&EPA
United States
Environmental Protection
Agency
Region I
J.F. Kennedy Federal Building
Boston, MA 02203
Environmental
Impact Statement
MDC Proposed Sludge
Management Plan,
Metropolitan District
Commission,
Boston, MA.
Part A
Final
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FINAL ENVIRONMENTAL IMPACT STATEMENT
MDC Proposed Sludge Management Plan,
Metropolitan District Commission, Boston, Massachusetts
Lead Agency:
Cooperating Federal Agencies:
Responsible Official:
For Additional Information
Contact:
U.S. Environmental Protection Agency
Region I
JFK Federal Building
Boston, Massachusetts 02203
None
William R. Adams, Jr.
Regional Administrator
U.S. Environmental Protection Agency
JFK Federal Building
Boston, Massachusetts 02203
Wallace E. Stickney, Director
Environmental and Economic Impact
Office
JFK Federal Building
Boston, Massachusetts 02203
Phone: 617-223-4635
Abstract:
This Final Environmental Impact Statement (EIS) evaluates a sludge
management plan proposed by the Metropolitan District Commission (MDC)
and examines other alternative systems; in an attempt to ensure the most
environmentally sound and cost effective sludge management plan for the
handling and disposal of primary sludge for the MDC system. Although the
proposed project would involve 75% federal funding; the ultimate
responsibility for implementing the selected sludge management plan lies
with the MDC. The various alternatives analyzed and their environmental
impacts are discussed in the EIS, and the selected alternative(s)
identified.
No Administrative Action will be taken on this project until 30 days
after notice of this publication appears in the Federal Register.
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This Environmental Impact Statement (EIS) has been written in two
parts and consists of Part A (this document) and Part B (Volumes I and
II). Since this EIS was initiated there have been many changes in Federal
legislation and several other Federal reports1 have been written about
the water cleanup effort in Boston Harbor. However, none of the legislative
changes release the Metropolitan District Commission (MDC) from their
obligation to provide an environmentally acceptable method for disposing
of the primary sludge now generated (and which will continue to be
generated) at the treatment plants. This obligation exists whether or
not the MDC is granted a waiver from the secondary treatment requirement.
Part A of this EIS was written to reflect these changes in legislation,
and the results and concerns of recent studies which .were not considered
during the initial preparation of the EIS. Part B (Volumes I and II)
contains references to federal policy which are no longer applicable and
as a result, several of the conclusions reached and judgments made in
Part B are no longer valid and have been appropriately changed as discussed
in Part A.
In order to provide the reader with a complete picture of the decision
process and to disclose all of the available information, we are circulating
both Parts A and B. Please note that Part B should be read in conjunction
with Part A to clarify its content. Further, information which has
changed because of change in federal legislation, policy, regulations or
guidelines is screened and appears as lighter type in Part B to advise
the reader that those conclusions and judgments have changed based on
information discussed in Part A.
1These are:
a. Draft EIS on the Upgrading of the Metropolitan Area Sewage
System
b. Draft Areawide Waste Treatment Management Plan for the Metropolitan
Boston Area
c. National Science Foundation Draft Final Report - Wastewater
Treatment Facilities Planning in the Boston Metropolitan Area - A
Case Study
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PART A
FINAL
ENVIRONMENTAL IMPACT STATEMENT
MDC PROPOSED SLUDGE MANAGEMENT PLAN,
METROPOLITAN DISTRICT COMMISSION, BOSTON, MASSACHUSETTS
Prepared By
U.S. Environmental Protection Agency
Region I
Boston, Massachusetts
Approved By:
William R. Adams, Jr.
Regional Administrator
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TABLE OF CONTENTS
PART A
Page
Preface ill
Section I - Background 1
Section II - Summary of Proposed Action 3
Section III - Areas of Controversy 5
Section IV - Issues to be Resolved 9
Section V - Consideration of Alternatives: 11
A. Alternative Analysis - Level 1 11
1. No Action 12
a. Explanation of Alternative 12
b. Impacts 12
c. Implementation Considerations 14
d. Summary of Analysis 14
2* Ocean Disposal 16
a. Explanation of Alternative 16
b. Impacts 16
c. Implementation Considerations 17
d. Summary of Analysis 20
3. Land Disposal 21
a. Explanation of Alternatives 21
b. Impacts 21
c. Implementation Consideration 24
d. Summary of Analysis 25
e. Composting 26
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Page
4. Incineration 28
a. Explanation of Alternative 28
b. Impacts 29
c. Implementation Consideration 36
d. Summary of Analysis 37
B. Summary of Level I Analysis 39
C. Alternatives Analysis - Level 2 40
1. Explanation of Alternatives 40
2. Impacts 41
3. Implementation Considerations 48
4. Summary of Analysis 49
D. Conclusions of Level 2 Analysis 51
Section VT - Environmental Consequences 52
Section VII - Public Participation 53
Appendix A-1
Appendix A-2
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PREFACE
The Environmental Protection Agency (EPA)/ along with the Commonwealth
of Massachusetts and the Metropolitan District Commission (MDC) have
consistently been concerned with the continued degradation of water
quality in Boston Harbor. The goal of these and other agencies has been
to improve the Harbor's water quality with the resultant increased
potential for recreation and use as a commercial fishery.
The discharge of digested primary sludge from the Nut and Deer Island
treatment plants has been identified as a contributor to the Harbor's
present poor quality. Both State and Federal Agencies agree that top
priority should be given to solving this problem.
This document is the latest attempt in a series of technical and
environmental studies, the purpose of which is to determine the most cost-
effective and environmentally sound method for handling the sludges
resulting from primary treatment.
In 1974, the MDC, which has responsibility for collection and treatment
of sewage in the Metropolitan Boston area, began to design an incinerator
with a waste heat recovery system to dispose of the sludge thus removing
the discharge from the Harbor. Based on a report prepared for the MDC by
the engineering/consulting firm of Havens & Emerson, the MDC proposed to
locate three multiple hearth incinerators on Deer Island next to the
existing primary treatment plant. Sludge from the Nut Island treatment
plant would be pumped across the Harbor in an underwater pipeline to Deer
Island for incineration. Their proposal also called for the resultant
incinerator ash to be put in a landfill or a diked area adjacent to Deer
Island.
Because of the public controversy surrounding construction of
incinerators on-Deer Island and EPA's own concern about the environmental
impact of the incinerators, EPA initiated the environmental impact
statement (EIS) process under the National Environmental Policy Act (NEPA)
to study the proposed plan and available alternatives. Particular
attention was given to the alternatives of land disposal of the sludge
which MDC had evaluated in its facilities plan. Further, the possible
coincineration of the sludge with solid waste from the Boston Metropolitan
area was studied by the MDC on an EPA grant and the results of that
study were included in the EIS. After three years of study and continuing
public debate, EPA has concluded that incineration represents the most
feasible and the least environmentally adverse option currently available
for alleviating the continuing water quality problem created by the
present sludge disposal method.
The technology and the regulations for dealing with the handling and
disposal of sludge produced by municipal wastewater treatment plants are
still evolving. Both EPA and the Commonwealth of Massachusetts continue
to seek alternatives which might make use of the nutrient resources in
.the sludge. Therefore, we wish to place our recommendation for incinerators
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in the following perspective: Although the EIS indicates that, in order
to provide continuing capability to dispose of the primary sludge and
thus keep it out of Boston Harbor, the incinerators will need to be
constructed, we would like to minimize the potential for air quality
problems associated with them. To this end, the MDC has agreed to continue
to investigate the feasibility of composting the primary sludge. In
addition, EPA will condition any grants to MDC on this project to require
that MDC will continue and build upon its program of composting and
subsequent land disposal in consonance with findings of that feasibility
study. EPA is willing to support and fund the construction costs of
composting as an adjunct or alternative to incineration where it can be
demonstrated that it would be environmentally sound and cost effective to
do so.
Although the MDC's demonstration sludge composting project has
terminated, EPA recommends that a composting operation be conducted by
the MDC during the feasibility study. EPA believes that an operational,
continuous composting program would serve to compliment the feasibility
study. The twofold purpose of this will be to determine the technical,
marketing and use opportunities for the production and disposal of a
sludge based compost, and to actually dispose of as much of the digested
sludge by composting as is practical.
We are critically aware of how the increasing shortages of resources
in the future will make the nutrient value of sludge a commodity for
which reuse will be the most cost-effective disposal method. We feel
that the Joint Group of Experts on the Scientific Aspects of Marine
Pollution meeting in October 1974 stated the most comprehensive and best
long-term policy towards sewage sludge disposal when they said, "Ideally,
the only ultimate method of eliminating waste disposal is recovery and
reutilization of the materials presently considered to be wastes; other
disposal options merely remove material from one part of our environment
to another." However, until steps are taken to ensure that sludge can
safely and economically be recycled (e.g., industrial pretreatment), some
interim solution to the sludge management problem must be implemented.
We believe that the proposal of this EIS, with its recovery of some of
the thermal value of the sludge, is an economically and environmentally
sound interim solution, but that we, the Commonwealth, and the MDC must
look forward to a long-term solution. We are convinced that the actual
operation of a composting program at Deer Island is the first step in
that direction and expect that when the incineration facilities proposed
by this project have reached the end of their useful engineering life in
15-20 years, that the technologies and economic factors affecting sludge
reuse will have progressed to the point where those interim facilities
will no longer be needed.
