottom
of me Una. Tbe effluetn tmn out
of me Una DUO the irouod rnnMgn
dnim. The iludee a pumptd out
of the taoU. muajy by commrmal
Imu. at regular iatervala.
Stwera an a nmem of pipci mat
collect and deliver wmtte wuer to
Blbllognphy
1) "Drift W«t«r Quillty Baaellne*
for tin SDQS on Boston Harbor
Wutewittr FacllitlM Siting
May, 1984 bj; C.E. Magulre, Inc.
2) Boston Harbor Uland* State Park
"1984 Maatar Plan"
Docomber, 1984 b^ Mtw. Oept of Environmental Management
3) "Boston Harbor Islands State Park*
"Draft Master Plan Update*
31 May 1984
4) "Final Report on Industrial Waste Program*
Commonwealth of Mass. MOC, Sewerage Division
by_ Black & Veatch/consultlng engineers 1981
5) "Combined Sewer Overflow Project"
•Summary Report on facilities planning*
MDC, April 1982
6) "Wastewater Management Planning for Boston Harbor-
A Status Report*
Boston Harbor Interagency Coordinating Committee
August, 1980 £y. Madeleine Kolb, DEQE
7) •Harborpark - A Framework for Planning Discussion*
October. 1984
by_ City of Boston & Boston Redevelopment Authority
8) "SDCIS/R on Siting of Wastewater Treatment
Facilities for Boston Harbor" Volume 1*2
Commonwealth of Massachusetts
Environmental Protection Agency
prepared by C.E. Maguire. December 28, 1984
9) Harr Report to Judge Garrity-Summary of Recommendation
by CZM August 10.1983
9aWie b ma aolid matter that au-
Oja to dM baaoa. floeti. or beromei
and mua be dapoeed af by Uiraboci
aad •"•— ™ or by traupon to
appropriau <"— ' -'—
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CITY Of BOSTON • MASSACHUSETTS
ornci OF THE MAYOR
RAYMOND L-FUTNN
Match 18. 1985
Mr. Michael Deland
Beglonal Administrator
U.S. Environmental Protection Agency
John F. Kennedy .Federal Building
Boiton. Maasachusatta 02203
Dear Mr. Daland:
Tha City of Boiton vaa pleased to have tbe opportunity to
praeant testimony on tba Supplemental Dcaft Environmental Impact
Statement/Beport (SDEIS/B) on Siting of Haatawatat TraatBant
Facilities for Boeton Harbor at tba baarlng bald In Qulncy on Marcb
7. 198S. I would Ilka to taka this opportunity to add some
additional eoncerna to tba raeord.
Boeton Harbor la a valuable regional raaourea which baa baan*
much abuaad. and the City baa taken tbe unequivocal poaltlon tbat
atepa to correct tbia aevare pollution problem must begin
immediately. However.. It la important tbat tbe process wblcb
defines bow 12 billion'or more will be spent to clean up Boston
Harboiy be one wblcb proposes a solution wblcb tbe public, can feel
wltb some confidence la tbe rlgbt way to proceed. Unfortunately.
tbe process of wbicb tbe SDBIS/B la a part la . fragmented.
Incomplete, and quite difficult to feel, much confidence in. Tbree
major decisions (siting, tba waiver from secondary treatment, and a
cbolce of aludge management technology) wblcb ougbt to be made, if
not togetber. at least wltb careful reference to. eacb otber, are
instead being made sequentially wltb little or no' analysis of tbe
Impacta of aacb upon tbe others.
In addition to our objection to tbls fundamentally unsound
declslonmaklng process, tbe City of Boston bas otber criticisms
pertaining to factual and analytical errors and/or inadequacies in
tbe SDEIS/B. Tbese pertain to tbe following issues: mitigation
meaaures. coat estimates, aludge management Impacts, and Long Island
and its future recreational uses.
I. Inadequate Consideration of Mitigation
Tha SDEIS/B proposes or discusses a number of measures to
mitigate tbe negative Impact of a new treatment facility. Tbe
potential for reducing construction traffic. minimizing or
eliminating the trucking of liquid chlorine through residential
BOSTON CTTT HAU • ONE CITY HALL PLAZA • BOSTON • MASSACHUSETTS 02201 • 6I7/<1S-«DO
-2-
nelghborhooda. Improving truck routlnga. and minimizing conflicts
with other proposed or existing land uses are all crucial aspects of
the altlng decision. Unfortunately, none of these elementa baa been
adequately treated In tbe SDEIS/B.
Tbe SDEIS/B Indicates tbat tbe barging of construction
materials will be made a part of tbe apeclfIcatlons of the project.
But after citing several constraints involved In locating a barge
terminal tbe report simply outlines a possible approach to .
overcoming tbeae constraints. Mo specific barging sites are chosen.
nor are any detailed cost estimates provided for barging of
•atarials under the various site options. In addition, the
possibility of ferrying workers to the site la given only the
briefest mention in the report. Options for reducing liquid
chlorine shipments through residential neighborhoods are- given
similarly Inadequate treatment, as are tbe possibilities for
alternative construction traffic routings.
The Final EIS/B must addreaa the feasibility and cost of these
measures on a site by cite basis. It la not enough to develop a
generalised discussion and a vague cost estimate which la Included
as a footnote to the individual site option coat estimates. Bather.
•ince tbe plans for mitigation will most likely vary by site and the
secondary Impacts of mitigation will also vary, some analysis must
be provided separately for each site. Tbe cost estimates developed
for each Individual site should, then be Included In tbe capital cost"
estimate for tbe site option. ' •
Tbe compatibility of a new treatment facility with other
proposed or existing land uses of the chosen slte(s) la also
discussed In the section on mitigation measures. Again tbe SDEIS/B
provides an Insufficient asseasment of tba issue. As regards
arcbeologlcal and historical resources on Long Island the report
Itself concludes tbat 'potential site conflicts will require more
extensive site Investigations. Additionally, tbe requirements' for
evaluation of all feasible and prudent alternatives to siting on
Long Island, as specified under section 106 of the National Historic
Preservation Act. need to be addressed.* (p. 4-94)
A final Issue directly related • to mitigation of Impacta is
tbat of compensation. The SDEIS/B recommends that a mechanism to
provide compensatory remedies should be examined following the
conclusion of the EIS process (p. 4-97). It is difficult to
understand bow tbe Issue of compensation can reasonably be postponed
until after the siting decision bas been made, since it presumably
would constitute an additional cost of the project, and furthermore
one which would vary by site. If a reasonable mechanism of
compensation can be developed and agreed to by tbe responsible
parties (including the new KWBA). It would have a very significant
bearing on.tbe altlng decielon.
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"-5- •
The southern bait of Long Island is « good loca-
tion for biking, nature study, archaeological •zplocatloo.
•wining and operating a susner caip for urban youth.
Long Island Head can comfortably serve 2.500 persons
per day with a boat plat. restored Pott Sttong. vlsltot
c*nt«t. picnic ground*, ball fields, and biking trails
vltb overlooks. ' •— -•- -.
Long Island offers • significant opportunity to
Increase tbe public recreational u>« of Boston Batbot.
Again, tbe city of Boston appreciates tba opportunity to
present, furtbar coaiant on tba. SDEIS/R and hopes that the Final
KIS/B will ba Issued in a fori which corracts tba substantial flaws
prasant in tba draft.
NJ Raymond L. Flynn
U> Mayor of Boston
cc: Jaies 8. Boyta. Secretary of Environmental Affairs
Philip Shapiro. Transition Dlr..'Hass. Hater Baaourcas Authority
Bobart Haaly. Cbalraan pro tern. MWRA Advisory Board
John Davaraaux. City of Boston Law Department
. Bobart Clolak. MWRA Board of Dlractors leiber
Lorralna Downey. MWRA Board of Directors »eiber
Ullllai Cougblln. MWRA Board of Dlractors member
Blcbard C. lanes. Boston dalagata. MWRA Advisory Board
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Beaton Witor and
S*w«r CommUslon
10 Pol Offic* Squar*
Boom. MisMcnuMItt 02109
617-4264046
Mr. Hlchael R. Oeland
Regional Administrator
United States Environmental
Protection Agency. Region I
John F. Kennedy Federal Building
Boston. Massachusetts 02203
March 15. 1985 M4ft j 8 (9^5
Re:
Environmental Impact Statement on Siting of Uastewater
Treatment Facilities In Boston Harbor
Dear Mr. Deland:
As you may know, the Boston Water and Sewer Commission (the
•Cotmlsslon") currently pays about one-third of the Metropolitan
District Comnlsslon's (the 'MDC') annual Sewerage District assessment.
The Commission Is accordingly vitally Interested In the Issue, now
under discussion, of where to locate expanded or new wastewater
treatment facilities for Sewerage District communities. We offer
the following conraents with respect to the 'site option" environmental
Impact statement ("EIS") now being developed by your agency.
First and foremost, the Comilsslon objects to the order In which
EPA has undertaken to consider the pertinent Issues. It seems to
us to be completely Illogical to decide where to locate a facility
before one has determined what the facility will be. The paramount
consideration should be whether the facility will be an expanded
primary treatment plant or will encompass secondary treatment as
well. No Intelligent determination of environmental Impact can
realistically be made until the primary vs. secondary treatment
question has been resolved. Similarly, no meaningful environmental
Impact analysis can occur without some fundamental sludge disposal
decisions. The Commission submits that EPA's decision to separate
the siting, secondary treatment, and sludge disposal Issues 1s
arbitrary, capricious, and Irrational and undermines the Intent of
the NEPA process which the agency Is charged with Implementing. The
purpose of this entire process Is to provide for water quality protection,
and should not be confused by restrictive administrative procedures.
RECEIVED
,? n jog
Mr. Hlchael R. Deland
March 15. 1985
Page 2
The Commission therefore formally requests that EPA delay
preparation of Its final site option EIS at least until such time
as the agency has finally passed upon the s301 (h) secondary
treatment waiver application submitted by the HOC. Should EPA
refuse to countenance such a delay, the Commission requests that
the entire $301 (h) application. Including all supporting materials,
be made a part of the record to be reviewed by EPA in the development
of the site option EIS.
Consideration of that record leads to certain conclusions. First.
In view of (a) the much greater long-term (operating and maintenance)
costs associated with a secondary treatment plant In a northeastern
climate and (b) the negligible. If any. water quality benefits to
be achieved through secondary treatment, secondary treatment is
Inappropriate for Boston Harbor. Expanded primary treatment plants
should thus be constructed on the most cost effective basis.
Moreover, in determining final costs for such comparison purposes,
mitigation measures should be treated as an essential element of
each of the project sites under consideration. Site-specific
mitigation measures should be Identified and quantified In dollars.
When that is done, the Commission submits that It will be readily
apparent that primary plants should remain located on the current
Deer Island and Nut Island sites. A Long Island site should be
given the lowest rating. To relocate a primary plant to Long Island
would be unduly expensive and deleterious to the presumably overriding
goal of making the Harbor Into an accessible and enjoyable public
resource.
We recognize that EPA cannot totally Isolate Itself from other
pressures which surround decisions of this sort and magnitude. The
Commission believes, however, that It is Incumbent upon EPA to base
its decisions purely upon the statutorlly-mandated factors. The
record strongly supports the comments offered In this letter, and
we hope that EPA will afford them the most serious consideration.
Francrs W. Gens
Executive Director
FWG/mb
Charles Button
Laura Steinberg, Esq.
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BOSTON
REDEVELOPMENT
AUTHORITY
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March 15, 1985
Mr. Michael R. D«l«nd '
Region*! Admlnl»tr»lor
U.S. Environmental
Protection Agency
Region I
J.F. Kennedy Federal Building
Boston, MA 02203
Dear Mr. Deland:
Re: Site Options (Siting of Wastewater Treatment Facilities In Boston
Harbor) - Supplemental Draft Environmental Impact Statement/Report
The Boston Redevelopment Authority has reviewed the Supplemental Draft
Environmental Impact Statement/Report on the siting options of wastewater
treatment facilities In Boston Harbor and wishes to submit the following com-
ments for consideration.
The Authority recognizes the critical need to upgrade the existing wastewater
treatment facilities In Boston Harbor In order to Improve the condition of the
harbor. We want to assure you of our support for your efforts to resolve
these problems. At the present time, the MDC has embarked upon an immediate
upgrade designed to provide Interim rehabilitation of machinery and struc-
tures at both the Deer Island and the Nut Island treatment plants*. We
consider it extremely important that these vital improvements proceed as
scheduled and that there be no delay In their Implementation pending a final
decision on the siting options described In the supplemental impact statement/
report.
Three of the options under study involve the use of Long Island for the
location of all or part of the wastewater treatment facilities. We wish to state
unequivocally that we oppose the use of Long Island for a sewerage treatment
facility. Long Island has been proposed as an integral part of the Boston
Harbor Islands State Park system and is a significant historic and natural
resource. The approximately 160 acres of the island not occupied by the
Long Island Hospital have the potential to offer unparalleled recreational
opportunities to the residents of the City and region. Long Island's location
in the center of the Harbor Islands and its accessibility make it a particularly
appropriate site for linkage to the other islands. The City is in full agree-
ment with the Department of Environmental Management that Long Island
should be developed as a major center in the Boston Harbor Islands State
Park. To this end, as part of our Harborpark planning initiative, the City
has begun discussions with Commissioner Gutensohn that may lead to the use
of the undeveloped portions of the Island for park and recreational develop-
ment. Siting of • sewerage treatment facility on Long Island would seriously
impair, if not foreclose, any such recreational use of the Island.
As the EIS has clearly indicated, Long Island contains significant archaeolog-
ical and historic resources which might be destroyed should the treatment
facilities be developed here. The primary significance of Long Island is
related to the Early Archaic prehistoric evidence found on the island, the
only such archaeological sites within the boundaries of the City of Boston and
thus unique resources of the City's historic and archaeological past. In
addition, the Island contains over 2,000 marked and unmarked graves, having
served as a burial ground several times in its history. Important natural
resources. Including two wetlands and a barrier beach, exist on the Island,
and would be adversely affected by the construction of sewerage treatment
facilities. Due to these and other factors, the legal and institutional
obstacles to implementation would be severe, and the multitude of approvals
that would be needed could seriously delay, if not prevent, construction on
Long Island. Any unnecessary delay In the construction of the vitally needed
upgraded treatment facilities cannot be tolerated, and would only act to the
detriment of the harbor.
Furthermore, location of the wastewater facilities on Long Island would be
Inconsistent with the Island's present use as a chronic disease hospital and
shelter for the homeless. The shelter, which Is the only shelter for the
homeless operated by the City, provides some two hundred beds, while the
Chronic Care Hospital continues to serve over one hundred and fifty patients.
Long Island plays, and will continue to play, an Integral role in the City's
effort to provide basic human services, and the City is committed to the
maintenance of these facilities. Siting of the wastewater treatment facilities
on Long Island would undermine this commitment by the City. .
While we are sympathetic toward the residents of Winthrop and Qulncy who
have borne the burden of the environmental problems caused by the existing
sewerage facilities, we do not feel that shifting the burden to Long Island is
the solution. There Is no need to destroy this unique resource to provide
the needed facilities. The construction of a primary or secondary wastewater
treatment facility on Long Island would forever eliminate opportunities for the
development of this Island as a major recreational resource In Boston Harbor.