Much of the study relating to the impact of incinerators has focused
on the decision as to the proper location and method of disposal for the
resultant incinerator ash. During the period of preparation of the Final
EIS, the question existed as to whether municipal sludges which contain
materials resulting from industrial discharges would be considered to be
"hazardous" under the Resource Conservation and Recovery Act (RCRA), thus
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requiring very high degrees of leachate control. EPA is currently in the
process of developing regulations which would implement the intent of
RCRA. Rather than continue to hold up the EIS for evaluation of ash
disposal options, we are providing our findings to date and are prepared
to fund further study by the MDC for the disposal of the ash while they
proceed with design of the incinerators. We will not authorize funds for
construction of the incinerators until after an environmentally acceptable
ash disposal plan has been developed.
In summary, EPA is publishing this Final EIS, but with the admission
that the environmental impacts of all the component elements have not
been completed. We are taking this course of action because we believe
that further theoretical analysis of the alternatives at the federal
level will not be as effective in solving the problems of sludge management
as practical planning action'at the state and local levels. At those
levels technical and environmental studies will continue to evaluate the
extent to which composting of sludge will be a feasible and practical
adjunct or alternative to incineration of the sludge, and perform an on-
the-ground analysis by the MDC of the best location for an ash disposal
facility. Should the follow-up environmental studies produce new
information that would lead to conclusions not adequately supported by
this Final EIS, E?A will publish a supplement to the Final EIS before
authorizing construction funds.
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SECTION I
Background
The Metropolitan District Commission .(MDC) is a state agency, which
is responsible for construction, maintenance and operation of water,
sewer and recreational facilities for the cities and towns within the
Boston metropolitan area. As such, the MDC owns and operates the
metropolitan sewage system which collects industrial wastewaters and
municipal sewerage from the MDC's 43 member communities, and conveys the
sewage to two treatment plants located in Boston Harbor which treat the
sewage prior to discharge. The two existing treatment plants are located
at Nut Island, in the city of Quincy, and Deer Island, a peninsula which
is part of Boston located southeast of the Point Shirley area of Winthrop.
The Nut Island treatment plant serves the MDC southern service area
consisting of 21 communities, which are generally residential in character,
and certain portions of Boston. It processes an average daily sewage
flow of 130 million gallons per day. The Deer Island plant serves the
more industrialized areas of Boston, Cambridge and Somerville to the
north as well as the northern suburban communities and processes an
average daily flow of 320 million gallons "per day.
Both of these plants provide primary wastewater treatment. Primary
treatment involves the settling out.by gravity of the heavier or grosser
solid particles. The effluent from both plants is chlorinated to destroy
pathogenic or disease causing organisms and is then discharged to Boston
Harbor off Deer Island and Quincy Bay. The material removed from the
sewage by the primary treatment process is called 'primary sludge and
contains organic as well as inert materials including nitrogenous compounds,
sand, grit and oil. It can also contain heavy metals, pesticides and
some potentially dangerous organic materials such as PCBs.
At both locations the sludge is subject to a process called digestion
which changes some of the organic constituents into usable methane gas
which is utilized. Digestion reduces, but does not eliminate, one
pollution-causing aspect of sludge by reducing the nitrogenous content of
the sludge by about 40% and also helps recover energy from this waste
product. After the sludge has been digested, it is mixed with chlorinated
effluent and discharged into President Roads, the main channel in Boston
Harbor* In an attempt to insure that the discharged sludge is carried
out to sea and does not stay in the Harbor, it is discharged only during
outgoing tides. The discharge of sludge is a significant contributer
toward the total pollution problem of Boston Harbor and is contrary to
the provisions of the Federal Water Pollution Control Act and the Federal
Marine Protection Sanctuaries and Research Act.
The EPA is the federal agency charged with assisting municipalities
and regional agencies in complying with federal water pollution control laws.
As such, EPA issues and enforces the federal permits MDC holds that
allow the effluent and sludge discharges and administers and grants
federal monies appropriated by Congress to help communities and authorities
comply with the law. In order to meet standards and deadlines set by its
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permit and the law, MDC intends to apply to EPA for a federal grant to
purchase and construct equipment and facilities needed to manage the
USD's primary sludge. Since the method proposed by the MDC, as well as
alternatives to that proposal, would cost in excess of $20 million and
would have a potential for significant beneficial as well as negative .
environmental impacts and also because there had been significant public
interest and opposition to some elements of the proposed project, EPA is
required under the provisions of the National Environmental Policy Act to
prepare an Environmental Impact Statement (EIS).
The environmental impact process consists of two phases: A draft
document which, in this case, was published for comment in February of
1976, and this Final EIS in which EPA makes a final decision on the
project which we consider to be the most cost-effective and environmentally
sound and, therefore, which we will consider eligible for federal funding.
Often in the case of large and complicated projects, information is
developed during the design phase which results in a modification of some
of the details of the project. If these modifications result in significant
impacts significantly different from those we currently anticipate, a
revised Final EIS may be required.
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SECTION II
Summary of Proposed Action
The action proposed in this Final EIS is for the granting of funds .by
EPA to the MDC to design and eventually construct all necessary facilities
and equipment to collect and dispose of the primary sludge generated by
by the Metropolitan Sewerage District. The project would provide for the
pumping and piping of the southern area sludges to Deer Island by means
of two high-head, non-clog centrifugal pumps and by extending the existing
sludge outfall pipe and building one completely new pipe. The existing
sludge discharge line from Nut Island would be extended from its present
terminus on Long Island, across President Roads to Deer Island. The new
sludge force main would be constructed parallel to the existing line
along the mud flats near Long Island and thence across the Harbor to Deer
Island.
At Deer Island(the sludge]from the northern service area along with
the Nut Island sludge(would be chemically treated, vacuum filtered and
incinerated.) Incinerator equipment would consist of three multiple hearth
units with a total capacity of 128 tons (dry weight basis) per day. The
units would be operated two at a time with one unit for standby. (j2ie
incinerators would be designed to operate) autogenously ([without the use
of supplementary fueU) (and heat would be recovered and used to generate
electricity for use at the plant.\
Installation of air pollution control equipment would be required on
all incinerators to insure that any air quality impacts would be minimized.
Incinerator emissions would be controlled by use of a Venturi-type scrubber
with a 42" H2O pressure drop through the scrubber.
In an attempt to encourage and foster growth of recycling sludges,
and thereby reduce the amount that must be incinerated, the MDC has agreed
to pursue its investigation of the feasibility of composting MDC sludge
and will dispose-of as much sludge by composting as market conditions and
operating costs allow. Items to be included in this investigation are as
follows:
Determine the potential demand for composted primary sludge
within the Boston Metropolitan area, particularly for use on public and
non-food producing lands.
Determine the quantities of sludge that can be composted
relative to this potential demand.
Evaluate the technology of composting primary sludge, including
the MDC's pilot project.
Evaluate site requirements and locations.
Prepare a preliminary design for a composting project sized
to meet the potential demand.
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Develop an appropriate marketing and distribution system.
Assess the public health, energy, and resource recovery
impacts associated with the project.
Evaluate legal, institutional, financial and managerial
constraints associated with the composting project.
Estimate construction, operating and maintenance costs and
possible revenue related to the project.
EPA recommends that the MDC conduct permanent and continuous sludge
composting to the full extent that the feasibility study determines is
practical. EPA will also provide MDC with facilities planning financial
support to perform the feasibility investigation and evaluate composting
as a larger scale alternative for ultimate disposal. Where it is determined
that total composting is more environmentally sound and cost-effective
than incineration, EPA would fund the construction costs of composting as
an alternative to incineration. Deer Island will initially be considered
as the composting site, but alternative sites and transportation requirements
will be considered.
EPA will require as a condition of federal grants on this project,
that as part of the MDC's feasibility study on composting they will
conduct an actual composting operation in order to dispose of as much of
the MDC primary sludge as is currently possible and practical. EPA feels
that in addition to currently being able to dispose of a portion of the
primary sludge through composting, small scale composting at this time
would help to refine the technical questions that exist and help build
a market for the compost product^
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SECTION III
Areas of Controversy
As part of the EIS process, a draft document was published and
circulated. Comments received on the Draft EIS were responded to and
incorporated into the final document. These comments, as well as EPA's
interactions with the MDC, various Department and Divisions of the
Commonwealth, other governmental agencies, and community-based groups
have surfaced many areas of concern and controversy. The EIS process has
not resulted in a sludge management plan which will satisfy the requirements
and desires of all parties who commented on or were involved in the
process. However, we believe that all reasonable alternatives have been
investigated or provisions have been made for them to be investigated
thoroughly, and decisions have been made which reflect a sensitivity to
the concerns and issues involved. We will only attempt to highlight what
we feel to be the major areas of controversy.
1. There was a general feeling expressed by many commenters that the
destruction of sludge by incineration results in the loss of a resource,
creates adverse air quality and other environmental impacts and that
there are other land-based alternatives available which are much more
preferable. We agree that incineration is not.the ideal long-term
solution, but in order.for any recovery or reuse option to be viable, it
would require the implementation of pretreatment regulations, the
institution of other programs to reduce the metals/toxic content of the
sludge, and the development of the technologies, policies and regulations
needed to ensure safety. All these 'developments will take a considerable
amount of time to implement. Meanwhile, the discharge of sludge and its
adverse impacts which we feel are much more serious than those associated
with incineration will continue. We do not feel that the incineration
of sludge now will prevent or hinder the MDC from exercising land disposal
options in the future. In fact, the composting elements of the recommended
solution will help overcome some of the obstacles that presently exist in
implementing a land disposal option.
2. Considerable controversy has been generated by the potential air
quality impacts the proposed incinerator will have on communities near
the Deer Island site, especially the town of Winthrop. EPA believes that
the proposed incinerators can be designed and constructed with pollution
control devices which will reduce the emissions to levels which will not
cause air quality violations. The air quality modeling done in the EIS
indicated that all of the federal ambient air quality standards (Primary
and Secondary) will be met. Much concern has been expressed by the
residents of communities which may be impacted by the incinerators, that
emissions meeting federal standards are no assurance that human health
and welfare will be protected. EPA sets the National Ambient Air Quality
Standards specifically for pollutants of nationwide concern that have known
adverse effects on human health in order to provide such assurance.
Based upon data and research, Primary and Secondary standards are
established. Primary standards' specify the highest concentration of a
pollutant in the atmosphere that can be tolerated without endangerment to
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the public health. Secondary standards (usually more stringent than the
Primary) are established at a level needed to protect the public welfare
from adverse effects, e.g., crop damage, animal diseases, etc. Although
compliance with federal standards is not an absolute guaranty that all
risks from incinerator emissions will be eliminated, EPA believes that
standards do reasonably ensure and safeguard against the adverse effects
associated with regulated pollutants.
Aside from the National Ambient Air Quality Standard pollutants,
concern has been registered over emissions which would result from the
heavy metals of the MDC sludge, specifically mercury and cadmium. Mercury
is considered a "hazardous pollutant" by EPA and as such, special emission
standards have been established to ensure that increases in morbidity or
mortality would not result from any source emitting mercury. The predicted
mercury emission rate is well below the regulated allowable levels,
however, the MDC will be required to sample and report its actual mercury
emissions at least once a year to ensure safety and compliance.
Emission limitations do not currently exist for cadmium. The
expected concentrations of cadmium were calculated and found to be well
below levels heretofore associated with harm to human beings.
Controversy exists as to whether any emissions resulting from
incineration are to be tolerated. While EPA does not deny the fact that
certain pollutants will be emitted as a result of sludge incineration, we
do believe that compliance with Federal and Commonwealth air quality
standards will ensure that significantly reduced air quality does not
result. Further, these air quality impacts will not result in a danger
to human health or welfare.
Concern had been expressed that air quality emissions of the
proposed incinerators have been "modeled" or "predicted" along with
expected 1985 background concentrations and that actual levels might be
higher. While EPA has confidence in these modeling efforts and believe
them to be accurate representations of future conditions and expected
emissions, we will require further air monitoring to be conducted during
the updating and additional facilities planning, and design stages of
this project.
Additional air quality monitoring will be performed to determine
with more certainty the actual levels of air pollutants and the locations
of the highest of those levels. Monitors will be placed near sensitive
receptors and areas where the modeling efforts indicated potential
emissions problems. The monitor will most likely be located in the Point
Shirley or Winthrop area. Pollutants to be monitored are: Nox, Total
Suspended Particulates (TSP), Lead and SC^.
3. Civic groups in Winthrop have shown strong opposition to the
addition of any further facilities on Deer Island. That opposition has
been based on the fact that the impacts of any increased construction
traffic on the community would be severe and the feeling that the existing
prison and sewage treatment plant and the proximity to Logan Airport has
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resulted in the Town being subjected to an,inordinate amount of environmental
stress. EPA and the MDC, after exhaustive studies can find no alternative
site for sludge disposal facilities which would be as.rcostreffective and
have less of an environmental impact. In an attempt to reduce the impact
on the community of Winthrop and in particular to mitigate the construction
related impacts on that community, we will include as. ;part of EPA's
construction grant conditions (based on an evaluation) to the MDC, the
requirements that the transportation of construction materials and
equipment to the Deer Island site be by barge, and that access to the
site by construction workers in private autos be severely restricted and
the use of shuttle buses be substituted. These grant stipulations will
be required of the MDC unless it is demonstrated that the costs of these
mitigating measures would be excessive or unreasonable, or that greater
adverse environmental impacts would result. The shore-based facilities
to be constructed in support of the barging operations should be permanent
for future use in MDC operations. The MDC will incorporate in its
specifications and other design and contractual documents a requirement
for the above. The MDC will specify sites for the shore-based facilities
and the shuttle bus parking lot, and will perform an environmental
assessment to insure that their selection minimizes the socio-economic
and natural environmental impacts. With respect to shuttle busing, the
MDC will be required to submit a transportation management plan with an
environmental assessment for approval to EPA. This plan and associated
assessment is to be coordinated with the involved communities. We feel
the air quality impacts of the incinerator will be minimal and the
aesthetic and. noise impacts can be mitigated by design features and
operational precautions.
4. Some concern has been expressed regarding the possibility that
future sludge disposal options may be limited by the construction of the
primary sludge incinerators. Specifically, as the treatment process is
upgraded or flows increase and more sludge is generated, there will be
pressures to expand the existing incineration facilities rather than
looking at alternative disposal methods.
The EIS for upgrading the level of MDC's sewage treatment plant
looked at the disposal options available and recommended a composting
option. We feel that even if a waiver to secondary treatment is granted,
the fact the pretreatment is being implemented and a composting operation
being continued indicates that the MDC and EPA are very serious about
developing non-destructive options to sludge disposal. We both look at
incineration as an interim and relatively short-term alternative to be
utilized until such time as other future options become practical,
cost-effective, and safe from an environmental and public health point
of view.
5. The final major area of controversy surrounding the project
concerns the fact that the construction of an incinerator on Deer Island
is not wholly in compliance with the Boston Harbor Island Plan. EPA
feels that the plan, which includes reference to an expanded sewage
treatment plant on the Island, is not being violated by the proposal for
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an incinerator. Any other alternative site in and around the harbor,
except possibly. Spectacle Island, would be more crucial to the recreation
objectives of the.plan than the Deer Island site.
We feel that these are the major areas of controversy. We understand,
however, that other individuals or organizations, because of local
interests, may feel that they have serious concerns and objections to the
project other than those mentioned here. All of the areas of concern
which were commented on at the Draft EIS stage are in Part B, Volume I of
this document and an attempt is made to respond to all of them.
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SECTION IV
Issues to be Resolved
There are certain aspects of the proposed project which are not
completely addressed in the EIS and which will require further environmental
and feasibility studies to determine how the detailed aspects of the
incineration alternative will be implemented. These additional studies
will be performed by the MDC as part of an updating of the facilities
planning effort and prior to the facility design phase of the project.
Specifically, a historical evaluation and archeological survey of Fort
Dawes and a §404 evaluation for the dredging and filling associated with
the project will be completed. This update will also include such tasks
as: characterization of the sludge and determination of quantities,
updating of cost estimates, technical evaluation of dewatering, and a
reevaluation of pumping vs. barging of sludge from Nut to Deer Island.
Upon completion of the Step I updating work, the facility design phase of
the project will be initiated. While Step II design proceeds, additional
Step I facilities planning will be performed to: determine the actual
method and location of ash disposal, and to study the feasibility of
sludge composting and conduct a pilot composting operation.
Part B of the Final EIS analyzes ash disposal options for the project
and makes the recommendation that if the incinerated sludge ash is
determined to be hazardous it shall be disposed of in a landfill on Deer
Island in order that all of the rain water leached through this material
can be recovered and treated. If the ash is judged not to be hazardous
as defined by. regulations pursuant to the Resource Conservation and
Recovery Act, it is proposed to be barged to Spectacle Island for disposal.
The MDC had originally proposed to dispose of the ash in a cofferdammed
area off the shore of Deer Island. This option was rejected by the EIS
on the basis of federal policy at that time. The thrust of this policy
was that construction on floodplains or wetlands could not be allowed if
a practicable alternative existed. Because the proposed cofferdammed
area was so clearly subject to this policy, EPA rejected the proposal
without conducting a full-scale wetland/floodplains environmental analysis.
Changes in a recently issued Presidential Executive Order and EPA's
implementing regulations now require that such an analysis be performed.
It is EPA's recommendation that the MDC perform such an assessment in
continuation of its planning work so as to determine the full impacts of
all ash disposal options and to select the most environmentally sound
one. When this work is complete, EPA will fulfill its responsibilities
under NEPA and amend the Final EIS if necessary.