In summary, the future use of Long Island is of paramount concern to the
City of Boston. As an Irreplaceable location for sheltering the City's home-
less and the chronically ill, and as one of the last remaining undeveloped
areas in the City, it offers unique opportunities for the enhancement of the
harbor. The City's Harborpark plan anticipates a time when Boston Harbor
will once again be available for use and enjoyment. The State's Harbor Island
Park will preserve for the public water access and recreational opportunities.
Water quality is a critical issue. The preservation of sites were that unique
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resource - clean water - can be enjoyed by all the people of Boston Is of
equal importance. The future use of Long Island should not include a
wastewater treatment facility.
Sincerely
Steph|
Olreci
cc: Raymond L. Flynn, Mayor
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CITY OF BOSTON
IN CITY COUNCIL
March 6. 1985
ORDER OF COUNCILLOR O'NEIL
ORDERED: That th« Boston City Council vote this day to oppos* the
construction of any Treatment Plant (sewer) on the site of
the Long Island Hospital or any other site located on the
K)
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NJ
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AMENDMENT OF COUNCILLOR TRAVACLINI
Amend Councillor O'Neil's order by Inserting at the end thereof
the following:
FURTHER ORDERED: That Deer Island shall not be considered as a location
for said Sewage Treatment Facility.
In City Council, passed by voice vote
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BOSTON
RESIDENTS
COMMENTS
2-299
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U MOUNT VCHNON mUKT
March 11. 1985
Michael Deland. Regional Administrator
U .3. Environmental Protection Agency
J.P. Kennedy Federal Building
Boston. MA 02203
Dear Mr Delandi
SDEIS on Siting of Wastewater Treatment Facilities
in Boston Harbor
My comments and questions on the SDEIS captioned above
M concern the two decision criteria to which, measured by the number
to of pages devoted to them, relatively little attention has been given.
° 1. Coati two of the determinants of 04M costs are staffing and
chlorination. How was the number of total staff for each site
option arrived at? Why is it necessary to use 750 tons more
chlorine in Primary than Secondary sewage treatment? And why does
the split Deer/Long Secondary option require less chlorine than any
other option? Mention elsewhere in the report of 'seasonal chlor-
ination" at the end of the 9 mile pipe is not discussed and justified
anywhere that I can discover.
2. Rellabilitvi Since the unreliability of the existing plants
leads to frequent bypasses, one would think that reliability was a
very important criterion. It is important to all who swim at beaches
in Boston Harbor. What conditions would lead to greater reliability
of these very costly plants? Consolidation of facilities? Addi-
tional staffing? Less complex processes, i.e. primary rather than
secondary treatment? Privatization of operation? My comment is
that this very important point deserves serious attention.
Thank you for this opportunity to comment on the SOEIS.
Eugenie Beal
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OTHER
OFFICIALS/BOARDS/DEPARTMENTS
ORGANIZATIONS
RESIDENTS
COMMENTS
2-301
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February 28, 1985
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SVIM: Nahant Citiiena Committee to
Seek Hater Improvement Measures
Testimony on 8uppl*al Dratt EI8/EIB on Haatavater Tc<>tneoc Flint Siting io
Boston Harbor
My aim* it Poll; Bradley, and I am Chairman of SWIM, the Valiant Citueue
Committee to Seek Water Improvement Measures. Nshsot ia very much concerned
ahout Boston's sewage treataient plane, because if a waiver of aecondary
treatment ia given and a longer eewage outfall huilt, Nahant will be the
cloeeat point on land to that outfall.
SUIM'a ecientiata and engineera have been looking at the Supplemental
Dratt SIS/EIR on Uaetewater Treatment Flant Siting in Boston Harbor, and I have
a few comments to make. First of all, we were ahockcd to eee that the report
dealt alaoit entirely with inner harbor pollution problema, ignoring the
existence of Nahant and of moat of the rest of the world outaide the narrow
confines ot Boston Harbor. Boeton muet not create a plan which would clean up
Boston by traoeferring the problem elaewbere.
1 spoke laat week vith Dr. Kenneth F. Sebens, Director of Northeastern
University's Marine Science and Maritime Studies Center at Cast Point, Mahant,
who oas looked at the current document. Hortheascero's laboratory is on the
point of land in Nahant wbich would be closest to the proposed Boston outfall
if a waiver ot secondary treatment is granted, and as I said Nahanc would be
the closest town on the mainland. Dr. Sebens was very much concerned about the
limited scope ot the Biological work in tnis EIS/EIR. He commented tnat there
were no sampling sites near the proposed outfall and no baae line studies out
*
of the inner harbor.
On the map showing tne location of the Marblehead Foul Area (Fig. II.2.6)
Nahant waa simply chopped off! He object I Hot only are we the closest point on
land to the propoaed Boatoo outfall, hut we are about as close to the Foul
Area as Marblehead - it could aa eaeily be called the Nahant Foul Area. He
were diatreaeed to read in the text of the N8/EIR about consideration of
dumping the dredged materials and eludge from Boston into the Foul Area. Since
that time we nave been reaaaured to hear that another entire EIS/EIB will be
required concerning diapoaal of sludge and that the Foul Area is only a remote
possibility for sludge. He will be watching the EIS/EIR on sludge very
carefully.
I do nave one queetion. Hill there also be a separate EIS/EIB on disposal
of dredged materials! The commenta in the document under consideration tonight
are brief, and we want to make sure we are fully informed ae plena are
coneidered.
Dr. Michael P. Manning ot Nabant Engineering and the Massachuaetts
Institute of Technology has also studied the EIS/EIR, and he testified last
night at the hearing in Cambridge. 1 would like to second bis comments and
urge that you study them carefully.
Thank you for this opportunity to testify.
7%
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APPALACHIAN MOUNTAIN CLUB
fIVE JO! STRICT BOSTON, MASSACHUSETTS 02108 617-523 0436
Commanta of tha Appalachian Mountain Club. Beaton Chaptar
Conaarvation Committaa on tha Supplamantal Draft Environmantal
Impact Statamant/Envlronmantal Impact Raport tSDEIS/EIR) on Siting
of Waatawatar Traatmant Facillttaa in Beaton Harbor.
Community Impact can not ba ovarlookad in thia siting daciaion.
Any auccaaaful aitIng affort muat includa mitigation and
companaation to tha hoat community. Tharafora tha final EIS/EIR
coat aatimataa muat Incorporata tha total coata of approprlata
altigation. Wa faal howavar, that although conaidaration of tha
coata of mitigation la Important, thaaa coata alona ahould not drlva
tha aiting daciaion.
Finally, tha Commonwaalth and EPA muat not maka long ranga
daclalona on tha baala of ahort tarm critaria.
Daar Hr. Daland,
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Tha praparation of tha joint EIS/EIR on Siting of Waatawatar
Traatmant Facilitiaa in Boaton Harbor im a critical atap in tha
claan up. Wa ballava tha critaria muat anaura that any naw
waatawatar traatmant facility ia afflciant, technically aound. and
ainimizaa nagativa impacta to tha natural anvironmant and hoat
community. Tha critaria muat ba comprahanalva and walghtad
appropriataly; critaria of graataat importanca ahould hava tha moat
aignificant int'luanca on tha final daciaion.
We accapt tha mix critaria praaantad in tha SDEIS/EIR. Of tha
alx. Harbor Enhancement* Praaarvation of Natural and Cultural
Raaourcaa and Railability ahould ba walghtad moat haavlly.
o Harbor Enhancamant auat carafully balanca racraatlon, public
accaaa, and acanlc valua with aconomic development.
o Praaarvation of Natural and Cultural Raaourcaa nuat
acknowladga that Long Ialand ia an intagral part of tha propoaad
axpanalon of tha Harbor lalanda Stata Park. In kaaping with
thia plan, tha laland ahould not hoat a waatawatar traatmant.
plant or any othar development inconaiatant with park uaa.
o Syatam Raliability muat alao ba avaluatad, Wa can laarn
aomathing from tha paat; don* t chooaa lower initial capital
coata ainca thia may laad to long tarm ayatam fallura or
unreliability 1 Tha final EIS/EIR muat axplicity axamina tha
coata of adequate aquipmant and technically aound faci1ity
daaign.
Sincaraly,
ir . TrU^
Ell.n Tonn
Ann U«.k«
Eric Rudar
Boaton Chaptar Conaarvation Committa
tt
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Wotdh. Shots.
HAhCH 6, 1985
Dear Administrator Deland
I am writing this letter as a concerned citizen, to express my
opposition to the expansion of the Deer Island Sewerage Treatment
^ Plant. But my opposition comes not as a resident of «finthrop, but
^j as a scuba diver who enjoys diving the entire coast line of
O Massachusetts. In my many years of diving I've found the Boston
Harbor waters.to be the worst (as far as pollution) in this state.
Huch of the pollution is due to the Deer Island Sewerage Treatment
Plant. No one knows this better then the scuba divers. Everyone
can see the pollution on the surface, but once below the surface
only the divers can see the true destruction these sewerage treatment
plants have done to our ocean. Every day millions and millions of
gallons of poorly treated sewerage is pumped into the ocean, with the
hopes that the ocean can take care of it. The ocean hasn't been able
to due this In the past. You can't possibly think this condition ..ill
Improve in the future. Not when the plans call for putting more
vaste water into it. The time has come to atop the sewerage treatment
plants from pumping their waste into the ocean.
Sincerely
Frederick U nfeil Jr.
President
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115 West Emerson Street
Helrose, HA 02176
February 26, 1985
Secretary Hoyte
Massachusetts Executive Office
of Environmental Affairs
100 Cambridge Street
Boston, MA 02202
Dear Secretary Hoyte:
Enclosed please find my comments on the SDEIS on the
Siting of Wastewater Treatment Facilities in Boston
Harbor for your consideration.
Sincerely,
CRITIQUE Of
SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT STATEMENT/REPORT
ON
SITING OP WASTBWATBR TREATMENT FACILITIES
FOR BOSTON HARBOR
FOR UEP 267
ANALYTICAL REQUIREMENTS OF ENVIRONMENTAL REGULATION
MR. JOHN WILSON
February 11.1985
Sarah L. Warner
Review and Comment
By Sarah L. Warner
RECEIVED
MARl 635
OFFICE OF THE SECRETARY
OF ENViaONMENVsL .-hMRS
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Preface
The following critique wag prepared to fulfill a course
requirement of UEP 267 offered by Tufts University. This
critique was not prepared for, or under the auspices of, the
author's former employer. The contents herein are solely the
opinion of the author.
General
I offer the following comments on the Supplemental Draft
Environmental Impact Statement/Report (SDBIS) on Siting
Hastewater Treatment Facilities for Boston Harbor, signed
December 28/31, 1984. On a positive note I compliment' EPA on
their presentation of the Issues confronting declslonmakers. I
believe the documents provide the most all-inclusive and
understandable presentation on this subject to date.
Unfortunately, their value as tools for communication to the
public and declslonmakers la sorely limited by their lack of
depth and breadth- The documents do little more than compile the
masses of information available in a decade worth of past
reports. Although this is an Important step, the real Issues
have yet to be tackled. The SDBIS provides little in the way of
conclusions or preferences by declslonmakers. He are now more
fully aware of the Impacts of 7 different alternatives but we are
not aware of what. If any, systematic approach will be used to
compare these alternatives or to weigh their Impacts. The matrix
of Impacts provided in the summary is informative but not
indicative of what's better or worse. The 7 decision criteria
represent Important Issues facing declslonmakers. But what is
the mechanism by which impacts and criteria can be evaluated more
analytically than judgmentally?
More troublesome than the lack of conclusions or a
methodology of arriving at them, is the decided non-evaluation of
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Issues pertaining to what Is really needed and when It should
occur In the massive effort ahead to clean up Boston Harbor. The
real problem facing declslonmakera now. la what to do now. Which
of the three Islands should be used for primary and secondary
treatment facilities Is truly a significant public Issue,
however, In terms of the total problem, decisions, and their
resulting Impacts, It Is but on* of many consequential items.
The remainder of this paper deals more specifically with
these and other weaknesses of the SDBIS as I see then. Discus-
sions of the Scope of the Evaluation and the requirements and
Intent of NEPA are followed by comments on specific sections In
Volume 1 and Voluae 2. Thereafter, some comments are offered on
other points made In the document, followed by a brief summary.
Scope of the Evaluation
NEPA requires that all major Federal actions with a
potential for significant environmental Impacts be accompanied
during declalonmaklng with the preparation of an Environmental
Impact Statement. One of four specific purposes stated In the
Act is "to promote efforts which will prevent or eliminate damage
to the environment and biosphere and stimulate the health and
welfare of nan*. In Section 102(2), the Act states that 'the
policies, regulations and public laws of the United States shall
be Interpreted and administered in accordance with the policies
set forth in this Act...*. This section continues with the
actions required by all Federal Agencies.
In regard to the SDBIS, I believe three major flaws exist
In the spectrum of issues and alternatives considered!
1. The document does not consider as part of its detailed
evaluations the preferred alternative of the
Commonwealth's Siting Study, namely upgraded primary
treatment with local outfalls. Although it is stated
In the Final Screening Report that this alternative
was eliminated because 'extended outfall with primary
treatment is the stated preference of the
Massachusetts Executive Office of Environmental
Affairs and Is the alternative submitted by the HOC
under the federal review of a waiver from secondary
treatment *(pg. 1-2), the NEPA requirements are quite
clear that neither policy nor existing law or
regulations unto themselves preclude the evaluation of
a reasonable alternative. The law is interpreted on
this point by CEQ In the Federal Register, March 23,
1981, where it is made clear that a 'reasonable number
cover log the full spectrum of alternatives' must be
analysed and compared in the EIS.
As to the Commonwealth's- position on this matter, the
origin of the footnote referenced above is unclear.
Secretary Boyte's Memorandum of September 9, 1983
entitled,' Certificate of the Secretary of
Environmental Affairs on the Environmental
notification Form, Site Options Study*, states in
Section IIB (Hi) that 'Although I, Commissioner
Cortese and Commissioner Geary have taken a firm
position In favor of primary treatment with deep ocean
outfalls, I considered it appropriate, for comparison
.purposes, that the EIR discuss water quality impacts
of all alternatives Inlcuding primary treatment/local
outfalls.* Secretary Hoyte's approach Is very similar
to that Intended by- NEPA and to that which' should have
been taken by EPA.
2. EPA should evaluate the No Action alternative In the
SDEIS. The purpose for evaluating the required. No
Action alternative is clearly interpreted by CEQ in
the March 23, 1981 Federal Register, where it is
explained that this analysis provides a benchmark
enabling decislonmakers to compare the magnitude of
the environmental effects of the action alterna-
tives. More than that provided by baseline data,
this analysis predicts the resulting environmental
effects from taking no action.
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3. The document acknowledges that two decisions oust be
Bade, |1) the level of treatment to be provided, and
(2) where the resulting facilities are to be sited.
The separation of these decisions and the elimination
of the more critical of the two from the BIS process,
what treatment level Is needed, seems an Inappropriate
approach to declslonmaking by EPA. If this most
Important Issue of far reaching environmental
consequences la not being addressed by EPA In this
BIS, then where and when will these alternatives be
evaluated, compared and made public for review?
Although the 301 (h) waiver regulations provide
decision criteria based on water quality Issues, NEPA
requires a quite different approach to major actions
with the potential for significant environmental
effects. I have yet to find any preclusion of NEPA
requirements with respect to the waiver process. On
the contrary, I think NEPA is quite clear that the
spectrum of all reasonable alternatives to a major
action must be evaluated fully and that administrative
policies, regulations and public laws be Interpreted
In accordance with the policies of NEPA.