The sludge management plan will require a §404 dredge and fill permit
to be issued by the U.S. Army Corps of Engineers (COE). The construction
of a cross-harbor sludge line will require some dredging, the construction
of a barge pier will require a COE permit and may involve some filling
and, finally, depending on the ash disposal method selected, a dredge/fill
permit may be required. It will be the MDC's responsibility to perform
the necessary environmental studies for submission to the COE when the
permits are applied for. These studies will be performed in light of
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EPA's Guidelines for the Discharge of Dredged or Fill Material into
Navigable Waters (Federal Register, September 5, 1975). These guidelines
will require an analysis of the physical, chemical, and biological impacts
of placing ash in an open water or wetland area. Consideration will be
given to impacts on: water quality; fish spawning and nursery areas;
shellfish beds; food chain; wildlife areas; wetlands serving important
biological functions; and aesthetic, recreational, and economic values.
If analysis indicate that impacts on these resources would be unacceptable
or contrary to the public interest, the permit would be denied. The MDC
can reference this EIS's discussions of available alternatives and need
for the project when preparing that 404 evaluation.
Finally, the KIS did not complete its study of the impacts of the
project on the historical assets of Deer Island. The construction of the
incinerator and ash disposal will impact other assets on Deer Island,
specifically Fort Daves. The full impact of the MDC sludge disposal
operations upon the historical/archaeological assets of Fort Dawes has
not been determined. This evaluation will be performed during the
facilities planning update and a determination and report will be published
prior to proceeding with Step II design or the start of any construction.
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SECTION V
Consideration of Alternatives
During preparation of the Draft EIS, four basic broad alternatives
were considered and analyzed in detail* They were: Ocean Disposal,
Incineration, Land Disposal, and the alternative of No Action. Detailed
analyses of these alternatives were performed based on their use of
resources and energy, their economic costs, and their social and
environmental impacts*
During preparation of the Final EIS, the original alternatives
presented in the Draft EIS were reevaluated in light of new information
developed, and federal guidelines and regulations issued between the
writing of the Draft and Final EIS. In addition, early in the preparation
of the Final EIS the alternative of coincineration was evaluated but
eventually eliminated.
A. Alternative Analysis - Level 1
The first level of analysis involved investigation of the following
four alternatives:
1. No Action - Continued digestion of sludge and discharge to
President Roads on outgoing tides from both Deer and Nut Islands.
2. Ocean Disposal - Barging of dewatered sludge from Deer Island for
dumping at a deep water offshore location.
3. Land Application -
. Dewatering and land application on private farmlands
Dewatering with 50% for land application on private farmlands
and 50% disposal in a landfill
. Dewatering with production and marketing as a fertilizer
4. Incineration -
. Dewatering, incineration with energy recovery in three multiple
hearth incinerators and disposal of ash residue
• Incineration of the MDC wastewater sludges with solid waste
from the City of Boston
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1. No Action
a. Explanation of Alternative (Existing System of Disposal)
Under the No Action alternative the present method of primary
sludge disposal would continue to be utilized. No additional facilities
would be constructed and only routine and periodic maintenance and
reconstruction would take place.
Presently the primary sludge from both the Deer and Nut Island
primary treatment plants is anaerobically digested to reduce the volume
and organic content of the sludge. Lime is added to aid in digestion.
The digestion process produces methane gas which is used for power
generation at the treatment plants. The digested sludge from both plants
is disposed of by discharging to the President Roads area of the outer
Harbor. The present practice consists of mixing the digested sludge with
chlorinated primary effluent and discharging it for four hours at the
beginning of each ebb tide. This is done in an attempt to insure that as
much of the sludge as possible is carried on the outgoing tide away from
the harbor. In fact, according to the July 1971 report prepared by
Hydroscience, Inc. for the Massachusetts Division of Water Pollution
Control (DWPC), it was determined that approximately 80% of the sewage
sludge is carried out to sea with the remaining 20% returning to the
harbor on the next flood tide. This results in the deposition of 15-20%
of the discharged sewage sludge solids west of the outfalls near Deer
Island. In addition to the sludge a minor amount of ash from a screenings
and grit incinerator is pumped to the Nut Island sludge discharge line.
b. Impacts
Water Quality - The discharge of sludge from both MDC plants is a
significant contributer to the total water pollution problem of Boston
Harbor. It has been identified as such by numerous studies sponsored by
the EPA and the Commonwealth as a result of the 1968-1971 enforcement
conferences on the pollution of Boston Harbor. Those studies were
performed to make specific recommendations regarding actions to be taken
to improve the water quality of the Harbor to the point where it would
meet r.he standards applied to it.
One of the specific recommendations in the final enforcement
conference report was that "alternative sludge disposal methods must be
found" for the Deer and Nut Island sewage treatment plants. The report
stresses the impact the Harbor's poor water quality had on shellfishing
and stated that "substantial economic injury results from the inability
to market shellfish or shellfish products due to pollution" of the Harbor's
waters. The majority of the shellfish beds in Boston Harbor were and are
still closed. While the sludge discharges have never been attributed as
the cause of shellfish closures, it is reasonable to conclude that the
known heavy metals and other toxic materials present in the sludge are
not beneficial to the biotic population of the harbor's waters.
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In addition, water quality has affected the use of existing
recreational facilities and the development of the full recreational
potential of the Harbor, its surrounding shores, and islands. It is also
reasonable to conclude that water quality is adversely affected by the
more than 20% of the sludge discharges to President Roads that actually
reenters the Harbor and is deposited there. The presence of these sludge
deposits, with their toxic 'constituents, will be a restraint on plans for
the future recreational development of Boston Harbor. In light of both
the Commonwealth's and MDC's commitment to the development of the harbor
islands as a recreational resource we see the solution to the sludge
disposal problem as being a critical step in that development.
EPA is mandated to develop programs, enforce laws and regulations,
and grant funds, in order to improve the quality of the surface waters of
our Country. To that end we have worked with the Commonwealth to establish
standards for water use which will limit the amount of pollution a water
body will have to tolerate. In the case of Boston Harbor a standard of
"SB" has been established. This classification means that its waters
should be "suitable for bathing and recreational purposes including water
contact sports". It should also have "good aesthetic value and be suitable
for certain, shell fisheries with depuration." The MDC in its report
before the 1971 enforcement conference stated that "it is evident that
the existing sludge discharges directly interfere with these assigned
uses." EPA totally concurs with that finding.
Past experiences here in Boston and other areas where massive
amounts of sewage sludge are disposed of to the marine environment have
indicated that the hitherto unforeseen future impacts of such actions may
be much more serious than the more predictable near-term impacts.
Specifically the anoxic condition that occured in the sludge disposal
area off New York City and New Jersey may be taken as a warning against
the long term dumping of sludge. The discharge each day of over 100,000
dry Ibs. of sludge solids to Boston Harbor does have an extremely severe
adverse impact on the water quality of Boston Harbor. The inability of
the Harbor to assimulate those waste products and maintain its classification
has adversely affected its present shellfishing and recreational uses
and has inhibited the future development of those resources.
Economic Impacts - The immediate capital cost of the No Action
alternatives is zero but the long-term monetary implications to the MDC
and the Boston area are very unfavorable. The facilities for digesting,
pumping and piping the sludge are aging and will need replacement shortly.
Since those facilities could not comply with the federal laws requiring
cessation of sludge discharges they could not be eligible for an EPA
grant which would provide reimbursement for the majority of the replacement
costs of those facilities.
The economic loss to the area due to the unproductive shellfish
beds and the lost recreational opportunities has not and probably could
not be calculated. However, these very serious losses should be considered;
the No Action alternative still costs the taxpayers, industry and commerical
interest in the Boston area a significant amount of money.
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Other Impacts - Since the discharge of sludge to the Harbor
involves few interfaces with elements of the natural and man-made
environment other than the Harbor and its biota, it has little if any
impact on those other elements.
c. Implementation Considerations
EPA, the Commonwealth and MDC's concerns regarding the future
discharge of sludge to the Harbor reflect the same concern which prompted
the passage of legislation to require that such practices be eliminated.
Both the Federal Water Pollution Control Act and the Marine Protection
Research and Sanctuaries Act expressly prohibit the discharge or dumping
of municipal wastewater sludges in rivers, harbors or the ocean. The
reason for this prohibition is clear.
In 1970 the Congress had considered a report by the Council on
Environmental Quality which noted that rapidly growing amounts of sewage
sludge were being disposed of to the oceans and estuaries of this country,
that they contained heavily concentrated toxic materials and that they
created serious environmental and health conditions. Among other
recommendations the report concluded that the ocean disposal of even
stabilized sludges should be stopped and that "high priority should be
given to protecting those portions of the marine environment which are
biologically more active, namely, the estuaries and the shallows near
shore areas in which many marine organisms breed or spawn. These biological
areas should be delimited and protected." This finding makes it explicit
that national policy was concerned not only with the impacts of these and
other wastes on the deep ocean but also the more sensitive near shore
areas.
In addition to the statutory prohibitions, MDC's present discharge
permit, issued pursuant to the Federal Water Pollution Control Act (FWPCA)
requires that the MDC cease the discharge of sludge. Failure to comply
with this permit will place the MDC in violation of the federally issued
permit and federal law, and thus subject the MDC to the remedies provided.