The environmental consequences which may result from
requiring and implementing secondary treatment in the
near future (i.e. 7-10 years indicated In the Impact
matrix) could be severely adverse when compared to the
Incremental gains in Harbor water quality achieved by
this effort. I refer to the impacts associated with
expending all available monies on such a project while
oore significant pollution problems remain
unaddressed. The SDEIS acknowledges there may be
limited improvement In water quality without
implementing other cleanup projects, especially those
directed at sources which plague shorelines, beaches
.and shellfish beds. A detailed discussion on user
costs and financial impacts is presented later In this
paper, however, it becomes obvious that all 1.7
billion dollars of projects cannot be Implemented at
once.
Higher levels of treatment will produce larger volumes
of sludge which must be handled at the same time.
These additional costs .for sludge disposal, not
Included In the SDEIS, together with the treatment
costs identified, would drive user costs above those
of any other City In the O.S. (based on SDEIS
figures) , and perhaps above what the community can
reasonably pay by 199S.
BPA's decislonmaklng oust evaluate the spectrum of
treatment and disposal options in order to provide a
framework within which the very difficult decisions of
frlorltlilng cleanup projects can be made. These are
he analyses that NEPA requires. These are the
analyses where benefits. Impacts, costs and needs will
be identified, quantified and compared. The NEPA
regulations state in Section 1502.1 that
•It..IBIS]..shall provide full and fair discussion of
significant environmental impacts and shall Inform
declsionmakers and the public of the reasonable
alternatives which would avoid or minimize adverse
impacts or enhance the quality of the human
environment.* For every possible cleanup plan there
will be significant environmental Impacts due to those
projects which are not Implemented until the time and
money allow.
Volume One
I believe the purpose and the need for action now is well
understood. However, I question the presentation of the
significance of the Issues as provided in Section 1 of this
Volume. The treatment plants are cited as the source of
significant pollution loads to Boston Harbor. A statement which
is seemingly supported by Table 1-1, Pollutant Loadings to Boston
Harbor. Is the reader supposed to see that, with the exception
of collform, the flow, 8005 and SS from the plants are the
largest numbers and therefore conclude that these must be the
most "significant" sources? Without interpretation of their
meaning (I.e. the Impacts of these loads) the table Is of no
use. For example, flow in Itself is of the little significance
in comparison to what It contains. Is 8005 bad? What impact
does it have? Solids? Collform? Interestingly, at the end of
Section 1 the other sources of pollutants are described. These
discussions are where the real Impacts on Boston Harbor are
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noted) water quality violations, posting of beaches, shellfish
b- '~«ures, floating sewage, oil and grease, and accumulation
of sewage debris at shorelines. The Draft Hater Quality Baseline
Report provides three major findings, one of which states In part
'Moat waters In Boston Harbor meet the water quality standards
established by the Massachusetts DHPC.* This finding goes on to
say that the water quality around the outer harbor Islands and
Hlnghao Bay Is the highest, while the northern harbor area has
the highest concentrations of pollutants. It also states that
the Inner Harbor and nearshore waters frequently fail to meet
minimum water quality standards. The body of the baseline report
provides even more, explicit impacts such as the statement that
'the most significant harbor uses which are impaired or precluded
by poor water quality are swimming and shellfIshlng" (pg. 3).
These statements and others, found within the SDEIS, the 301(h)
Waiver documents, the CSO studies and many other reports
discussing Harbor water quality, imply the significance of other
sources, perhaps outweighing the significance of the plant •
effluents.' However, since no quantification of impacts and their
environmental costs has yet been prepared for comparison of
sources, the significance of each can only be subjectively
deduced by source location, dilution of the waste, and the type
of waste. On these characteristics, the plant effluents being
treated and discharged to the main shipping channels of the
Harbor, where velocities are the highest, become much less
significant.
Briefly, two additional points must be made about the
basis of comparisons of significance made in Section 1. First, a
statement is made that 135 tons of dry solids are discharged In
the effluent, while 75 tons are discharged in the sludge
(pg. 1-1). Hhlle this may be a true representation of
quantities, the characteristics of these solids are very
different. Sludge solids settle on the order of 10 times faster
than effluent solids. Sewage solids are known to be associated
with toxic compounds which are adsorbed from the wastewater.
Sludge is composed of the sewage solids which settle out during
the sedimentation process. In addition to water quality, a major
area of environmental quality concern is the condition of harbor
sediments and the condition of the marine community associated
with them. Effluent solids may well be of higher magnitude In
tons, but the Issue of which solids are retained wlthln'the
Harbor as sediment, and which contributes most to the high metal
concentrations of these sediments is far from resolved.
Second, I believe Table 1-1, and a similar presentation of
solids data by source provided in Figure 11.3-14, obscure (acts
rather than enlighten us to the comparative impacts of the many
sources. Comparing on an annual basis, intermittent sources
(such as those which discharge during wet weather or river, inputs
which vary greatly over the year) to continuous sources is a
gross misrepresentation of the situation. A lower strength
continuous source, such as the plant effluents, though larger in
total load at the end of the year, may well be of far less
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consequence environmentally. Continuous ailing of the discharge
and flushing froa the Harbor maintain receiving water
concentrations at a much lower level. This/ In part, explains
why the apparently 'leas significant* sources are where water
quality violations occur. Hater quality Is not evaluated
annually. Net weather, dry weather, waste characteristics of the
discharge, and receiving water characteristics at the discharge
are the factors which are pertinent to Boston Harbor pollution
and Its control.
As such, the discussion of Actions Resulting from the
SDBIS misses the crux of the pollution issue. If EPA and State
decisions on the SDEIS as presented 'allow the design and
construction of wastewater treatment facilities to begin"
(pg. 1-8), little will be gained In overall Harbor improvements
The cost of the wastewater facilities alone may preclude any of
the other cleanup projects for a very long time and the hope for
'significant Improvements in harbor-wide water quality* becomes
an unobtainable expectation in the near future. Again, a
quantification of Impacts and environmental consequences will
provide a basis for prioritizing cleanup projects. When the
ongoing Improvements are complete at the treatment plants which
will reduce plant failures and raw sewage bypassing, the effluent
from these facilities will likely be of comparatively little
concern during the early stages of a Harbor cleanup program.
Volume 1
My review of Volume 2 concentrated on the sections
pertaining to water quality, costs, and financial Impacts, and
therefor* the following comments do not address the substance of
the other Issues.
Water Quality. Given the previous comments on Harbor
water quality and interpretations of significant pollution
sources, I forego further discussion of this issue. Although
somewhat obscured in the summary provided In the main SDEIS
documents, the Draft Water Quality Baseline Report portrays a
more meaningful representation of water quality data as It
relates to areas «f the Harbor and different sources. Still
however, this document summarizes the results of many different
studies conducted at different times for different purposes. The
lack of a comprehensive measurement program which Is designed
specifically to determine the relationship of 'sources and their
Impacts to differences In water quality, sediment quality and
marine biota at shorelines vs. the Inner Harbor vs. the Outer
Harbor, under wet, dry, and seasonal Influences, is a limiting
factor in the quality of baseline determinations.
while the scope for this SDEIS states that 'Hater quality
issues to be examined will be limited to impacts of siting.and
secondary effluent quality discharges* it also states that *A
review of the broad comparative effects of primary vs. secondary
effluent will also be generlcally addressed...*. The exact
meaning of these statements eludes me, however, the presentation
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on wastewater and affluent characteristics and resulting
discharge effects are problematic on several counts. Generally,
this section presents a large volume of Information but little
Interpretation of It. For example, the discussion on the Initial
dilution modelling for the Harbor discharge does not actually
provide an expected Initial dilution factor. Nor does the
presentation on secondary treatment removals of toxics provide a
basis for the assumed removal rates applied to the HOC wastes.
The following comments are limited to four issues only) the
Implied removal of toxics by secondary treatment! the ambiguity
of measurements of toxic concentrations in MDC'a wastewater and
effluentsi the comparative effects of primary vs. secondary
effluenti and the Issue of PCBs. *
In Section 11, two tables are presented Illustrating
percent removals of metals from wastewater at operating secondary
treatment plants. These data provide little insight as to what
could be expected from secondary treatment If applied to MDC'a
waste. First, the data Itself shows the extreme variability in
removal efficiencies. For example, copper removal for secondary
plants was reported as 57 percent and 84 percent in the 1977 and
1982 surveys, respectively. The most extreme case Is cadmium
removal, reported as 17 percent in 1977 vs. 85 percent in 1982.
Although the 1982 data is more recent and may reflect Improved
plant performances, the survey is based on much fewer
facilities. Therefore, the Impact of variability of the many
factors which may Influence these removals is less likely to be
reflected In the 1982 data set. In 1977, 34 to 63 facilities
were sampled for metal removal efficiencies compared to 6 to 22
facilities in 1982. For the case of cadmium, the 17 percent
removal was based on the operations of 44 plants, while the 85
percent was based only on 6 plants.
Toxic removals resulting from secondary treatment are not
a phenomenon that is well understood or predictable. The SDEIS
notes that the removals Indicated in the tables may not be
achievable in large treatment facilities such as the HDC'a. In
addition to sixe, MDC's wastestream Is diluted by high I/I
volumes which will have an Impact on removal efficiencies. The
state-of-the-art «f wastewater treatment la not such that
conventional secondary treatment schemes, such as the proposed
activated sludge process, can be designed for specific removal of
metals and toxics. Removal performance is highly conditioned on
process characteristics and wastestream characteristics. The
actual mechanisms of removals and methods of prediction are
current topics of research. Predictions of removals at this
point are not possible. Source reduction. Irrespective of
treatment level, seems a more reasonable approach to the control
of toxics.
Two data sets are currently available with which to.
characterize the metals concentrations of MDC's effluent. There
exists orders of magnitude discrepancies between the data taken
by grab samples and reported monthly vs. the data available from
short term composite sampling conducted during the 1978, 1979,
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1982 and 1984 field programs associated with the 301(h)
investigations. There are many possible reasons for the
differences. The SDBIS chooses to use the monthly data which
represent much higher concentrations; a reasonably conservative
approach if verification was unobtainable. However, a
determination of the validity of the 301 (h) data is extremely
Important since these results provide the only data for the
entire 128 priority pollutants. Therefore, I question EPA"a
decision to neither use nor verify this data set. Over the time
frame of preparation of this SDBIS priority pollutant samples
lo could have been analysed over a range of seasonal conditions.
CO Metals and their purported potential for water quality violations
N> are a very significant issue. If evaluations are to be made
about critical dilutions and relative contributions, then a
reliable data set should be the basis of any such determinations.
An interesting observation can be made about the
comparative effects of the alternative primary vs. secondary
treatment schemes. Two of the most frequently cited pollutants
of concern are copper and suspended solids, so I will use these
for illustration. Under the conditions of minimum 10°percentlle
current and maximum stratification at the deep ocean disposal
site, an initial dilution of 141 is projected. Dnder conditions
of 50 percentlle currents and with and without stratification,
initial dilutions will be 200 to 700. Within the Harbor, the
Initial dilution factor expected by EPA Is not clear. Previous
Investigations during the Site Options Study determined that a
dilution of about 40 could be attained at the proposed Harbor
discharge location. The major difference in'magnitude being
quantities of dilution water, discharge depth and mixing. In the
case of copper, using HDC's monthly data for the basis of the
combined effluent concentration after primary treatment, as done
in the SDBIS, the concentration expected for the discharge Is
0.3463 mg/1. If It is optimistically assumed that 84 percent
removal is achieved by secondary treatment, then a combined
discharge concentration of 0.0736 mg/1 would be expected for this
situation, as put forth In the SDBIS. A comparison of resulting
receiving water concentrations after 'initial dilution shows that
under minimum dilution of 141, a copper concentration of
0.002 mg/1 will result (0.3463 » 141) following primary treatment
with an ocean outfall. Coincldentlally a similar calculation, at
a dilution of 40 at the Harbor location following secondary
treatment, results In the same receiving water value of
0.002 mg/1 (0.0736 r 40). In the case of suspended solids, a 30
mg/1 effluent concentration after secondary treatment results in
a 0.75 mg/1 concentration In the receiving water after
dilution. For upgraded primary with the deep ocean outfall, an
effluent value of 65 mg/1 results In an after-dilution value of
0.46 mg/1, under minimum mixing conditions. At 200 to 700 .
dilutions, copper and S3 concentrations would be .0017 to .0005
mg/1, and 0.33 to 0.09 og/1, respectively. It should also be
noted that the calculations presented actually represent the
added amounts of copper or solids to that already existing In the
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receiving water. Because waters In the Harbor flow In and out
with each tidal cycle, a net flushing of the Harbor occurs
overtime, however, a complete purge la not achieved each cycle.
Some of the waters which leave on the ebb tide return on the
flood tide as do the associated contaminants. Therefore, a true
Initial dilution value for the Harbor is more difficult to
define. At the deep ocean site, this condition Is less of a
problem since a continuous net movement away from the dlffuser
will occur. Therefore, only the background concentrations of the
dilution waters of Mass Bay will be contributing to final
receiving water concentrations.
The Issue of PCBs in plant effluents, in Harbor sediments.
and relating to fish disease, has caused much concern during
recent deliberations. I question the validity of this issue as
It relates to the treatment plant effluents, since no determin-
ations as to the source of PCS'a in the Harbor has been made, but
more Importantly, in light of the data base In total. PCB
concentrations are reported for sampling conducted in 1978, 1979,
1982 and 1984 as part of 301(h) investigations. Of all this
data, in only three tests, all'conducted in 1978, did PCB
concentrations occur at levels high enough to project water
quality violations given upgraded facilities. Subsequent years
of sampling have shown greatly reduced concentrations. Perhaps
this reflects the Impact of regulations banning PCB manufacture
and controlling their disposal. In any case, the fact that PCBs
are thus controlled, greatly reduces the long term importance of
ttis issue as it relates to MOC's waste, particularly to the
e.fluent. It hardly seems appropriate to decide to construct
secondary treatment facilities based on this issue.
Given the foregoing points, one specific comment about the
SOBIS treatment of PCBs relates to the critical dilution cacula-
tlon. Dae of the highest measured concentration to obtain a
value of 1272 dilutions (Table 11.3-12) seems very inappropriate
for the Intended purpose of making judgments on impacts.
Costs. The most significant issue in regard to costs is
the basis for costing the secondary settling tanks. The 5230/aq.
ft. unit cost used in the Site Options Study vs. the $112/sq. ft.
unit cost applied-in the SDEIS changes the total cost of the
secondary alternatives by 15 percenti an amount in esceas of $130
million. Given the magnitude of the changes in the total capital
cost of secondary alternatives due to this discrepancy, the basis
of the unit.cost actually used should be as accurate as
possible. To Insure credibility in whatever value is used, I
suggest verification through comparison of actual construction
costs with other large secondary treatment facilities that have
been built.
k second point relates to eliminating the cost of sludge.
facilities as Included In the Site Options Study. I question the
basis for disregarding sludge disposal costs since they are
coincidental with treatment facility construction, and as a rule
of thumb are equal to or greater than the cost of the liquid
stream treatment. The Impact of this Issue will be discussed
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further in the following section on financial Impacts. If sludge
facilities are to be renoved from the costing of the siting
alternatives! then the credits Incorporated Into the annual DIM
costs for digester gas use as primary fuel for the engine
generators must be compensated for in estimating power costs.