These prohibitions are the most serious implementation problem associated
with this option.
d. Summary of Analysis
Because of its severe water quality impacts, as reflected by its
basic illegality, the no action alternative is considered unacceptable.
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Elements of Proposal Common to all Action Alternatives
The determination of the EIS was that consolidation of facilities at
Deer Island represented the most cost efficient and environmentally
acceptable method of sludge processing. All of the final options studied
involved digestion and dewatering of sludge and therefore include the
following common element of pumping, piping and processing.
A new sludge pumping facility will be provided to transfer the sludge
from Nut to Deer Island. These pumps will be high head, centrifugal, non-
clog types with one used for service and the other for standby. The
existing Nut Island sludge disposal line will be extended from the tip of
Long Island to Deer Island and a new parallel sludge force main will be
built across the 4.2 miles of Boston Harbor from Nut to Deer Island.
The digested sludges from the two treatment plants will be combined
at Deer Island and then chemically conditioned and dewatered. At this
point the three action alternatives to subsequently be discussed (ocean
disposal, land application and incineration) propose different means of
ultimately disposing of the digested dewatered sludge.
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2. Ocean Disposal
a. Explanation of Alternative
The ocean disposal alternative consists of barging the dewatered
Nut and Deer Island sludges from a dock/loading facility at Deer Island
to a location approximately 70 nautical miles east of Boston known as the
Murray/Wilkinson basin. The size of the barge/s and the number of trips
per month/year needed were not developed in detail in the EIS since this
alternative was eliminated fairly early in the process based on its
associated environmental impacts, (discussed below) and the fact that the
alternative is considered illegal and would, therefore, be impossible to
implement.
b. Impacts
The ocean disposal of sludge has the potential for many adverse
impacts on ocean sediments, the water column and the species of marine
life which inhabit each of these. Due to the fairly high levels of heavy
metals which would be present in the MDC's dewatered sludge, a marked
increase in metals content would occur in the upper levels of sediment at
and near the disposal site. These metals would be taken up by organisms
which would inhabit the site and surrounding areas and could be passed on
up the food chain to species which have a commercial use. The organic
material in the sludge would cause a depletion of oxygen in the water
column and an anoxic (no oxygen) condition in the sediments and the
immediately adjacent water column. This would prevent the normal marine
species which usually inhabit these areas from continuing to do so.
Experience in the New York bight, the site of long term sewage sludge
dumping, indicates that the area is totally devoid of all life and that
the edges are inhabited by only the most tolerant species. In addition,
the mixing of the sludge in the water column as it is dumped could result
in contamination of surface water. This would allow heavy metals, toxic
organic compounds, and pathogens to infect the plankton which larger
species feed on and thus adversely affect the viability of commercial and
recreational fisheries.
In light of the impacts associated with the ocean dumping of
sludge the Congress passed the Marine Protection Research and Sanctuaries
Act which prohibits the dumping of harmful sewage sludge into the ocean.
Congress clearly recognized the dangers inherent in ocean disposal of
harmful sewage sludge when in 1977 it passed this legislation. Congressmen
William J. Hughes of New Jersey, the author of the provision, explained,
"These sludges contain high concentrations of a number of metals. There
are serious risks to marine life and also to humans if they should reach
fish or shellfish that come from the dumping area. EPA has reported that
sewage sludge dumped in 1974 in the Atlantic contained about 24 tons of
cadmium and that sludge dumped in the New York bight alone contained
about 2 tons of mercury. In addition, there exists the possibility that
sludge dumping may contribute to the problems of excess nutrients in the
ocean waters leading the algae blooms that deplete oxygen in the sea
water and result in fish kills." Congressman Robert Leggett of California
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added that, "a large part of the opposition to elimination of ocean dumping
stems from the fact that it remains the cheapest means of disposing of
municipal wastes. The ocean dumping of sewage sludge usually cost $1.80
per ton while the alternative costs $5.00 per ton. My concern is that
while it may be cheaper for the particular communities involved, it is
quite likely very expensive for the nation as a whole. For example, the
Department of Commerce has indicated that the shellfish industry has
ceased harvesting in over 18.5% of the shellfish waters because of
intolerable levels of pollution." The concern that congress had was
emphasized when the House banned ocean dumping by a vote of 359 to 1 and
the Senate followed suit by a voice vote.
Since this option has very few interfaces with elements of the
natural and man-made environment other than the marine/water quality one,
its impacts on other areas are negligible. The presence of a sludge
barge and dock on Deer Island could have a minor adverse aesthetic impact
and there is a possibility of odors from the barge and transfer facilities
if proper operation and maintenance procedures are not followed. Since
this alternative utilizes the most efficient method of hauling and requires
no facilities for disposal it has the lowest monetary cost and is the
most energy conservative.
c. Implementation Considerations
Appendix "O" of Part B, Volume II, "Review of Legal Measures and
Policies Relevant to Ocean Disposal of Sludge" discusses the implementation
problems and legal ramifications associated with the ocean disposal of
sludge. The most important of these policies are the 1977 amendments to
the Marine Protection Research and Sanctuaries Act of 1972 as follows:
Sec. 4(a) - The Administrator of the Environmental Protection
Agency shall end the dumping of sewage sludge into ocean waters, ..., as
soon as possible..., but in no case may the Administrator issue any
permit..., which authorizes any such dumping after December 31, 1981.
Sec. 4(b) - ... the term "sewage sludge" means any solid,
semisolid, or liquid waste generated by a municipal wastewater treatment
plant, the ocean dumping of which may unreasonably degrade or endanger
human health, welfare, amenities, or the marine environment, ecological
systems or economic potentialities.
Legal interpretation of the law does not explicitly state that
ocean disposal of sludge be unequivocally banned. It states rather that
only sewage sludge which may unreasonably degrade the marine environment
be prohibited from ocean dumping. Further, the question has arisen as to
whether or not the disinfection of sewage sludge by energized electron
treatment would be allowable for ocean spreading under the prohibitions
of the Marine Protection, Research and Sanctuaries Act. EPA's Regional
Counsel has rendered the legal opinion that this manner of disposal may
be permitted under the act but only i£ it can be demonstrated that the
dumping (spreading) will not unreasonably degrade the marine environment
and that no practicable alternative exists.
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The EPA Ocean Dumping Regulations published January 11, 1977,
(40 CFR, Parts 220-228) require the cessation of the ocean dumping of
any material which does not meet the EPA environmental impact criteria
(40 CFR, Part 227, Subpart B) by December 31, 1981. This includes all
sewage sludge presently being dumped. This regulation is fully consistent
with the intent of the Marine Protection, Research, and Sanctuaries Act,
as amended, (MPRSA), which states in Section 2(b) that it is the policy
of the United States
"to prevent or strictly limit the dumping into ocean
waters of any material which would adversely affect
huma-.i health, welfare, or amenities, or the marine
environment, ecological systems, or economic
potentialities".
EPA, in following its mandate under the 1977 amendments and the
Water Pollution Control Act established interim guidelines to determine
the acceptability of material for ocean disposal. An analysis of the
MDC's primary sludge (Table N-5, p. 96 of Part B, Vol. II) shows that it
exceeded the criteria for mercury and cadmium many times over. As a
result, during the early stages of alternative analysis in the EIS, the
Ocean Disposal Alternative was eliminated because of the sludge's
nonconformance wi.th the interim standard.
In April 1978, EPA replaced the interim standards with final
regulations. These require that material under consideration for ocean
disposal be subjected to biological testing to determine if it has or
will have toxic or long-term negative effects on marine biological
organisms. EPA has not performed such bioassays on the MDC's primary
sludge, nor are we requiring the MDC to do so.
In addition, first among those factors listed in Section 102(a)
of the MPRSA, upon which EPA has based its criteria for regulating ocean
dumping, is "The need for the proposed dumping." In its regulations, EPA
has stated explicitly that a need for ocean dumping will be regarded as
existing only when no practicable alternative to ocean dumping exists.
An alternative is regarded as practicable when it is available at reasonable
incremental cost and energy expenditures and when the overall environmental
impact of the use of the alternative is less than that for the use of
ocean dumping (40 CFR, Part 227, Subpart C).
Aside from the legal interpretations and ramifications of the
Marine Protection, Research and Sanctuaries Act, EPA has rendered policy
decisions with respect to the ocean disposal of sewage sludge. EPA's
policy is based not so much on significant evidence directly attributed to
actual harm at specific ocean disposal sites, but on the general concern
of the scientific community over the continued addition of heavy metals,
toxics and other pollutants to the ocean.
Former EPA Administrator Train, in previous decisions regarding
the granting of permits for ocean disposal of sludge, established the
framework for current EPA policy. In his decision on granting an interim
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ocean disposal permit to the City of Philadelphia, Train stated, "The
scientific evidence surrounding this particular permit application can
only be described as preliminary and, as indicated by the testimony at
the hearing, is certainly subject to. differing interpretations. To focus
solely on whether the data show that a particular organism at the dump
site has suffered adverse effects from the city1s dumping activities is-,
in my view, to take an unnecessarily narrow view, of the criteria established
by Section 102 of the Act... we must take a broader view of what causes
harm to that system."