Further, though likely insignificant, the cost of the engine
generator facilities, if not primary power facilities, would
change due to reduced sise and costs of facilities related to
dual fuel provisions.
The decision to screen out the primary/local outfall
alternative is particularly significant when considering the cost
issue. Review of-the costs of the primary alternatives
considered shows that the long outfall la about SO percent of the
total project costj certainly a factor to be considered. In
approving grants under the Construction Grants Program, EPA must
consider the cost effectiveness of the proposal. The selected
.alternative must be demonstrated to be cost effective. In
Construction Grants 1985 (CG-85), EPA states that the selected
alternative must be shown "to be the most economical means of
meeting applicable effluent, water quality and publlc'health
requirements over the design life of the facility while
recognising environmental and other nonmonetary considerations".
Further, the cost issue is of major importance to the
comparison of primary vs. secondary alternatives) a consideration
which at some point must be addressed. The costs associated with
doubling sludge volumes requiring disposal from 110 to 200 dry
tons per year, and tripling energy requirements for secondary
processes from 9 Billion to 30 Billion KWB per year could prove
to be major factors in declslonmaking as it is framed by NEPA
policies.
Financial Impacts. This discussion magnifies the
weaknesses in the approach taken in the evaluations presented in
this SDBIS. The evaluation as presented provides the reader, or
•ore importantly the current HOC system user, with little
information on the Impacts of the decision(s) ahead. To evaluate
the Impact on user costs of wastewater treatment plants without
considering the cost of disposing the resultant sludge from that
treatment is meaningless. In the example of a Boston user's cost
Impact presented in the SDBIS, the present charge of $80 will
increase by an additional $80 to 100 per year. 'The user costs
reported in the SDEIS for other large cities range from $100 to
$160. Given the SDBIS figures, the new Boston user charge will
be $160 to $180 without including the costs for sludge facilities
or any other of the many needed sewer system and CSO Improve-
ments. After Incurring this cost Increase, the closure of
beaches and clamflats due to raw sewage overflows will still
occur. If one assumes sludge disposal costs will be of a similar
magnitude as wastewater treatment costs, then the resulting user
fees will far exceed that of any of the other Cities cited. If
the entire $1.7 billion cleanup program is considered, user costs
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would be $150 to $250 higher than present charges! a 1 to 4 fold
Increase assuming 50 percent funding. The need for priortlilnq
projects becomes very clear.
Other Comments
The following list of questions and comments came to mind
while reviewing the SDEISi
Why are the mitigation costs presented In the summary
document the same for the primary and secondary
alternatives when construction years and costs are
different?
Given the environmental concerns about the Impacts of
chlorinated effluent on receiving waters biota, the
assumption that post chlorlnatlon with a deep ocean
outfall would be required only 6 months of the year
becomes a positive environmental factor worth some
consideration.
The deteriorating HOC water system and its future
demands on the Water Resources Authority's yearly
budgets and on annual user costs must also be
considered In determining acceptable user cost
Increases and the timing of expenditures.
The Issue of filling at Hut Island must be evaluated
since this is part of HDC's preferred plan. It seems-
Inappropriate to consider filling to be an adverse
impact on the basis of existing State law or the 'need
for Federal permits when the SDEIS states that for the
alternative of upgraded primary facilities at Nut
Island there will be no Impact on natural resources.
Without significant Impact, permits for filling should
be obtainable.
The Impacts of stormwater drainage from urban areas to
the Harbor shoreline, though presently unquantlfled,
could potentially be of major consequence in the
quality of nearahore waters and sediments. Storm-
water has been shown to have high concentrations of
certain metals and other priority pollutants.
What Is the Impact of 80 to 120 truck deliveries per
barge trip at the location where barge trips will
originate?
Summary
The problem of cleaning up Boston Harbor Is ominous,
financially and loglstlcally. To date the problem has totally
overwhelmed us, obstructing declslonmaklng and progress. Doing
nothing In response to over-aged facilities and Illegal sludge
discharges for a decade or more, has surely caused the most
detrimental environmental consequences of all. As we wait,
system deterioration aggravates the problems faced.
It's time to take a broader view, to disentangle ourselves
from the less significant Issues^, and to focus on the total
problem. A suitable mechanism by which EPA and the State can
attack the problem is through the BIS process as prescribed by
HEPA, where alternative actions and their environmental
consequences are evaluated fairly and fully.
If the 301(h) Waiver is denied, secondary treatment is
•required by law* but to no greater a degree than are the other
abatement projects to eliminate or control unlawful discharges.
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An assessment of the full spectrum of actions, from doing
nothing to providing facilities commensurate with our ultimate
goals, should be performed. Bach of the separate BIS'a and
decisions being Bade by EPA influence greatly the outcome of the
others when considering the total program needed to clean up •
Boston Harbor. It's time to take a whollstlc approach to define
the benefits gained and costs Incurred by decisions which commit
Halted resources, financial or otherwise. Of the si* decision
criteria identified, I would add a seventh. Prloritlxation of
projects should weigh the advantages of those alternatives whose
implementation provides the earliest payback In Improvement in
the envlronmental~quallty of the Harbor. An example would be
combined upgraded primary at Deer Island vs. separate upgraded
primary facilities at Deer Island and Nut Island. Separate
facilities would allow staged improvements to be realized In
Harbor water quality. The combined facility could not be used
until treatment plant construction, cross harbor transport and a
combined capacity outfall are fully constructed. These types of
consequences when evaluating tradeoffs, must also be considered,
given time and financial constraints.
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45 Uoodruff Rd.
Valpole, Ha 02081
March 8. 1985
Regional Administrator
Environmental Protection Agency
John F. Kennedy Building
Boston. HA 02203
Attn: Michael Deland
I want something POSITIVE done about the pollution in Boston Harbor. Therefore
I support any legislative bill that will start a dedicated effort toward
cleaning it up. Over the last twenty years the people of Massachusetts have
lost a valuable natural resource which is the beach area around the whole
Boston Harbor. Swimming at the local beaches, which was once a major
recreation for the residents of Greater Boston, is no longer possible due to
the pollution levels during the summer months. The once crowded beaches from
L-Street bath house to Ueyntouth are now empty because of the unsightly and
unhealthy water conditions. Recreational sailing, which was another very
popular local sport, has diminished drastically because of the water pollution
levels. Many other shore-related activities could be given as examples of the
deterioration of this natural resource.
Over the past forty years I have observed the attempts of the State to handle
the pollution problem. I see the attempts of trying to solve the whole of
Eastern Massachusetts sewer problems by slowly expanding the two existing
sewer treatment facilities and dumping the steady overflow directly into the
harbor. The present plans for further expansion of these facilities is just a
continuation of the existing plan, which we already know does not work. The
expansion of the facilities will never keep up with the increasing population
of the suburban communities that pump their raw material to the shore for
treatment.
The pollution cleanup plan should consist of the following:
Each city and town should have their own primary treatment center and pump
their treated sewage material to the shore for central pumping to an outlet
more than six miles offshore. Each city and town should be made responsible
for expanding its facilities to keep up with its population growth. The two
existing facilities should be used strictly for treating and handling the
Quincy and Winthrop material and for supplementary pumping the treated
material from the surrounding towns. Additional pumping facilities should
be added to the network to handle the volume from the North and West of
Boston.
1 know that the solution to a runaway pollution problem is not an easy and
inexpensive one. But, whatever the cost and the long-term schedule
requirements, we must get going on it. We owe it to ourselves and the next
generations of Greater Boston residents.
truly yours,
John F. Healy
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Avon, HA. 02322
March 13, 1985
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Mr. Deland
EPA Regional Office
JFK Federal Building
Boston, MA.
Dear Mr. Delandt.
I would like to object to the current plans being considered
for dumping sewage Into the inner or outer harbor. I don't like
eating fish loaded with metals, chemicals, and carcinogens, espec-
ially when the effects on me are unknown but suspect. V.'hy take
that risk? You noted on page 11-3-33(botton) of volume 2, Supple-
mental Draft of the Environmental Impact Statement, that there
may be risks to peeple from the fish. I want protection! There Is
a big fishing area out there whose fish are eaten by a great many
people from all over the world.Solving a problem In the Inner
harbor and creating another problem outside the harbor Is not
the type of solution I want. Forming carcinogens by adding large
amounts of chlorine to the sewage Is not what I would call a
solution either. It's another, long term health problem that
won't be solved. The use of ozone to treat at least some of the
sevage would be a partial solution. I don't like any of the
choices under consideration. They are not solutions. They are
future problems.
The only feasible plan that I can see is a split system:
one long pipe carrying primary treated oaterlal and ) short-pipes
rylng primary and secondary treated material. This system will
accomplish what Is wanted for the harbor:
1. A clean harbor
2. Cut down on pollutants In the inner & outer harbor
(2)
3. Minimize damage to fish life
W. Provide the maximum environmentally sound policy.
This Is the only plan that makes sense.
Since ay system Is different from yours, I would like my
system evaluated and considered. Do a computer slmllated analysis
to compare the results with the present proposals. I am available
for consultation and further details. This system can be licensed
for use. I think the harbor will be better Inside and out, and the
fish will be In better shape, and so will the people eating the
. _..v«.
fish. This system takes In the total picture. Your choices solve
one problem, but create another.
Sincerely,
- . : -T- / /"'
-£_u t (!/;;..-
Arthur P. Clasby
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COMMENTS ON THE
SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT STATEMENT
ON THE SITING OF
WASTEWATER TREAT!,£NT FACILITIES IN BOSTON HARBOR
Submitted by: Nancy ^cConcack. Philip loherty, and Pierre Zrvllle
We have taken the time to research the Boston Harbor waste treatment
situation and have read and discussed the SDEIS submitted by Region I EPA at
.the end of 1984. The following contains our comments concerning both the •
content of the SDEIS and the methodology used In preparing the document.
The first area we would like to address concerns the KOC's second
application for a 301 (h) waiver of the secondary treatment requirement.
Nowhere In the two volumes of the SOEIS Is It explained why such a waiver Is
being sought, why (In detail) the first application was rejected, nor how the
second request differs from tire first, ether than calling for an effluent
discharge about nine all in Into the Massachusetts Bay. We would also like to
see an analysis of the consequences of denial of a permit renewal at the
primary level, at-a five-year review point. An attempt at such an analysis In
the SDEIS does not exist.
In terms of objective comparisons, this SDEIS seems extremely weak. A
matrix methodology was employed that attaches only three possible values to
each Impact cited: severe, moderate, or minimal. This failure to use a more
specific, quantifiable approach, a l-to-10 system for Instance, results In
such vague valuations of Impacts as to make any attempt to aggregate Impacts
of any given option Impossible. At the very least, a more precise grading
system should have been employed for those easily quantifiable values such as
costs, land area, and time needed to complete construction. As Is, the SDEIS
RECEIVED-EPA
MAR 1 o 1935
WATER QUA1ITY BRANCH
provides no methodology by which as objective comparison can be made.
In addition, there were no priority values assigned to the Impacts
considered. Is the Impact on traffic considered more Important than the
Impact on archeologlcal and historic resources? Does the cost have a higher
priority than protecting environmentally sensitive areas? Are all Impacts
considered equally Important? Tha fact that no priority values were given In
.this SDEIS makes any evaluation of the seven alternatives considered a highly .
subjective proposition.
As to the alternatives presented In this SDEIS. we question the
appropriateness of the Inclusion of the two secondary treatment alternatives
that would Involve locating a large treatment plant on Long Island. Both of
these alternatives have severe Impacts, as described In the SDEIS. In several
areas. These severe Impacts Include:
1) The taking and relocating of the Chronic Disease Hospital;
2\ Irretrievable damage to the oldest (pre-hlstorlc) sites yet discovered
within the city of Boston;
3) Permanent damage to the visual quality from the Boston Harbor due to
Long Island's central location In the Harbor;
4) Many potential obstacles to Implementablltty;
5) Conflict with the Division of Environmental Management's stated plans
for an expanded park system; and
6) Potential damage to environmentally sensitive areas.
None of the five other alternatives offered In the SDEIS present Impacts of
equal magnitude. It would therefore seem logical to eliminate these secondary
treatment options from consideration. It seems that the only reason they are
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Included In the SDEIS Is due to pressure being exerted by the Town of
Ulnthrop. whose Instinct for self-protection should not be reison enough to
•arrant consideration of two alternatives wtth so many, potentially severe
Impacts.
In terns of presentation of the results, this SOEIS remains highly
Inadequate. Due to the onlsslons and vagueness mentioned above, It becomes
literally Impossible for the reader to objectively evaluate leach alternative
In any comparative and conclusive manner. Subjective conclusions based on a
1
partial attempt at quantification are the only kind of conclusions possible
under the circumstances, revealing • significantly flawed draft EIS.
• In addition there were problems with the six decision criteria utilized 1n
the document. The decision criteria listed In Section 2.6 of the SDEIS
provide areas In which the Impacts of siting a wastewater treatment plant will
be addressed. However, as no rating system has been devised for these
criteria, pending public comment, an analytical approach to applying these
criteria Is difficult. The criteria also have no weighting factors Included.
again pending public content, and thus direct comparison of the alternatives
Is not possible. The Inability to make such comparisons Is the single largest
flaw In the decision criteria. The use of public comment to determine the
final rating and weighting system Is seemingly a good Idea, but It forces the
reader to develop their own system for comparison.
The harbor enhancement decision criterion has been broken Into three
sub-categories:
1. Promotion of the economic development of the Inner harbor;
2. Improvement of the recreational facilities of the outer harbor; and
3. The development of Harbor Islands State Park.
There Is no ranking system for the three sub-categories; each of which could
have different Impacts on different sites. The first sub-category Is not
discussed for any of the alternatives, thus a comparison of economic effects
(other than construction costs and maintenance) cannot be made. The economic
development criteria also does not address how the development 1s supposed to
occur; Is the development due to Increased tourism and recreation, or Is It
due to a growth In the fishing Industry. The second category Is also not
addressed, except In Volume 2 with discussions on noise and odor. There are
no predetermined plans for Increasing or Improving the recreation facilities
anywhere In the Harbor, and certainly none for Deer. Long, or Nut Islands.
The State Park section Is stated to be the most clearly Impacted, yet there Is
not a concise analysis of the effects on any of-the Islands due to a
particular facility siting. There Is not an analysis of the no-action
alternative with respect to these sub-categories; this would -be helpful In
determining the true Impacts.
The effects on the neighborhoods adjacent to any proposed facilities are
fairly well documented In respect to noise, odor, and loss of property value.
However, the effects of odor are not quantified In any manner. A review of
the wind patterns associated with the area could give more Information on the
relative Impacts of odor.
Implementablllty criteria are well addressed with respect to permltlng;
the other aspects of Implementablllty are Incorporated In the other criteria.
especially cost. Reliability criteria Is not really addressed at all; a
worst-case scenario Is not Included for any of the alternatives.
The area where most of the problems with thr decision criteria lies with
the Impacts on cultural and natural resources. There Is a limited attempt to
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quantify the the difference In the Harbor both before and after siting with
regard to fishing and recreation; as there are established Mater-quality
criteria based on chemical and biological testing these should be Included to
discuss the relative Impacts on natural resources by each alternative. , There
Is no mention of the effects of the dumping of the prlaary effluent Into the
Bay or of the secondary treatment plant effluent Into.the Harbor. Again, this
could be esttnated by using chemical tests and by tracking current flows. —
Other Issues not fully discussed In the SDEIS Include the effects on the
archeologlcal and wetland sttes on Long Island, new measures to reduce air
quality problem at Deer Island, and the build-up of Nut Island.
Finally, the cost analysis criteria were only addressed In a superficial
way: 'The cost Issues are straightforward and have two aspects: 1) The cost to
build, and 2) The cost to maintain and operate.* (p.2-30). This cost analysis
Is therefore by definition quite limited, and does not Include Individual
evaluations of the cost of barging materials and busing construction workers.
nor does It Include estimates of the cost of appropriating land not presently
owned by the HOC. The costs of sludge disposal are also not addressed, nor
are the costs of Bltlgatlng measures detailed for any of the alternatives.
All these costs represent a significant amount that should have been estimated
and added to the cost figures for each alternative, thus presenting a more
realistic total for each, as veil as allowing a more meaningful basis for
comparison.
There were additional factors not Included In the decision criteria which
we feel should be Incorporated Into the final screening process. They
Include:
1. Tlmespan to bu\j)d the facility
2. Future needs and requirements for wastewater treatment
3. Sludge disposal options
4. Worst-case analysis
These factors provide additional Information to aid the public In choosing the
safest, most efficient and well-Integrated facility.
The SDEIS claims that the present Deer and Nut Island facilities are
contributing significant pollutant loads to Boston Harbor. It would therefore
seen logical that the time required to build a particular facility should be
considered 1n the decision criteria. Although the three primary treatment
alternatives will all take approximately six years to complete, the secondary
alternatives range froo seven years (all Deer Island) to nine years (all Long
Island) for completion of construction. It Is Important to consider the
additional pollution load on the Harbor as well as the further economic losses
(1.e sellflshlng and recreation) created by an extra two years of
construction. These economic and environmental costs should be considered In
the evaluation. For example. If the all Deer Island alternative costs $595
million and only seven years to build and the all Long Island alternative
costs $705 million and nine years to build the actual savings by building the
Deer Island facility would be $110 million plus whatever revenue Is created by
the fishing Industries and recreational facilities for too years. This
savings also does not reflect the decreased level of pollution In the harbor.
The project costs should not be estimated simply In terms of the costs of
manpower and materials.
The future needs and capacity requirements for the wastewater treatment
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was overlooked In the SOEIS. The site «nd facility chosen should be large
enough to treat any Increased volume of waste which nay be created In the near
future. In addition the site chosen for the facility should have a sufficient
buffer of land around It such that If additional equipment or treatment
facilities were needed (I.e. stricter pollution laws or a need to Increase
capacity) the facility could be modified. For example. If the Nut Island
treatment facility was decreased froo twelve acres to two acres and the land
around It were developed, then It would be more difficult to eipand the Nut
Island facility back to twelve acres at a later date. A "tunnel-vision*
'approach cannot be used In a project of such magnitude and cost.
Furthermore, we feel that the SOEIS statements about sludge disposal
options not affecting the selection of a site for a wastewater treatment
facility are untrue. They state that 'None of the sludge disposal actions
would alter the respective plant siting alternative's relative Impacts and
none of the treatment plant options would foreclose a sludge management
solution* (p 12.9-1 Vol. 2). However, there are alternatives that would
require the sludge tobe barged or shipped to another location for treatment.
For example, the statement Is Bade that Nut Island 1s too snail to accomadate
a land intensive method of sludge treatment such as composting. Even though
the sludge could be treated elsewhere (thus not foreclosing a sludge
management solution) there would be additional costs and Impacts inherent in
transporting the sludge. This problem may be avoided by selecting a different
alternative. It would be Ignorant to think that there is no advantage to
treating the sludge on-site. The selection of sites for the facility should
Include the potential for sludge treatment options in the decision criteria.
If one alternative can Incorporate both sludge and wastewater treatment then
it should be considered a preferred site.
Finally, during the analysis of the potential Impacts of a project It is
customary and crucial to Include a discussion of a worst-case scenario. Each
of the alternatives presented stated Impacts based on --he assumption that the
facilities would operate without any problems whatsoever. Yet If the
equipment were to breakdown, an overflow to occur, or the pipes to burst then
the impact!, created nay be site specific. For example, the environmentally
sensitive areas on Long Island could be drastically effected. Evacuation of
both the Chronic Disease Hospital on Long Island and the Deer Island House of
Correction on Deer Island would be extremely difficult. The worst-case
evaluation should compare the problems associated with evacuation,
contamination of environmentally sensitive areas, proximity to residential
areas, harbor pollution effects, ground water contamination, odor Impacts,
etc. In addition, mitigation measures should be stated 1n the SDEIS. Without
such discussions the analysis of Impacts Is Incomplete.
We feel that the comments stated aboVe represent and encompass a range of
problems with the SDEIS of the siting of a wastewater treatment facility In
Boston Harbor. Without additional Information and clarification we find It
difficult to make an intelligent decision on which site and alternative is
best for Boston.
Civic Education Foundation
Lincoln Filene Center
Medford. MA 02155
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RECEIVED-EPA
MAS 1 3 tS35
Kerch 7. 1985
Coalition
On
Alternative
Sewage
Treatment
Klchael Deland
Beglcnal Administrator
US EfA Region I
JrK Building
Boston. Ha 02203
Dear Mr. Deland,
K) In regard to the 3DEI3 prepared by CE hagulre, Inc. on the siting
I of uasteuuter treatment facilities In boston harbor, we would like to
OJ express our concerns over the proposal put forth for sludge disposal.
to Our particular concern Is over the proposed use of the Karblehead r'oul
OJ Area as a receptacle for not only the sewage sludee but also for con-
struction debris and dredged material from Boston harbor.
A report completed In Hay 1982 on the feasibility of ocean disposal
of sewage sludge from South Essex Sewerage District, also prepared by
SE Hagulre, Inc., examined various ocean disposal possibilities and gave
some consideration to toxics contamination, recreational use, cor.n.ercial
fishing, and economic factors. The recommendation of this study was
(p. VIII-18) • disposal at the 1<» Mile Site (Karblehead r'oul *rea) Is
slightly more cost effectlvei however, disposal at the 25 Kile site Is
better from an environmental perspective, environmental problems asso-
ciated with the I1* Mile Site Include i an estimated sludge deposition
rate equal to or areater than the natural sedimentation ratei the general
location of the l5 Kile Site In Massachusetts Bayi and the problens of
monitoring a site where sludge and dredged spoils are both dunped. These
environmental objections are considered sufficient to ellnlnate ocean
disposal at '.he 1"* Kile Site In favor of the 25 Hlle alte. despite the
slight cost advantage of the 1U Hlle Site." Yet this sane engineering
firm now offers the use of the 14 .11 le site for the disposal of an even
greater volume of sewerage sludge, dredged material, and construction
debris with even more toxic contanlnants. »e find It difficult to believe
that environmental considerations have diminished so fraatly In less than
three years In order to allow oceun dumping of this nature. «e feel that
ocean dumping at the itarblehead foul Area Is not an acceptable solution,
even If £FA has Identified It as the closest approved site, and we cer-
tainly do not endorse the 2J Hlle Site, doth areas are too close to
Important commercial fisheries locations.
Coalition
On
Alternative
Sewage
Treatment
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rurther, we feel tnat It Is a serious error to proceed with
facility siting until the sludge disposal Issue has been carefully
resolved, since the ultimate solution may well Impact the final
siting decision. Our experience at the South Essex Sewerage Treat-
ment Facility clearly Indicates that sludge disposal is a major
problem. More research and effort by EfA and Kass DEQE are required
In order to Identify the best and safest solution for sludge disposal
before decisions are made on the use of ocean dumping.
Sincerely yours,
' "*?•: -I? .;-J. ' f'
I
Jan P. Smith
9 Hitting Uux>. UtrtH«>ud. MA 01945
9 Hudlng Uiw. MufiUMxI. MA 0194J
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CLUfe • Neco ensLand CbapteR
1 JOY STREET. DOOM la. SOSTOM, MASSACHUSETTS. 0210S • «1T-M7-6«»
COMMENTS OH SITING OF HASTEHATEB TREATMENT
PLANT IN BOSTON HARBOB
(submitted to U.S. Environmental Protection Agency,
March 18. 198S)
The Greater Boston Group of the Sierra Club has for many years
focussed on Boston Harbor as one of Its priorities. Our efforts
have Included support for the -development of recreational
opportunities on the Harbor Islands, as well as workable mechanists
to ensure cleanup of the Harbor. In addition, we have been and
remain concerned about the Impacts of regional wastewater facilities
on the communities hosting or neighboring such plants. The Club
K> wishes to express at the outset of these comments its grave concern
I about the severity of harbor pollution and Its support for immediate
U) and dramatic action to reduce pollution of the harbor and achieve
K> compliance with state and Federal laws.
The following comments address the Club's concern about flaws
In the SDEIS/B process as well as specific substantive conclusions
of the study. In addition, we wish to recommend specific mitigation
measures to protect the health and safety of affected communities
which should be Implemented no matter which site Is selected. After
each discussion of a major area of Sierra Club concerns, we have
listed specific questions which should be addressed In the Final
EIS/B.
1. Mitigation of Community Impact Must be Guaranteed at Any Site
Selected and Deserves More In-Depth Treatment in the EIS.
Since all 7 site options will entail serious Impacts on one or
more communities, mitigation of those Impacts must be an Integral
part of the planning and budgeting for any option selected.
Mitigation measures. Including those listed below, must be as
Integral to the Harbor cleanup as new pipes and sedimentation
tanks. This Issue needs much Bore complete treatment In the Final
EIS/R.
In particular, the following Issues have not been adequately
addressed and should be Included to the maximum extent practicable:
(1) The odors from the present plants on Deer Island and Nut
Island are a constant problem Cor the residents of Point Shirley and
Houghs Neck. Hhat are the short and long term effects oC these
odors on the health of nearby residents? Uhat specific measures
would be required to lessen or remove completely this problem In a
plant or plants of larger size?
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(2) Barging of equipment, materials and personnel to the chosen
site has not been addressed properly In the SDEIS/B. Mould this
possible mitigation measure have Its own set of environmental and
community Impacts? Mould these vary by site?
(3) To the extent that barging Is Impracticable for getting
personnel to the chosen site.-bussing them would seem preferable to
allowing hundreds of workers In Individual cars to drive to the
site. How could such a system be Implemented?
(4) For transportation needs not addressed by barging or
bussing, a significant planning effort will be required to minimize
the use of residential streets and particularly to avoid use during
periods of congestion. Realising that many of the affected streets
are too narrow to allow two large trucks to pass each other, what
safety precautions have been studied to prevent accidents?
(S) Presently. 3 to 7 tanker trucks, each containing 30.000
pounds of liquid chlorine, pass through the narrow streets of both
Qulncy and Hlnthrop each week. What studies have been conducted on
the effects of an accident Involving these tanker trucks? Have
evacuation plans been developed to remove the tens of thousands of
affected residents In the event of such an accident? Mould It be
feasible to barge the needed chlorine to the chosen site Instead of
trucking It? Once the chlorine Is actually at the new plant, what
effects would a leak have on the residents of Hlnthrop, East Boston.
South Boston. Dorchester. Oulncy. and Hull? Are there safer forms
of chlorine or some other kind of disinfectant altogether which
might be substituted for the current practice?
(6) No provision has been made for the disposal of sludge
generated by a new plant. If the sludge Is to be trucked away from
the chosen site, what would be the traffic and health Impacts upon
the community through which It would be moved? If incineration Is
Implemented, what technology would be used to control air emissions?
Hhat will be the effects of the resulting air pollutants on the
nearby communities? How will the ash from Incineration be disposed
of, and where?
(7) Hhat guarantees can be provided that there will not need to
be any further expansion of the treatment facility due to new
additions to the MDC system? Could surcharges on large new hookups
to the system be used to fund some sort of rate reduction for the
affected communlty(les)?
2. The EIS Lacks a Comprehensive and Integrated Analysis ot Measures
Necessary to Achieve A Harbor Cleanup.
The DEIS/B focussed almost exclusively on the siting of
treatment facilities, without considering the effect on actual
treatment needs of such other Important elements of a complete
Harbor Cleanup agenda as:
o reduction of combined sewer overflows (CSOs)
o reduction of infiltration and Inflow (I/I)
o an effective Industrial pretreatment program
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In addition, failure to consider as part of this analysis the
Implications of each of the 7 site options for the ultimate choice
of sludge disposal method omits a crucial factor ttom the siting
Issue. Given the volume of sludge which will be generated, this
omission seriously underlines the validity of the study. The study
also falls to adequately Integrate Into the analysis the Impact that
the 301(h) waiver decision will have on the site selection and site
Impacts. A complete EIS should provide a reasonable evaluation of
the economic, environmental, health and other Impacts of the CSO.
I/I, pretreatment. sludge disposal, and treatment alternatives, as
well as specific site-related Issues, since these are all
Interdependent In producing the ultimate benefits, costs, and
secondary Impacts of the Boston Harbor cleanup. While It may be
difficult at this point In the process to add so much new analysis
to the Final EIS/B. failure to at least address the major types of
Impacts will leave the document hopelessly flawed as a basis for
sound declslonmaklng.
These Questions Should Be Answered In the Final EIS/B:
(1) What effect will the Implementation of the many CSO
projects currently planned within the HOC system have on both the
amount of and characteristics of Influent to any new treatment
plant? To what extent would such changes affect the needed scale of
treatment plant?
(2) What effect would a substantial program to reduce I/I In
the HOC system have on both the amount of and characteristics of
Influent to any new treatment plant? To what extent would these
changes affect the needed scale of the plant?
(3) What effect would a properly staffed monitoring and
enforcement program for Industrial pretreatment have on the
characteristics of Influent to any new treatment plant? To what
extent would such results modify the 0 & H needs for the plant?
(4) For each of the seven site options, what are the
Implications for the quantity and characteristics of sludge which
would be generated? What constraints would each site Impose on the
eventual choice of technology for sludge manageoent and disposal?
What additional costs might be required unique to any particular
site?
These Questions Should Be Answered In the Final EIS/8:
(1) Would a system Involving one or more satellite treatment
plants make It possible to segregate partially or completely flows
containing only household wastes from those containing Industrial
wastes as well? What would be the benefits In terms of easier.
safer, and cheaper sludge management?
(2) Assuming complete treatment and local discharge of effluent
at one or more satellite treatment plants, by how much could such a
system reduce the total flow to a plant located on Boston Harbor?
What would be the Impacts of local discharge of effluents from such
satellite treatment plants?
(3) What would be the effect of some such degree of
decentralization of the MDC system on (a) total capital costs, and
(b) annualIzed cost Including all necessary OSM costs, of the system?
Conclusion
The Sierra Club Is anxious to see the questions raised above
answered as fully as Is practicable with the framework of the Final
EIS/B, and If a very short delay (one or two months) In the Issuance
of that docuaent will oak a It possible to produce significantly
better analysis In support of the answers, then the Sierra Club
would see that as worthwhile for the longterm credibility of the
process. We would, however, like to reiterate our desire to see the
cleanup of Boston Harbor proceed as rapidly as possible. Further
analysis should not become another excuse for delay In addressing
the problem.
3. The E1S/R and the Process Leading to It Have Inadequately
Addressed the Satellite Treatment Option
Satellite treatment plants could offer benefits over the
current centralized system. The process leading to this DEIS/B has
assumed that the plants would be centralized In the harbor. The
large plant size resulting from centralization leads to larger
environmental impacts (severe access problems and Intense community
Impacts during both the construction and operating phase)and will
make quick mitigation of these problems more difficult. The Sierra
Club urges further review of the satellite option.