Train went on to state in his decision that even assuming that no
harm could presently be attributed to the ocean disposal of sludge at
that point in time, it would be up to the applicant to show that continued
or subsequent ocean disposal would not contribute to a general deterioration
of the ocean or that such deterioration would not eventually cause adverse
effects.
It is the long-term potentially adverse effects of ocean disposal
which are currently unknown, and which continue to be of greatest concern
to EPA. As a result, EPA policy seeks to guard against these unknown
effects of ocean disposal which may only be realized in the long term.
It is EPA's belief that the heavy metals, organohalogens, oils and greases
contained in the MDC's primary sludge could undoubtedly "degrade or
endanger human health, welfare, amenities, or the. marine environment,
ecological systems or economic potentialities." As such, EPA believes
the MDC sludge would not qualify for acceptability for ocean disposal.
The regulatory controls placed on ocean dumping require that the permittee
or the party proposing to ocean dispose the sludge prove that the actions
will not be harmful before a permit will be issued and that no practicable
alternative exists. This shifting of the burden of proof from the
regulatory agency to the proposing party, insures that only in cases
where the evidence is overwhelmingly positive will permits be approved.
Thus, even if a sewage sludge could be treated so as to meet the
environmental impact criteria, its dumping in the ocean would be permitted
only when there was no practicable alternative. Because of the availability
of practicable alternatives to ocean dumping, it is the policy of EPA
that all dumping or other discharge of sewage sludge into the ocean shall
be stopped as soon as possible, and that no new disposal of sewage sludge
into the ocean will be permitted.
EPA feels that there has been no evidence to show that ocean
disposal of sludge would not harm the marine environment. There is,
however, substantial evidence which indicates that past ocean disposal
practices have shown severe impacts in other areas. In addition, the
MDC's sludges are known to contain heavy metals as well as substances
which can be toxic or can bioaccumulate to the detriment of the marine
environment. The unknown effects of sewage sludge, either ocean dumped
or spread through dispersion, presents risks to the ocean's waters and
biotic population which EPA, as an agency, seeks to avoid. As such, we
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would not be prepared to issue the necessary ocean dumping permits to
the MDC and consequently, we could not fund a construction project which
would not allow for compliance with Federal law.
d. Summary of Analysis
Because of the severely adverse marine/water quality impacts of
ocean dumping which are reflected by its basic illegality, this option was
eliminated from future consideration. However, as our knowledge of the
sea and its functioning and our ability to remove toxic materials from
sludg§ (pretreatment) improves, we may be able to look once more to the
marine environment as a method to dispose of our sewage sludge. The
abuses which caused anoxic conditions and the toxic uptake may eventually
be understood and dealt with. If so, Congress may then lift its ban on
ocean disposal. Such progress, however, is not in the foreseeable future
and so ocean disposal must be considered infeasible.
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3. Land Disposal
a. Explanation of Alternatives
(1) Dewatering of sludge at Deer Island followed by barge transport
of sludge (in trailers) to a dedicated terminal, with truck transport to
dispersed storage sites in the Connecticut River Valley and Bridgewater-
Westport, Massachusetts areas. During two months of the year, sludge
would be applied to privately owned, cropped farmland with application
site soil analysis for nitrogen species and heavy metals on an annual
basis. Application would occur two months per year (60 days) at two dry
tons per acre per application. Storage would be at dedicated sites,
with piles being covered to prevent contamination of runoff.
(2) Dewatering of sludge at Deer Island followed by barge transport
of sludge (in trailers) to a dedicated terminal. Half of the sludge
(high cadmium:zinc ratio) would be transported to a landfill located in
Plainville, Massachusetts. The sludge acceptable for land application
(50%) would be handled as in the alternative discussed above.
b. Impacts
Soils - potential adverse impacts which could result from the
land application alternatives include:
increase in heavy metal concentrations,
. increase in sodium and chloride ions, and
. increased plant uptake of metals upon cessation of lime
application.
Heavy metals (e.g., copper, zinc, nickel and cadmium) present in
the sludge could increase in concentration in the soil during land
application. This is a potentially severe, long-term impact that could
be controlled by employing the EPA guidelines which limit the amounts of
sludge that may be applied (see Appendix R, Part B, Vol. II). Further,
the application of lime (used as a conditioning chemical in dewatering)
to keep the soil pH near neutral, would result in less metals leaching
into the soil and being absorbed by plants.
Sodium and chloride ions would also increase in the soil during
land application. Sodium ions destroy the soil structure, resulting in
reduced permeability. The amount of sodium that may be applied to the
soil depends on the amount of calcium and magnesium that is available to
inactivate the sodium effects. The chemical models for soil (Appendix R)
discuss the sodium balance for the soils. Chloride would not be expected
to be a significant problem.
One major adverse effect would occur after sludge application
ends. A high pH results in less heavy metals being available for crop
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uptake. If liming of the soil ends with the sludge application, a natural
lowering of the soil pH may result in an increased availability of heavy
metals thus leading to metal toxicity of plants growing on these sites.
Beneficial Impacts - Operation of land application alternatives
could result in some beneficial impact on soils such as:
. lime application to raise native pH,
increased organic content, and
increased organic nitrogen levels.
The amount of lime applied with the sludge would be similar to
the amount applied on farms. Lime application with the sludge will result
in about 0.5 tons per acre of calcium oxide, which is equivalent to 0.9
tons per acre of calcium carbonate. Present agricultural practices put
1.6 tons per acre of calcium carbonate on the land (U.S. Department of
Commerce, 1972).
The organic content of the soil should increase due to land
application of sludge beneficially affecting the soil structure, the
cation exchange capacity, and the water-holding capacity of the soil.
This may be a major beneficial impact and since organic breakdown is
relatively slow, would be expected to have a long-term positive effect on
the soil. The organic nitrogen level would also increase and subsequently
be released during organic breakdown.
The combination of potential adverse and beneficial impacts of
land application on the soil would have a net adverse overall impact.
The benefits to the soil to be derived from the additional nutrients
added by applying limed sludge might be outweighed by the accompanying
increase in heavy metals concentrations if sludge rate application
guidelines are not strictly followed.
Surface and Groundwater Quality and Quantity - Implementation of
the land application alternatives could have potentially severe impacts
on groundwater and surface water quality. It is possible that underdraining
and leachate treatment for the 4,671 ha (11,550 ac) of disposal area may
be required. With an annual infiltration rate of 234 mm (10") this would
result in loss of 32,500 m3/day (8.6 mgd) from groundwater. Without
leachate recovery, the impacts on water quality would be adverse because
of possible excessive nitrogen loss to groundwater.
The beneficial impacts to surface water quality resulting from
the land application alternative would be the reduction of BOD, solids
and metals from the waters of Boston Harbor where the sludge load is
presently discharged.
Air Quality Impacts - Reduced air quality would result from the
increase in carbon monoxide (CO) emissions, which accompany the land
application alternatives. The CO emissions would result from the use of
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trucks to transport the sludge from Deer Island, and would be approximately
10 times that of the incineration alternative. The areas affected by the
increase in CO emissions will depend upon the routes used to transport
the sludge to its associated land disposal site.
Biotic Communities - An adverse, long-term impact that could vary
from minimal to severe is the heavy metal uptake by vegetation growing on
the landfill (a suggested land application alternative) upon conclusion
of filling operations. This impact would be dependent on plant type,
depth of cover soil and the type of cover soil.
Improved water quality in Boston Harbor due to cessation of the
present sludge disposal method would result in improved conditions for
shellfish.
Public Health and Noise - An increase in noise would result from
truck transport of sludge to the receptor site.
Economic Impacts - The land application alternative as developed
in the Draft EIS with 1975 costs, would increase the costs to the MDC by
23.4% per year and have an associated cost per household of %5.79 per
year.
Energy Impacts - The land application alternative as described in
the Draft EIS, would require direct energy inputs of 162x109 BTU per year
(mostly fossil fuels) and an indirect (chemical) energy input of 50x1O9
BTU per year. This energy use could be partially offset by a maximum
nutrient energy recovery of 51x1O9 BTU per year resulting in a total net
use of energy of 161x109 BTU per year.
Land Use Impacts - Land application would require the use of 40
acres of storage land and 11,500 acres of land for application. Although
positive impacts on agriculture would result from land application designed
and operated in accordance with the provisions of applicable state and
federal regulations, the loss of this area from agriculture in the event
of problems would constitute a severe negative impact. In addition, the
lack of land availability for land application poses a serious barrier
towards implementing the land disposal alternative.
Transportation - The extent and location of the transportation
impacts of land disposal depend heavily on the mode of transportation
from Deer Island to the major road network surrounding Boston. Both tht
MDC1s studies and the EIS conclude that trucking significant quantities
of sludge through the Town of Winthrop would create an unacceptably
severe adverse impact over a particularly sensitive area and therefore,
would require barged transportation of sludge to a landfill. .The truck
traffic in the communities surrounding those landfills has the potential
for adverse impacts but they are much more acceptable than those in
Winthrop would be.
Aesthetic Impacts - The land application of sludge would not
require the construction of additional permanent facilities other than
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those discussed under common elements on Deer or Nut Islands and therefore,
the adverse aesthetic impacts on those communities would be negligible.