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Friends of the Boston Harbor Islands
15 Sellers Street
Cambridge, MA 02139
868-6362
March Ik. 1985
Mr. Michael Oeland
Regional Administrator
United States Environmental Protection Agency
JFK Building
Boaton. Mass. 02203
Mr. James Hoyte
Secretary
Executive Office of Environmental Affairs
100 Cambridge Street
Boston. Mass. 02202
Dear Slrai
NJ The Friends of the Boston Harbor Islands Is a non-profit organization
I that was founded to promote the conservation and preservation of
l*> the natural and historic resources of the Boston Harbor Islands.
N) Our 350 members from all areas of Eastern Massachusetts are concerned
CT> about the siting of the new sewerage treatment plant on one of
the islands, specifically Long Island.- Becauaeof its rich natural
and historic resources, Its central location in the harbor and
its potential for year-round access, Long Island could become the
focal point of the Boston Harbor Island State fark.
For these reasons, the Friends feel that the Interest of the
citizens of th" Commonwealth would best be served by encouraging
each community to handle its own wastes in satellte plants Instead
of burdening any one or two Islands with the waste from the whole
district. In addition, the Friends would like Long Island to be
preserved as open space for recreation rather than be used for
any kind of industrial or resldental development.
Very truly yours,
Diane Qreaney
Member, Board of Directors
''•«*
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CLF
Conservation Law Foundation of New England, Inc.
CLF
02U8-U97
1617) 742 2540
Conservation Law Foundation of New England, Inc.
March 18, 1985
N)
CJ
to
Michael R. Deland
Regional Administrator
U.S. Environmental Protection Agency fa,,
Region 1 •'.:'': .
J.F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Deland:
Enclosed is a copy of our comments on the Supplemental
Draft Environmental Impact Statement.
PSisc
Hon. James S. Hoyte
Massachusetts Hater
Resources Authority
Metropolitan District
Commission
Bosun. Masucftusoltt
02I08-U97
(617) 742.2S40
The Conservation Law Foundation of New England, Inc.
(•CLF*) submits the following comments on the Supplemental Draft
Environmental Impact Statement/Report on Siting of Hastewater
Treatment Facilities for Boston Harbor ("Siting SDEIS*).
I. Preferred Alternatives Analysis
A. General Comments
The Siting SDEIS does not actually Identify a preferred
alternative, which makes review of the document for compliance
with the national Environmental Policy Act CNEPA-) difflculti
there Is no federal decision to fund a .specific state facilities
choice under review. Indeed, It Is surprising to hear tne siting
decision being constantly referenced as BPA's decisioni the
decision Is the state's as the discharger.
Another limitation on an effective review of this
document is the lack of detail which has been developed for any
one of the alternative projects. This deficiency Is observable
in the conclusory discussion of the application of the criteria
to the alternatives, but more specifically It is observable in
the inadequate evaluation of the treatment processes and
facilities themselves. There is really no single configuration
of processes or technology which can achieve secondary levels ot
treatment. Some have treatment efficiency advantages; others may
have advantages relative to their visual aspects. Bowever,
because this level of detail was not Included in the analysis,
the conflicts of a facilities siting on Long Island, even If Long
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Island's potential ae the keystone of the harbor island park
system Is reallied, were greatly exaggerated and skewed the
reader toward Deer Island. This comment should not be
nlsunderstood as an endorsement of the Long Island optioni we are
simply pointing out that sufficient data was not presented to
allow a thorough analysis of the potential Long Island secondary
option Impacts and available mitigation measures.
The third general comment on the document, or more
precisely, on the project itself has to do with the severity of
the potentially unavoidable environmental impacts wtilch are
directly related to the gargantuan sise of the present system.
Gravity and 'cheap* annual bills have led this system to grow
without restraint, relying on the never realized promise of
future flow reductions. The HOC system is simply too big to be
properly managedi too many hundreds of miles of pipe bring too
many millions of gallons of sewage to Boston Barbor. EPA must
take this opportunity to insist that the state immediately
initiate a program to stop new flows to the system in the absence
of documented and enforceable flow reductions through I/I
projects, satellite treatment, or otherwise.
B. CLP's Preferred Alternatives
CLP concludes on the basis of the Information presented
In the Siting SDEIS that Options la.2 and 2b.l — the all Deer
Island secondary option and the all Long Island secondary option,
respectively — are on balance the least bad of the evaluated
options and therefore the alternatives of choice. The principal
factors that lead us to choose the Deer Island option are the
desire to avoid the risk of ruining yet a third island with
treatment facilities and the belief that if the Deer Island Bouse
of Correction is removed, the Deer Island option can be done in a
way which would produce net environmental Improvements for the
residents of Nlnthrop. The principal factors that lead us to
endorse the Long Island option are the desire to avoid advocating
an option that places disproportionate impacts on a single harbor
community and a belief that so long as the hospital is moved.
Long Island's topography and, the use of stringent design criteria
can allow facilities on that island which are fully consistent
with utilization of the Island as the keystone of the harbor park
system.
There are no clear siting winners in the state's siting
decision from an environmental perspective; there are only
relatively clear losers. Although the case has not been made
persuasively that so-called 'satellite* plants have no present
utility in the immediate solution of the horrendous Boston Barbor
wastewater treatment problem, the marginal benefits that such
facilities would provide in the short-term. If any, are
overpowered by the llmmedlate need to make a decision on siting so
that adequate facilities can be ezpeditiously constructed and
begin operation. Therefore, CLP feels that it must advocate
harbor siting options which may be far below the optimum
resolution of the region's wastewater treatment needs, realizing
fully the cost of such options to the already burdened harbor and
adjacent communities.
At the same time. It is clear that the burdens of a
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massive harbor facility can and, as an equitable matter, must be
mitigated virtually without regard to cost considerations.
Indeed, if the state ultimately decides on the Deer Island
option, the residents ol Nlnthrop are entitled at a minimum to
compensation In the foro of waived treatment fees and the long
overdue relocation of the Deer Island Bouse of Correction.
Turning to the substance of the Siting SDEIS, the
following considerations played important roles in CLP's process
of selecting preferred alternatives. He first rejected all
options which were premised on the viability of primary
treatment. As CLP has pointed out in its comments in the 301(h)
proceeding, the MDC's demonstration of Its compliance with tne
301(h) criteria was so deficient as to preclude approval.
Looking only at the secondary options presented, we
rejected Option lb.2 — split secondary between Nut and Deer
Islands — on the following groundsi there was no compelling
direct cost reason for preferring it; there were unacceptable
environmental costs associated with the filling Impacts at Nut
Island and the water quality impacts of spills and upsets in the
relatively enclosed circulation system surrounding Nut Island;
and there seemed to be no principled reason for multiplying the
community impacts caused by the treatment system by using two
Islands so closely situated to residential communities. While
such a split system appears historically to be the MDC's favored
option (at least at primary levels), no persuasive reasons for
continuing with this split were set forth in the Siting SDEIS,
other than the relative time advantage in which it could be
implemented over Options 2b.l and 2b.3. We felt that tne slight
superiority In that category did not overcome the significant
disadvantages in other categories.
Elimination of Option 2b.3 -- the split secondary
facilities at Deer Island and Long Island — was not as straight-
forward as the split Nut Island/Deer Island option.1 It would be
significantly more expensive in both capital and O * M costs tnan
the other two options. The combined staffing costs were the
highest, suggesting that it was probably the least etficlent of
the final three from a management standpoint. Finally, It seemed
to offer no significant environmental benefits, except perhaps
better reliability in the event of a total plant shutdown at
either Deer or Long Island under the other options. Our
principal reason for rejecting it was that we felt that the
amount of money available for mitigation measures was finite and
that this option — with principal treatment facilities on two
islands instead of just one island as is the case with the
remaining two options — would not result in a cost-effective or
environmentally sound division of the finite capital available
for mitigation and would not promote the maximum mitigation
effort which would be reasonably likely to result if only one
Island were designated for supporting the treatment facilities.
Consequently, we eliminated this option.
This left two optionsi la.2 (all Deer Island) and 2b.l
Indeed, a fairly strong case can be made that it is
sufficiently close to Options la.2 and 2b.l that It snould be
kept In the running and the state should be allowed to select any
of the three with appropriate conditions and use of mitigation
measures.
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(all Long Island). As noted above, it IB our belief that either
option could be (elected and, through the use of appropriate
conditions and Implementation of alligation measures, be roughly
equivalent In terns of net environmental Impacts. Stated
differently, we believe that the choice between Option la.2 and
2b.l is essentially political, not environmental. That choice is
the state's to make, not CLP's.
II. Siting SDEIS Deficiencies
There are some significant deficiencies in the Siting
SDEIS which should be cured or clarified in the final document.
These Involve the treatment of water quality impacts of the
project and the analysis of available mitigation measures.
A. Deficiencies of Water Quality Analysis
The Siting SDEIS takes the position that apart from
construction Impacts, analysis of the siting decision is
Independent of any water quality issues. The document argues
that the latter Issues will be resolved either in the Record of
Decision of the 301(h) Waiver, which will then be incorporated
into the final siting impact statement, or in future engineering
design of the facilities. Among the issues thus reserved or
relegated elsewhere are the location and design of the outfall
pipe under the secondary treatment approaches, the reliability of
the various treatment configurationa from both an engineering and
an administrative perspective, and the water quality Impacts of
various types of secondary treatment technologies.
With particular regard to outfall location and design, It
i
seems remarkable that there is no detailed analysis of various
outfall location and design options in the Siting SDEIS,
particularly since the Siting SDEIS states that water quality
criteria may be violated from time to time even at secondary
treatment levels.
Location and design of the outfall has a direct bearing
on the likelihood of such potential adverse impacts. By way of
defense, the Siting SDEIS appears to suggest that since all the
secondary treatment options will use the same outfall, analysis
of the outfall site or design can be Ignored. See Siting SDEIS,
vol. 1, 4-1. This position, however, misrepresents the purpose
of the BIS, which should Include an evaluation of all the impacts
of the ultimate federal action at issue, which in this case is
the EPA funding of the terminal facilities of which the outfall
pipe is an intrinsic feature. Moreover, is not appropriate for
EPA to ignore the issue in reliance on the DEQB'e future
•evaluation of such site and design alternatives0 during the
design phase. Siting SDEIS, Vol. 2, 11.3-4. Finally, since this
analysis has apparently been done (see Siting SDEIS, Vol. 1, 4-1
to 4-2), it could have been Integrated into the Siting SDEIS with
little loss in time.
Second, we are startled to read In the document that
water quality violations for toxic metals and pesticides may be
an 'unavoidable* adverse Impact of the federal action even at
secondary treatment levels. Siting SDEIS, Vol. 1, 4-104.
Available technology utilized at the treatment plant as well as
pretreatment and toxics control upstream, and appropriate outfall
design and location can eliminate such violations. All
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pollutants can, and must be controlled to neet water quality
criteria. See §301 (b) of the Clean Hater Act. EPA must insist
that such control be exercised by the discharger. If the system
is too big and unwieldy to allow such controls to be implemented,
the system oust be broken up into smaller management and
discharge units. .In any event, it nust be unacceptable to EPA
and EOEA to finish 'this agonising process with a system still in
violation of federal law.
The third water quality issue that should be addressed or
clarified has to do with the reliability questions posed by the
alternatives. The final Siting SDEIS should evaluate the
reliability of various secondary treatment engineering techniques
in yielding acceptable effluent quality, and the question of
whether the selection of any particular siting alternative will
place limitations on use of those techniques, because of lack of
space or the like. The discussion at vol. 1, $4.3.5, of the
Siting SDEIS is simply inadequate in this regard.
The Siting SDEIS should also analyze the reliability of
each alternative from the standpoint of the reliability of its
upstream transmission components, such as bypasses, pump
stations, overflows and the like, and the consequences for water
quality. Finally, the reliability analysis should consider
management questions such as the level and quality of personnel
that must be recruited and maintained and the advantages or
disadvantages of multiple facilities with respect to personnel
management. In short, CLP agrees with the Siting SDEIS that
•Reliability* is an Important criteria in the siting decision but
finds it all but impossible to use or weigh the limited and
conclusory reliability material in the Siting SDEIS as a guide
for choosing between options.
B. Analysis of Mitigation Heasures
1. Ose of Grant Conditions
EPA and EOEA are to be commended for treating some
mitigation measures as so central to the acceptability of the
action that they are to be conditions of the grant. See Siting
SDEIS, vol 1., 2-10 to 2-12. This set of conditions, however,
should be expanded.
The first additional condition should focus on wastewater
flow control and growth regulation. Such a condition is
essential to protect the facilities. The present design flow is
predicated on successful completion and ongoing administration of
a massive I/I program by DEQE. If the program is not completed
or is not successful in bringing system flows down to the design
capacity of the system, there will have been little gain over
present circumstances. EPA should Impose a condition on the
grant that sets a deadline for putting effective flow monitoring
devices in the system so that claimed I/I reductions can be
corroborated and^ a deadline for reducing extraneous flows down to
design capacity. The failure to satisfy this condition should
trigger an automatic limitation on new flows from system
municipalities until resolution of the capacity problem is
achieved.
The second additional condition that should be imposed in
the event that Option la.2 is selected is the relocation of tne
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Deer Island House of Correction. There are a number of
justifications for imposing this condition. First, the present
facility is in such a state of disrepair that the 'moat cost-
effective solution to upgrading the prison would be to build a
completely new facility.* Siting SDEIS, vol. 1, 3-35. There is
no compelling reason to rebuild it on Deer Island. Second, the
prison is in no way an appropriate water- or harbor- related use
of Deer Island and probably should not have been located there at
all. Third, removal of the prison would allow facility design on
beer Island to ainimize physical destruction of portions of the
Island and maximize opportunities to 'blend* the treatment
facilities into the topography. Finally, relocation of the
prison would more equitably distribute the burdens currently
borne by tfinthrop and allow the reopening of Shirley Gut, if
desired.
It is not possible for CLP to catalogue all the
mitigation measures that could be recommended for the two
preferred alternatives. Indeed, except for the additional
mandatory conditions described above and the measures that would
naturally suggest themselves when some of the water quality
analysis deficiencies noted above are completed, the Siting SDEIS
contains discussion of a fairly broad spectrum of mitigation
measures In Volume 1, $4.3. CLF would particularly emphasize the
points made in section 4.3.1 (land use considerations),
partlculary the Introduction and subsection a> section 4.3.2
(traffic); section 4.3.S (engineering considerations); section
4.3.6 (compensation for affected communities) and section 4.3.7
(visual quality).
The aore fundamental issue on the subject of mitigation
•easures has to do with insuring Implementation of the
recommended measures. What, for example, is EPA's authority to
require the implementation of these measures, particularly tnose
which are not made specific conditions to the grant or those
which are not related directly to water quality and thus not
federally fundable? There should be discussion of this issue in
the final Siting SDEIS.
III. Conclusion
EPA and EOEA are to be commended for sticking relatively
closely to the schedule for release of the Siting SDEIS. He
appreciate the opportunity to submit these comments.
Conservation Law Foundation
of Hew England, Inc.
3 Joy Street
Boston, Massachusetts 02108
(617) 742-2540
Contact: Peter Shelley
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COMMENTS OK THE SUPPLEMENTAL DRAFT ENVIRONMENTAL
.IMPACT STATEMENT FOR A WASTEWAT2R TREATMENT PLANT
IN BOSTON HARBOR
Submitted by:
Richard Gelst
35 Teele Avenue
CO Somerville. MA 02144
U> Madeline Kasa
"^ 43 Electric Avenue
Somerville, MA 02144
Diane Newton
12 Pearl Street, I3R
Medford. MA 02155
John Pepl
30 Swan Place
Arlington. MA 02174
March 13, 1985
The prepared SDEIS for wastewater treatment plant
alting in the Boston Harbor identifies impacts of siting
alternatives at great length. Does this quantity, however,
reflect and address the main issues required by the NEPA
process for ElS'e, and does it do so in a manner that is
beneficial for decision making?
NEPA requires the following types of impacts to be
identified in all EIS documents: quantifiable and
unquantiflable, long term, short term, Irreversible and
irretrievable resource commitments, and major versus
minor impacts.
The short term impacts are well identified as those
impacts involved in construction at alternative sites and
the legal and institutional obstacles to implementation.
Moat of the discussion has been based on the early impacts
on people in the areas of each alternative. The Impacts
listed include those that would affect what people may
have to see, hear and smell as well as pay for in the case
of each alternative.
Long term impacts are similarly addressed as they
apply to the operational facility. The major, prioritized
impacts are well summarized and explained in Volume I.
However, it is important to note that this discussion
treats as most significant those things that people will
sense, rather than actual physical Impacts and what they
mean (for people or for wildlife). Por example, how much
noise and/or odors will actually be produced? What does
"moderate" noise or odors mean to area residents, prisoners
on Deer Island or patients at the Long Island hospital who
are chronically ill? Will people in any of these groups
be awoke at 6 a.m. by moderate noise? Will they be
constantly aware of ongoing construction? Will odors
make breathing unpleasant or eating unenjoyable? If
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poeeible, Impacts should be stated more clearly, and in
more understandable terms. Also, what are the long term
Impacts? There la mention of a future expansion possi-
bility, but what would be the Impacts of a malfunctioning,
worn-down plant? What are the impacts of an abandoned
plant at any site?. Which alternative could best accommo-
date an expansion to secondary treatment in the future?
Overall the required areas of impacts are identified.
Nevertheless, other aspects of Impact identification
should also be considered. In fact, the authors of the
SDEIS also list, under "Unresolved Issues - Not Site
Applicable," other additional impacts. These impacts, if
truly not applicable, perhaps should not be included.
However, they are important, and worth considering before
a site choice is determined. At least three of the five
choices clearly could be considered for each alternative.
For instance, different alternatives have different
requirements for pipeline distances, whether a combined
or single-island alternative la used. What are the
differences? Which option may be better in the long run
for growth? Which option will be best suited for eventual
sludge disposal? One island may or may not be good for
a compost solution or more convenient for ocean disposal.
These Issues, as well as many not Mentioned or listed
at all, must be defined and added for a worthwhile deci-
sion to be made.
It is also rather difficult to compare the impacts
of one alternative with those of any other considered in
the SDEIS. The document presents the reader with several
different versions of the Impact parameters under examina-
tion. This is in contrast to the report in the appendix,
prepared by C.E. Hagulre, which summarizes the process of
narrowing down the choice of alternatives to the eight
options presented in the SDEIS. The Haguire report
clearly lists the Impacts (potential or actual) that they
considered, and uaea that list to compare the eighteen
alternatives that they originally considered.
In the SDEIS document, however, impacts are not so
Hated. On pages 2-24, the authors present six categories
of decision criteria against which alternatives are to be
evaluated. In the following section of the SDEIS, these
general categories are elaborated upon and additional
specific impact parameters discussed. Next, the agency's
intent to eventually perform the rating and weighting
judgments is explained and public input on this rating-
weighting process is solicited.
The "Alternatives11 chapter both lists the Impact
parameters against which it will analyze alternatives,
and then presents them in a matrix chart form. Tracing
the evolution of some of these categories from the first
(decision criteria) listing through the second and third
(matrix), we find them listed quite differently:
"Harbor enhancement" in the first listing can be
equated with "recreational resources'* in the second
listing, and with "recreation" in the third listing.
Similarly, "natural and cultural resources" becomes
"archaeologic/historlcal resources" and then "cultural
resources," and "reliability" is not translated into any
category in the second and third listings of impacts.
The reliability criterion provides a good Illustra-
tion of the consequences of Inconsistent Impact cate-
gories, definitions and terminology. Reliability appears
in Section 2.6.6 as a basic decision criterion; yet it is
never operationally defined as a type of impact, it is
absent from the analysis of alternatives, and then it
reappears under the "Mitigation Measures" chapter as an
engineering consideration to be evaluated during final
facility design.
Assuming that the chart-matrix array of Impacts
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against siting alternatives, which la presented at the
beginning at the primary treatment and secondary treatment
alternatives sections, is the preferred technique for
comparative evaluation of Impacts, then it would benefit
{he cause of public participation if the reader were
appraised of the agency's proposed method of analysis.
How will individual ratings of alternatives for each
impact category be summed or aggregated? Will a "slight"
rating for visual Impacts be awarded 5 points and a
"severe" rating 20 points? By what method. If any, will
a 10-polnt rating for visual Impacts be weighted against
a 10-polnt rating for legal-Institutional obstacles?
For which Impact values will there be an attempt.to
quantify effects and for which will there be no attempt?
Also, we could not find adequately addressed the issue
of the "no-action alternative." In the SDEIS, the sec-
tions on "Purpose and Need for Action" and on "Baseline
Conditions," detail the character and extent of deteriora-
tion of the harbor's various environmental parameters,
but do not constitute an Impact analysis for the no-action
alternative.
While it may be apparent to all readers who are
concerned with the various facets of the Boston Harbor
cleanup that the status of the full gamut of values at
stake in this process Is certain to progressively deterio-
rate without upgrading of the wastewater treatment
facilities, that common sense knowledge is not sufficient.
NEPA requires that a comparable impact analysis be
produced for the no-actlcn scenario as is produced for
the various alternative actions. Baseline data and
descriptions of current conditions of water quality,
odors, recretlonal uses, traffic flow, etc., do not
qualify as analysis of what will result from no action.
Without relevant calculations, modeling projections and
other analyses that attempt to project the environmental
consequences of no action thirty years hence (the span of.
time over which primary and secondary treatment alterna-
tives under consideration would conceivably exert an
impact), we are left with an inadequate basie on which to
evaluate the true costs and benefits of the various
•build" alternatives (i.e., willingness to take on a
relatively high cost but "conservative" alternative,
cost-weighed against a predicted long term devastating
Impact).
Basically, the purpose of the SDEIS is to completely
analyze impacts that could result from the construction
of a new (or expanded) wastewater. treatment plant in
the harbor. Three sites » Deer Island, Long Island, and
Nut Island -- are the remaining locations under considera-
tion after screening of the original twenty-two alternative
sites. The SDEIS would be Improved if the process of
narrowing down from twenty-two to eight final sites under
consideration were made more apparent, rather than being
pretty effectively burled in Volume II. It is necessary
that the general public, especially those people who live
or work near the proposed sites, are able to easily and
thoroughly understand the Impacts of such construction.
Because of this necessity, the findings and conclusions
of the SDEIS must be stated clearly, so that all interested
parties can provide their Input on the subject before the
final site decision Is made.
This standard la achieved quite well through the
Summary Introductory volume. This fifteen-page document
presents the overview in a relatively short, easily read
report. It is put together in a very organized fashion
in separate sections: the setting, the potential, the
problem, mitigation measures, the scope, and the various
primary and secondary treatment alternatives.
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Tables 1 and 2 In the summary volume show the impacts
of the alternative actions In what Is probably the clearest
way possible, although, as mentioned above, the impact
criteria are not consistent with those used throughout the
8DEIS. Tables 4-1 and 4-2 in Volume I of the SDEIS are
more detailed versions of the Impacts charts. Because
of the usefulness of these detailed charts to anyone trying
to compare Impacts from different alternatives, we suggest
that they be located in a more obvious place within the
SDEIS (e.g., at the beginning or the end of the document),
and that the list of potential impacts be standardized
throughout the document. The charts, even in their present
form, do add a considerable amount of clarity to the
SDEIS. If It were not for the charts, many interested
parties would not have been able to read the lengthy
report and to make reasonable conclusions from the impact
analyses given in them.
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SUPPLEMENTAL DRAFT
ENVIRONMENTAL
IMPACT STATEMENT/REPORT
on
SITING OF
HASTEHATER
TREATMENT FACILITIES
FOR
BOSTON HARBOR
CRITIQUE I
by
JOHN JEFFREY HEALEY
for
UEP-267
RECEIVED
OFFICE OF THE SECRETARY
OF EUViRONMt.'i' .".' r.uRS
TABLE OF COHTENTS
I. INTRODUCTION
II. PURPOSE I NEED FOR ACTION
III. DISCUSSION OF ALTERNATIVES
IV. AFFECTED COMMUNITY
V. ALTERNATIVES AND THEIR IMPACTS
VI. SUMMARY
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I. INTRODUCTION
II. PURPOSE AND KEEP FOR ACTION;
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The cleaning up of Boston Harbor li a complex cask. The diverge
neture of the harbor and ahorellnee, along with the wide variety of
actlvltiea that occur In the areaa aurroundlng and within the harbor,
demand that an Envlronaentel Impact Statement for the possible alting
of a waste water treatment plant be equally dlverae. laeuee muat be
eddreaaed which focua on commercial Impacta, recreational Impacts aa
well aa realdentlal Impacts. Eathetlc concern! auch aa nolae and odor*,
aa well aa visual effecta auat alao be conaldered. Moat importantly
one muat look at impact* on the environment iteelf and Public Health.
The purpoae of thli E.I.S. wee to determine the beat location for
the conatructlon of primary and aecondary (?) treatment facllltlea which
will enable Che beginning of clean-up of the harbor. Singe eech of
the euggeated alternatives will do equally well with regard'to developing
a higher water quelity within the harbor, the declalon aa to which
alternative will be picked will depend primarily on which alternative
poaea the leaat algnlflcant impact problem* during conatructlon and .
normal operation. Other factor* auch aa Implementability, reliability
and coat muat alto be considered.
I did not Intend to do thlt paper alone, but due to conflicts outside
my control, fete haa left me alone to do tbla assignment. The concept
of'environmental Impacts' 1* fairly new to me, as I have little academic
or professional work la this field. I must confeaa at this time that
I have not been certain of the best way to approach this assignment. I
began by trying to be the 'Devll*a Advocate1. I was trying to find an
ares thst was poorly done in the E.I.S., or to find a significant point
that should have been made but was not. Over and over again I was
certain that I had aubstantlal ground to base a good argument. Unfortunately,
each time I thought I had found a mistake In the E.I.S., I later found thru
further reading, that a point I thought they miased, they covered In a
aeparate section. I realized I was trying to outsmart the engineers who
do this kind of work for a living. It waa a humbling realization.
For these reasons, my paper will provide an unbiased approach,
providing both praise In areas I feel were covered well and criticism
were It la called for.
One cannot make proposala for aolvlng complex environmental laaues
without giving some attention to the historical circumstances that have
created the present situation. In order to Justify the construction
of new waste water treatment planta, NEPA requirea that significant
evidence be demonstrated that the conatructlon la both neccesary and
warranted. We are told in aection 1.0, that the present operating waste
treatment facllltlea at both Deer laland and Nut Island together discharge
75 tons of digested sludge solid dally. This accounts for roughly half
of the pollution problems existing in the Boston Harbor. We are also
told that aewarage overflowa from 100 locations in the surrounding
communities also contribute algnlflcant amounts of waste material and
sludge. The final aource contributing waste are the storm water runoffa,
(contributing i.7 billion gala, annually) and dry weather overflows. ( 8
billion gala, annually). To aa there Is no doubt that measures must be
taken to begin reversing the process of uncontrolled contamination of
the harbor and vicinity.
I feel the Integrated approach to takllng this problem Is reasonable.
The list of major projects listed in section 1.4.1. demonstrate the feet
that significant pollution problems need to be tackled from more than one
approach. A combination of the following;
Interim Rehabilitation of Deer laland and Nut Island Facilities
New Alternative Primary & Secondary Facilities, Pumping Stations
Sludge Management
Surface Runoff and Sewar Overflow Control
would be a great step In salvaging the Boaton Harbor.
I feel, with regard to a hiatorlcal perspective which should be Incor-
porated Into a statement of need, this E.I.S. leaves a lot of unanswered
questions;
1. Why has there been such poor operation and maintenance of the
presently existing fscilities for treating waste water on both Deer
Island and Nut Island, In the past?
2. Has operation and maintenance of the plants gone unchecked
due to poor MDC management or misappropriations of funds?
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IV. AFFECTED COMMUNITY
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3. Would proper operation and maintenance of these plants
have prevented much af the present situation from occurring?
4. Why has rsw wsste water bypassing gone unattended for so long?
I feel these Issues should be looked at to allow the Commonwealth'to
learn from its mistakes in the past. Aa a member of the public, my
reactions sre both; 'tea, let's get started with the ideas!
'Why have you let it get this far'?
III. DISCUSSION OF ALTERNATIVES;
The screening process has dropped the number of poaaible alternatives
from 22 to 7. NEPA requires thst all reasonable alternatives be examined.
In section 2.2.2.2 we are told that for ell 22 options, economic, envir-
onmental and soclsl Impacts were studied. Analysis wss slso done on the
technical, legal. Institutional and political ramifications of esch option.
I feel the screening from the original 22 to 7 was reaaonable. The resulting
7 alternatives are ell somewhat variations of each other, involving
either primary only, or primary with secondary treatment, being arranged
in different combinations on the islands. The effectiveness of esch
alternative are aald to be nearly equal with regard to development of
a higher water quality in the harbor. The fact that the 7 alternatives
are slmillar to each other, this allows for a more systematic approach
to be used in the assessment of thler individual Impacts.
According to NEFA Regulations, the 'No Action' alternative must be
included in the discussion of possible alternatives. This establishes s
baseline with which to compare the resulting impacts of the other new
alternatives. Along with the establishment of s baseline for comparing
Impacts, the inclusion of the 'no action' alternative also allows us to
compare the effectiveness of the new sltematives with regard to harbor
clean-up. I feel analytical predictions of water quality 5 to 10 years
iwn the road should be included for both the new alternatives and the
no action alternatives allowing us to see just how effective the new
alternatives will be.
Section 3 provides us with descriptions of the local communities
who live in close proximity to the sites of the proposed alternatives.
The locsl communities begin to come alive as we are given descriptions
of the communities. Such items as proximity to the ahore, distance to
the islands, size of populations in the areas and also the types of
recrestlonal activities sssoclated with the area, help to give us a feel
for the townfolk and also help us to understand better their feelings about
theae alternatlvea.
The 3 lalands assoclsted with alternatives are; Deer Island, Nut Island
and Long Island. Point Shirley and Cottage Bill are residential areas
near to Deer Island. Bough's Neck Is a residential area in close proximity
to Nut Island. Squantum is the residential srea sssoclsted with Long
Island. It is significant that each proposed-site for a treatment plant
la in close proximity to a residential area. It is slso significant
thst In order to reach each of the respective Islands, overland, you
euat travel thru the above mentioned localities. These facta well prove
significant when we begin a discussion of Impacts.