The construction of the barge dock on Deer Island would not be very
noticeible and the unloading facilities would generally be located in an
industrialized area of the waterfront and would not conflict with the
aesthetic qualities of such an area. The operation of storage sites for
sludge and the ultimate disposal on land in a rural/agricultural area
would have some adverse aesthetic impact, but could be mitigated somewhat
by operational controls and siting.
c. Implementation Considerations
In analyzing the feasibility of land application, the relative
ease/difficulty of implementing such an alternative was taken into
consideration. Several problems were seen to exist in implementing the
land application alternatives suggested.
( 1) In order to effectively dispose of sludge by the land disposal
alternative suggested, land availability becomes an important factor.
The amount of land which would be required (over 11,000 acres) is presently
not available, nor is there any way of ensuring that the land needed
would be available. Without the required land needed for storage and
application this disposal alternative becomes infeasible as it would be
impossible to implement.
(2) Other implementation problems exist in terms of being able to
market the sludge as suggested in this alternative. Early in the EIS
process EPA contracted a study to explore the existing and potential
market for fertilizer produced from digested primary sludge from the Deer
and Nut Island Treatment Plants. In September 1975, Development Planning
and Research Associates, Inc. submitted their findings to the EPA in a
report entitled, "Market Survey and Feasibility of Sludge Fertilizers".
The conclusions of that report indicated that the market for an unfortified
dried primary sludge produced at Deer Island by the MDC would be extremely
limited. The proposed product would have a low nutrient content of
approximately 2% nitrogen, 2% phosphate and a trace of potash (designated
2-2-0). Such a product could not compete effectively as a fertilizer
because of its low nutrient content; and, its potential as a soil
conditioner would be limited geographically because of relatively high
shipping costs. In addition, the marketability study looked at a fortified
dried primary sludge fertilizer (6-2-4 level) and found that only one
half of the total volume of sludge generated could be sold even under the
most favorable market conditions. Further, this would require an effective
but costly marketing program for such a volume to be sold. As a result,
use of this mechanism for disposal and/or for revenue generation was not
considered feasible.
(3) The Resource Conservation and Recovery Act (RCRA) of 1976
(PL 94-580), initially was not clear as to whether or not sewage sludges
would be considered as potentially hazardous materials. Draft regulations
to implement proposed sections 1008 and 4004 published in the Federal
Register on February 6, 1978, and unpublished drafts of other sections
24
-------
contained information indicating that stringent restrictions would be
placed on the land application of municipal sludges or compost. RCRA
required the formulation of regulations defining hazardous wastes and the
management and ash disposal criteria for such wastes.
Unpublished draft regulations defining "hazardous" and "non
hazardous" indicated that one of the criteria used to define a waste as
hazardous would be toxicity. As a result, the heavy metals content
(cadmium, zinc, lead) of the MDC's sludges was initially considered to
conform to EPA's definition of hazardous waste, and therefore, the
sludges would not be available for the land disposal alternatives suggested
which involved application to food chain crops. Later studies have
indicated that application to lands where food crops are not involved,
could be implemented safely (see discussion below under "composting").
The Draft Hazardous Wastes Regulations (Federal Register
December 18, 1978) state that municipal sewage sludges will no longer be
considered subject to the hazardous waste provisions of RCRA. Sewage
sludge from publicly owned treatment works will be excluded from coverage
under RCRA and will be regulated instead under Section 405 of the Clean
Water Act of 1977.
Owners and operators of publicly owned treatment works are
required by Section 405(e) to use or dispose of sludge in accordance with
guidelines promulgated under Section 405(d). With respect to land disposal
and landspreading, the owner or operator must assure compliance with
these criteria. They must (1) analyze the sludge for cadmium and other
toxic substances, (2) assure that the sludge has been appropriately
stabilized, (3) determine the appropriate sludge application rates and
assure that they are complied with, (4) determine what monitoring is
required and assure that it is performed, and (5) develop any necessary
contingency plans and assure they are complied with.
i
(4) The effect of various state and local laws and ordiances
would also contribute to creating implementation difficulties for a land
disposal alternative. For example, the Massachusetts Department of
Environmental Quality Engineering (DEQE) recommended the sterilization of
sludge prior to land application (letter from Anderson to Ochs, August
28, 1975). This requirement was seen to adversely affect both the energy
requirements and cost effectiveness of land application of sludge. In
addition, DEQE has developed an "Interim Policy on Disposal Practices for
Sludge and Sludge Ash", January 24, 1979.
d. Summary of Analysis
While the concept of utilizing sludge (i.e., recycling as opposed
to disposal) has definite benefits, the analysis of impacts and implementation
considerations proved the land disposal alternative to be infeasible. As
a result, the land disposal alternatives (land application and landfilling
of sludge) were eliminated from consideration due to the uncertainty
25
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about sludge quality (heavy metals content) the amount of land which
would be required (and its availability), high economic costs, and energy
intensiveness•
e. Composting
The alternative of land application analyzed had been considered
infeasible and rejected due to marketability problems; energy and
cost intensiveness; heavy metals content; and because it did not appear to
be in compliance with federal legislation and policy (i.e., RCRA). Since
the time that RCRA initially designated sewage sludges as potentially
hazardous materials (primarily due to heavy metals content) studies were
performed whicn indicated that the levels of heavy metals found in most
municipal sludges are not such that they should be considered toxic, or
hazardous, nor are they seen as possibly endangering the public health.
Entry of heavy metals into the food chain can also be controlled by
limiting and regulating the uses of municipal sludge or compost in land
application operations. As a result, recent federal guidance (October,
1978) indicates that restrictions on heavy metals content would not
preclude the use of cadmium-rich municipal sludge or compost in landspreading
operations where food crops were not involved.
Even when land application is restricted to non food chain uses
potential benefits exists which make land application a viable and attractive
alternative. There are many acceptable uses, especially for a sludge
based compost, which make use of the nutrient resources in sludge and
thus could be implemented with positive beneficial results. Composted
sludge can be beneficially applied for use on state forests, sod farms
and Christmas tree farms. It can be used in horticultural applications
for growing potted plants in green houses and for shade and flowering
trees in nurseries. Use of compost and compost-containing materials as
soil amendments for landscaping and land reclamation purposes have also
proven highly successful. Compost can safely and beneficially be used
for public work projects such as highway beautification. In fact, the
number of non-agricultural uses for composted sludge is increasingly
large with the benefits derived from such operations indicating a positive
outlook for future compost usage.
In order to investigate the feasibility and practicality of
composting sludge from the MDC system, a demonstration pilot program of
composting the Boston area's sewage sludge and converting it into a soil
conditioner potentially useful for horticultural and landscaping
applications, was initiated. In August 1977, Energy Resources Co., Inc.
began a 1-year project for the MDC "... to design, construct and operate
a demonstration sludge composting facility at the Deer Island wastewater
treatment plant and investigate the potential demand for the compost
product within a 40-mile radius of Boston." The results of this operation
are contained in a report entitled "Sludge Composting Project, 1977-1978",
and have shown composting to be "a potentially feasible sludge management
alternative for the MDC, and that there is sufficient interest among
Boston area users - for utilization of the entire present sludge product
to warrant further market assessment. Composting should be continued on
26
-------
a modest, but steady, scale in order to gain experience with the process
and to develop site-specific, time-tested information." The composting
pilot program has demonstrated that there is sufficient local demand to
merit the initiation of a permanent continuous sludge composting facility
and that a market for composted sewage sludge, even in non-agricultural
uses, exists.
The option of composting the MDC's sewage sludge becomes an
attractive land disposal alternative. To transform a "waste" into a
useful product has great appeal, but there are still environmental and
economic/energy considerations which must be taken into account. Heavy
metals and materials resulting from industrial discharges are currently a
component of the MDC sludge. As such, steps must be taken (initiation of
an effective pre-treatment program) to ensure that the sludge can safely
and environmentally be recycled.
Further, we recognize that the utilization and marketing of a
sludge compost product has not yet fully been determined. Until an
active distribution effort is begun which has the support of both the
state and MDC, the potential for disposing of the MDC's sewage sludge
via composting can only be surmised. Further, the success of a composting
operation on any scale will require a commitment on both the part of the
MDC and the State. Because large scale composting would be an innovative
sludge management solution departing from conventional practice, it will
be necessary for the Commonwealth of Massachusetts and EPA to make firm
commitments for a thorough assessment of its potential, and for its
implementation if it is judged to be cost-effective and environmentally
sound.
Within this framework it,is seen that the land disposal alternative
of composting primary sludge is a viable option deserving further evaluation
for cost-effectiveness. The use of composting should be employed to the
extent practical.
27
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4. Incineration
The alternative of incineration analyzed is essentially the same
proposal recommended by the MDC in their Step 1 facilities plan. An
explanation and examination of the incinerator alternative is presented
at this time without the question of residue ash disposal. Feasibility
of incineration is not dependent upon selection at this time of an ultimate
method or disposal of incinerator ash residue, although such a site must
be selected before actual construction of the project begins.
a. Explanation of Alternative
(1) The basic alternative of incineration (as recommended by the
MDC), involves:
(a) At Deer Island, the primary sludge from the Deer and Nut
Island treatment plants would be chemically conditioned and dewatered,
either by vacuum filter or filter press.