Ths aain impacts we will concern ourselves with, es fsr aa local
realdencles are concerned, will be noise and odor. Noise and odor have
been found to have significant health effects on the most sensitive members
s population, at high enough levels. Therefore, I feel a significant
component has been left out of this study of affected environments.
That is an'age distribution' component, which would tell us which of the
above mentioned localities haa the highest proportion of elderly residents.
This could be accomplished through the'use of census bureaus, surveys
as well as counts of nursing homes snd elderly housing projects existing
in the'areas. Elderly citizens are often unable to get around often by
themselves, meaning they will spend much time in thier homes as opposed
to younger people who are up and about town much of the day. This fact,
along with the fact that many elderly residents will not be in the best of
health, means they could possibly be the group most affected by chronic
loud noise or bad odors. For this reason, I feel it Is essential to
incorporate an 'age-distribution* component into the section on affected
environments.
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V. ALTERNATIVES AHD THIER IMPACTS;
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ID this •cctlon I will discuss Impacts which I feel need greater
conilderetlon than they were given in the E.I.S..
A. It bee been stated in lection 4.7 that during periods of construction
for the varioua options, traffic problems would be lessened, .if not alleviate
thru the uae of barges for the purpose of hauling construction materials.
In Incorporating the use of barges as a means of transporting construction
nateriele for these projects;
What is the guarateed availability of bargee for thia purpose?
Is there e possibility that the availability of barges could be sig-
nificantly reduced due to wear and tear or equipment breakdown?
SIGNIFICANCE;
If after construction has begun for a given alternative has begun, and foi
unforeeen reasons the availability of barges for the purpose of hauling con-
struction materiel la reduced, in order to keep the project going, justifies!)
may exist for increasing the uae of trucks to haul material well above thler
projected use level, with resulting disruptions of the local vicinity.
>• Boston Harbor hae tremendous esthetic value and its uses include both
commercial and recreational activities. Oil tankers and container ships
are often seen in the harbor aa well as public boats, commuter shuttle*
and recreational crafta. Tears of construction would range from 3 to 7
depending on the altemetlve decided upon.
With the expanded uae of barges during these construction years,what
la the possibility of having significant congestion problems in
the harbor?
SIGNIFICANCE:
Congestion of large ships, barges and tankers in the harbor could be detri-
mental for the following reasons;
1. Increased likllhood of oil spills and fuel leaks from vessels
2. incressed noise and odor problems
3. disruption of recreational boating activities and
commercial activities
*. loss of esthetic appeal to the harbor.
C. It has been stated in the E.I.S. that the use of barges will reduce
or eliminate traffic problems. In order to determine the reliability of
this statement, it Is important to know the location of the port where
.the bargee would be loaded up and leave from.
Baa the departure point for the barges been determined as of yet?
SIGNIFICANCE:
This sres may also be the alte of waterway congestion and land traffic
congestion. Construction materials picked up by the barges at this point
will have to be delivered to thla area by truck.
D. tot the various options, it will be neccesery during construction years
that some material be hauled by trucka to the construction site. The estimated
no. of trucks needed daily enroute to the chosen island will- be 8.
What typea of trucks are we talking about?
What will the trucks be carrying?
SIGNIFICANCE;
There are many different types of trucks. Pick-up trucks, Dump trucks,
trsctor trailer trucks, trucks which carry heevy equipment,. le. bulldozers
and cranes. Some trucka can even carry homes, although this may not apply.
The fact remains, in order to essess the true impact of 8 trucks dally on
local areas, it is important to know what types of trucka to expect.
E. In the building of a 1* and 2* treatment plant on Deer laland, peak
construction noise may reach 78dbs, on Nut Island 84db».
Bas It been determined what time of the day construction will be peak?
What time during the day will construction work end? Nightfall?
Will work continue later into the night during summer months?
SIGNIFICANCE;
Noise is known to have significant health effecta on sensitive individuals
In e population, especially chronic noise. Noise peaks occurring at 12Noon
will be eaaier to handle than noise peaks at 8pm. There must be assurance
that residents living in the areas of construction sites will have some
guarantee of peaceful evenings end nights to Insure thier personal well-being.
F. The present treatment plant existing at Nut Island has been part of
problem with regard to historic onset of pollution in the harbor. Poor
maintenance and operational practices have allowed it to discharge sizable
quantities of waste Into the harbor.
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VI. SUMMARY
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Various alternatives allow for tha removal of this-treatment plant
on Nut Island, replacing it with only a pumping station. It has been
suggested that this action would allow for the use of liacrea of land
for recreational purposes.
How clean and aafe would this land be for recreational purposes
considering the fact that it was previously the site of a poorly
functioning waste treatment plant?
SIGNIFICANCE;
In order to use this land for recreational purposes one would have to
be unquestionably certain of the cleanliness of the area. Even if thla Is
achieved, the public may atlll ba wary as to wether or not the area Is
truly safe.
G. It has been said that property values in the areaa adjacent to
construction sites will go down during the construction years and in some
• cases may not rebound.
Hill there be an existing medium in place to provide compensation
to property owners If they decide to sell out?
SIGNIFICANCE;
Public acceptance of the chosen alternative depends upon maintaining
good relation! with local realdenta.
B. Slgnlficsnt odors ere associated with the construction process.
Has it been reaearcbed as to the possibility of health effecta
assoclatedwlth varloua chemically related odors?
SIGNIFICANCE;'
Prevention of a possible public health incident.
I. In reference to the 'All Secondary Long Alternative'. In the building of
1* and 2* treatment fecllltles on Long Island It will be neccesary to remove
the presently existing chronic care hospital.
will the removal of this hospital from the Island result in a
substantial drop In employment opportunity for the residents of
the island?
SIGNIFICANCE;
This could result in the disruption of many lives on the island, if
their place of work is removed.
In conclusion, I feel the E.I.S. is comprehensive in content
and systematic in their approach. Appropriate channels were followed
in screening the 22 alternatives down to the final 7. The fact that they
did not make mention at this time of the 'no action* alternative, la
inconsistent with NEPA guidelines.
The approach to determining impacts was systematic in the sense that
for each alternative, impacts weraassessed fori traffic, noise, environ-
mentally sensitive areas, recreational impacts, archaeological and
historic resources. Legal technicalities, property value, visual quality,
odors and costs of construction and operations.
There axe many factors to be considered before a final decision is
made, I do feel that the E.I.S. is a neccesary tool In the decision-
making process.
-------
SAMPLE OF PETITIONS RECEIVED
2-343
-------
<
/•. /.. r'•«/)•• C,-.--.. .';;
o'co/)/je//
'
.Ha . tba uadaralcnad object to a primary and/or aaeoodary »ewer«ge treataeat plant
, 'Sta loaf, lalaad. Our objection la baaad oa tba (act that it baa top priority by the
<-ike*OB Barber farka for oao a* a recreation area. Locating tha txaataaat plant on
' Lone lalaad wold ba very axpaaaiva and it la aaaaatlal to tba aaecaaa of tbia pro-
, Ject to keep capital coata and Mlntmra eoata OOMU finally, we object bacauaa of
oar cloaa aaaoclefaa vita tha tons lalaad Boapltal and Ita patlanta.
1DDEB3S
-------
to
I
(Jl
THE.
3TUOEIVT3 or THE
WTWTHROP Mi DOLE .S*OJOOt.
PROTEST THE POSSIBLE.
I.3LAND
fbroRC TAX
-------
MARCH. 1985
WE THE UNDERSIGNED EMPLOYEES OF LONG ISLAND HOSPITAL OBJECT
TO THE PROPOSED SEWERAGE PLANT ON LONG ISLAND. HE SAY KEEP
LONG ISLAND FOR PEOPLE, FOR JOBS, FOR THE HOMELESS, THE SICK,
AND ELDERLY.
XT.
fSTAMLi
7s/ / '
II " V' \
^ Ji
<^ ^I^
(I •-!VKxJi&' T^ • (j^^^ur^. "
2-346
-------
Winthrop Concerned Citizens' Committee
"We, the undersigned, are against ANY'expansion ''
of the Deer Island Sewage Treatment Plant."
Name—(print)
Signature
Address
0.
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2-347 ,
-------
I/to* j
^^lk^i^
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(X)
Winthrop Concerned Citizens' Committee
"We. the undersigned, are against ANY expansion
of the Deer Island Sewage Treatment Plant."
Name—(print)
Signature
Address
jttt-t a
r/^ ?
(L-I.M-.
(a Mr M-*. T. . /*/
TL.i ILvLfl&J
-------
March T. 1989
to
VO
Dear Administrator Deland,
As a citizen of Winthrop, I ask you to please consider the
only FAIR location for siting a sewerage treatment plant -
LONG ISLAND. Winthrop's residential nature is not compatible
with a sewerage plant. Winthrop supports Harbor clean-up and
realizes that environmental and economic issues must be
considered. However, we have the airport, prison, arid the
existing sewerage plant - more than our fair snare of
regional problems. Please support the option which places
all sewerage treatment facilities on LON3 ISLAND. We should
not be asked to, cannot, and will not take any more!
PI**) bciCr/tK * ?*.< 'lAjifiti'Mlf*^' r'j
•^ fjflu •? A / y
Signed: ,
Address:
)£-/
Winthrop, bfc 02152
Michael R. DeUnd
Regional Admlnbtrator .
U.S. Environmental Protection Agency
JFK Federal Building •
Boston, MA 02203
Ret
Comment Regarding the Siting of
Wasti-water Treatment PucUltleT
I. the undersigned, am opposed to the siting of treatment facilities on Nut Island
for the following reasons!
I.
2.
The present treatment plant Is too close to a residential community.
I am strongly opposed to the taking of homes by Eminent Domain and/
or filling the Bay.
There are other, more reasonable, alternatives available that cost
less, have the necessary land resources, and would have less impact
to the surrounding community.
Signature
-------
ODOR/NOISE SURVEY
2-350
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT "HE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
ro
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
JL
j t~
.GNATURE (Optional)
Prt_fc.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
t?-vCr<~~ J'
SIGNATURE (Optional)
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
U)
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT? _ ,
^£ , ,-£2-«'**-< •'*i-'' '
.' -;'„< .. •,_--_ <;._- tut-/./ -/. <•"/- .>-«••-' ' <- -,•'""'•
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
0 find Rii siAvf
~ \~j~ •-
SIGNATURE (Optional)
;l!/./ /'/-
^ ST
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE (Optional)
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
to
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in
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT KflJlCATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
:'•
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
T .H't/fa'S r-'*-Sc-' re.: .ft?'*' ,? S^r'S^
y/ry-V
SIGNATURE (Optional)
SIGNATURE (Optional)
\k
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
K>
CO
O1
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
yg <•
7
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
-';';•(=- Or>,*.l ;/jc ff.-C^B^) PK--.*'~ Pic'-- -ry.f
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SIGNATURE (Optional)
<1-/
\L\.-.-. i- .
'.V A:
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
7
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
*• ./ /
t:J.'••< i•-•.-' ?. i .-7-f-'- n i ft ./ / .
J '
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SIGNATURE (Optional)
/'/*-*>•' •
C .&. /c,'o7
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
10
I
U>
Ul
O1
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUl LIFE?
SIGNATURE (Optional)
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
>ik ,
!. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3.
CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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SIGNATURE (Optional)
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGF TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
K)
I
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Ul
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I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT? JU^' -Jn^^^LA'iliCL^y
(/
^
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE (Optional)
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
r-
. HAVE YOU
BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN X9U DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
\
SIGNATURE (Optional)
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
Ki
U»
cn
-J
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORt APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE 1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
DEER ISLAND SEWERAGE TREATMENT PLANT?
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION Of THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
to
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in
oo
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE;
QUALITY OF YOUR LIFE?
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
U
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
y
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
CiQT?
SIGNATURE (Optional)
C>~C [\
r, $,.
f.)
SIGNATURE (Optional)
/ 55
-------
K>
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01
vo
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
/I.4JI J _
YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
. HAVE
3. CAN
QUALITY
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YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
"Jf^L^
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^A^ *~f.j' s^~~~
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR. AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR. AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
10
I
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1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
'->/! \1 S
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
J
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
-\
SlfiNATUKt
-------
CONCERNED CITIZENS COKMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
K)
I
Ul
at
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
c
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
\\^~.J
SICHATin
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF TUB DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OP CLEANING UP TUB
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR. AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AMD ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
01
IO
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
\le '-.
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR^gDORJ
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
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CONCERNED CITIZENS COMMITTEE
'
OUl COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR. AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
CONCERNED CITIZENS COMMITTEE
OIR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR. AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
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CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE (Optional)
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
•
QUALITY OF YOUR LIFE?
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25
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING IIP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDTES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
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CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED
QUALITY OF YOUR LIFE?
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
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QUALITY OF YOUR LIFE?
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
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CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
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MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
I. HAVE YOU NOTICED mitt ooDORS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NSiSfi- 0( ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE Dr-ER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
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CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR #AS DISRUPTED THE
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OP THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
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CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
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1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
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SIGNATURE (Optional)
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
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1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
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CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
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CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF TliE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
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SIGNATURE (Optional)
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
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MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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QUALITY OF YOUR LIFE?
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MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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SIGNATURE (Optional)
-------
CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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SIGNATURE (Optional)
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
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MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
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ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
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MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
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MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR Of CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE (Optional)
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN 'YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
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CONCERNED CITIZENS COMMITTEE
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CANVXj/U DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE (Optional)
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF T'.IE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEE.;
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MOKE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
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2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
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QUALITY OF YOUR LIFE?
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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3. CAN YOU DESCRIBE WAYS IN WHICH THIS .NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE (Optional) Citi
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
10
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1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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SICNATUitE (Optional)
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
_
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE (Optional)
I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
•
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CONCERNED CITIZENS COMMITTEE
CONCERNED CITIZENS COMMITTEE
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR Of CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
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I. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?.
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
SIGNATURE (Optional)
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE?
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OUR COMMITTEE IS WORKING TO PREVENT THE EXPANSION OF THE DEER
ISLAND SEWERAGE TREATMENT PLANT. WE ARE IN FAVOR OF CLEANING UP THE
HARBOR, AND WE ENDORSE STUDIES THAT INDICATE LONG ISLAND WOULD BE A
MORE APPROPRIATE SITE FOR A LARGER FACILITY.
THIS MINI SURVEY IS DESIGNED TO DOCUMENT NOISE AND ODOR POLLUTION
CREATED BY THE OPERATION OF THE CURRENT DEER ISLAND SEWERAGE TREATMENT
PLANT.
1. HAVE YOU NOTICED NOISE OR ODOR AS A RESULT OF THE OPERATION OF THE
DEER ISLAND SEWERAGE TREATMENT PLANT?
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2. HAVE YOU BEEN BOTHERED BY THIS NOISE OR ODOR?
3. CAN YOU DESCRIBE WAYS IN WHICH THIS NOISE OR ODOR HAS DISRUPTED THE
QUALITY OF YOUR LIFE? 1X'^\4\™Wi^^l^m^'l^-/^!^ ,
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SECTION III
AVAILABILITY OF VERBATIM HEARING TRANSCIPTS
Verbatim transcripts were prepared of the public hearings on
the SDEIS held in Cambridge on February 27, 1985, in Winthrop
on February 28, 1985 and in Quincy on March 7, 1985. A copy is
available for public review at the EPA Regional Library, located
in Room E-121 of the J.F.K. Building, Government Center, Boston
Massachusetts.
3-1
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