(b) The total s'.udge mass would then be thermally reduced by
incineration with energy recovery, in two multiple hearth incinerators
with a variable speed fan for intake air. (The actual installation would
consist of three incinerators, with one for standby.) The design capacity
of the sludge incinerators would consist of 128 tons/day (TPD), dry weight
basis.
The incineration alternative includes waste heat recovery
from the incinerator exhaust gases, and the generation of electric power
from this energy source. The energy recovery facilities will include a
boiler and a 4000 kw generator. The temperature difference through the
boiler will be about 500°F. Existing dual fuel engine generators would
continue operation utilizing digester gas. Outside electric power supply
would be provided to supplement on-site generated power, and for stand-by
service for the"turbogenerator set.
Quenching and ash removal from the incinerator will be either
wet or dry, with dry quenching recommended to minimize the amount of
leachate to be recycled. Air pollution control will be by a high energy
venturi-type scrubber with a 42" H20 pressure drop through the scrubber.
(2) Coincineration - Early in the EIS preparation process the MDC
was provided a federal grant to study the alternative of coincineration
(i.e., incinerating the MDC's wastewater sludges with solid waste from
the City of Boston). The Draft EIS published in March 1976 did not
include the alternative of coincineration since the study on that
alternative had yet to be completed. The results of that study, conducted
by Stone and Webster, Inc. were presented in a report entitled "The
Commonwealth of Massachusetts Metropolitan District Commission, Boston
Metropolitan Area Waste Treatment Feasibility Study" in November 1976.
Coincineration was evaluated for two possible locations, South Bay and Deer
Island. Facilities at the South Bay site would consist of two boilers,
each having a capacity of 850 TPD, sludge drying equipment, electrostatic
28
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precipitator's, ferrous recovery and residue conveyors, and an underground
steam connection. The Deer Island site would incorporate the same basic
systems except that steam would be piped to two 20,000 kw turbogenerators
for power production instead of.being piped into the existing Boston
Edison direct heating system. The South Bay facility would require
delivery of solid waste to the site via packer truck and transportation
of dewatered sludge via truck and barge from the sewage treatment plants.
The Deer Island site would necessitate truck-barging of solid waste and
sludge from Nut Island to Deer Island.
In assessing the environmental impacts of a cotreatment system
located at either South Bay or Deer Island, air quality, noise, terrestrial
ecology, water quality and energy consumption were all taken into account.
The most adverse environmental effects of cotreatment were found to be in
connection with air quality.
The results of the study indicated that because of adverse
environmental impacts, specifically air quality, and because of the
associated costs and impacts of transport, coincineration was not feasible.
In addition, the alternative had several major implementation problems
which would need to be overcome before the option could be economically
feasible.
Subsequent to distribution and review of the Stone & Webster
report by EPA and various state agencies, consideration was given to two
further sites as possible coincineration facilities. The option of
coincinerating MDC's sludge with the-municipal refuse currently being
burned at the existing RESCO incinerator in Saugus was examined by EPA
and determined to be infeasible due to transportation problems and air
quality impact problems.
Consideration of the West Surburban Project (WSP) in Stoughton
as a coincineration site was also eliminated for many of the same reasons
the RESCO site was rejected. In addition, the possibility of codisposal
at WSP was eliminated by action of the WSP policy committee.
b. Impacts
Soil - Construction of the incinerator and storage facilities
could cause a slight erosion of soil. This would be a short-term adverse
impact, localized in the areas of construction and could also be mitigated
by erosion control procedures (e.g., mulching at 2 tons/ac) and careful
site selection. .
Incineration can also result in particulate fallout adding a
small amount of heavy metals to the soil. This would be a negligible
adverse impact, especially in comparison to the amount of heavy metals
which could be introduced to the soil through use of the land application
alternative.
29
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Incineration has the potential to create problems with S02
emissions decreasing the pH of rainfall ("acid rains") and, hence, soil
leaching.
Air Impacts - The proposed incinerator will produce certain
adverse air quality impacts. None of these impacts, however, are expected
to result in violations of Federal ambient air quality standards. This
conclusion covers all of the pollutants which can be expected to be
emitted from the sludge incinerator, and for which ambient standards have
been established. Emissions and projected ambient concentrations were
estimated for 1985, when the incinerator will be in full operation.
There arr presently violations of the National Ambient Air Quality
Standards (NAAQS) occuring in the Boston Metropolitan Area. The proposed
incinerator will, however, produce no new violations. Under EPA's
Interpretive Ruling Policy, a determination must be made as to whether
the proposed source would contribute to the existing violations. As
such, a determination was made as to the importance of the incinerator's
contribution to the ambient air quality. This importance is evaluated in
terms of numerical levels which have been established by EPA ("levels of
significance"). Modeling efforts indicated that the levels of significance
would not be exceeded for the locations monitored.
The Boston Edison Company has conducted an ambient air monitoring
program on Long Island for sulfur oxides and suspended particulate matter,
since April 1976. Information from this program, which was established
to support a Boston Edison request for a change in Massachusetts fuel
sulfur content requirements applicable to the company's generating
stations, has been transmitted to the Massachusetts Department of
Environmental Quality Engineering and to the Environmental Protection
Agency. Data from the monitors (located 4.23 km from the site of the
proposed incinerator) can be considered representative of the air quality
on Deer Island and at the points of maximum ground level air quality
impact expected to result from operation of the incinerator. Based upon
conclusions drawn from an air quality prediction model (EPA CRSTER Model),
using actual Logan Airport meteorological data for the five year period
January 1970 through December 1974, these maximum impacts are expected
not to exceed twenty-four hour average values of 12.5 micrograms/m3 for
suspended particulate matter and 36.8 micrograms/m3 for sulfur oxides.
The estimated maximum incinerator generated impacts, when added to the
1985 projections of Boston Edison's Long Island data indicate total
expected peak 24 hour ground level concentrations during a twelve month
period of 116.6 micrograms/m3 for suspended particulate matter and
156.8 micrograms/m3 for sulfur oxides. The second highest 24 hour
peaks are predicted to be 107.8 and 151.9 micrograms/m3 for particulate
matter and sulfur oxides, respectively. The closest 24 hour National
Ambient Air Quality Standards are the secondary suspended particulate
matter standard of 150 micrograms/m3 and the primary sulfur oxides
standards of 365 micrograms/m3; both standards are not to be exceeded
more than once per year. Because the Federal ambient standards do allow
for the concentration limits to be surpassed once in twelve months,
violations are not charged unless the second highest peak also exceeds
30
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the standards. In the particular case in question, concerning predicted
1985 air quality in the area to be impacted by the proposed incinerator,
neither the second highest nor maximum expected twenty-four concentrations
of suspended particulates and sulfur oxides will exceed the established
standards.
Since the expected particulate matter and sulfur oxides concentrations
for time periods related to other standards, such as those established
for annual exposures or the special three hour period specified for the
secondary sulfur oxides limit, in all cases fall far below the concentration
values of the standards, it can be safely assumed that no Federal ambient
air quality standavds will be violated for these two pollutants.
The same conclusion can be made with regard to the National
Ambient Air Quality standard for lead. This standard specifies that the
ambient concentration for lead, averaged over a three month period, shall
not exceed 1.5 micrograms/m3. At the present time, this standard is
violated in the Boston Air Quality Control Region but it is believed that
atmospheric lead concentrations will decline steadily as new vehicles
capable of burning only unleaded gasoline begin to dominate the automobile
population of the metropolitan area. By 1985, when the incinerator is
operational, it is expected that the highest three month average ambient
atmosphere lead concentration measured in the Boston Air Quality Control
Region will be well below the standard.
The peak three month lead concentration monitored to date was in
heavily trafficked Kenmore Square for the period January through March,
1978. This measured value was 6.6 micrograms/m3. It is expected that
the automobile population changeover to unleaded gasoline will reduce
this peak value to about 1.0 micrograms/m3 by 1985. Even with the
conservative and unlikely assumption that the monitored Kenmore Square
lead levels would be representative of ambient concentrations in the
areas impacted by emissions from the proposed incinerator, the quantity
of lead expected to be emitted from the incinerator will not produce
violations of the ambient standard. The peak three month ground level
impact directly related to the incinerator will be no more than 0.015
micrograms/m3.
It is not expected, either, that there will be violations in 1985
of the National Ambient Air Quality Standards for nitrogen oxides. The
annual average ambient standard is 100 micrograms/m3. The expected NOx
emissions of 4.81 micrograms/m3 added to the background level of 86.5
micrograms/m3 result in a total ground level concentration of 91.3
micrograms/m3 which is less than the annual ambient standard. There are
currently no short-term standards established for NOx, but EPA is
considering promulgating such a standard in the future. If during design
or construction of the incinerator a short-term NOx standard is established,
the incinerator will be analyzed for compatibility.
Aside from the National Ambient Air Quality Standard pollutants,
it is generally considered that the most important emissions from the
incinerator will concern mercury and cadmium. It is expected that daily
31
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mercury emissions will approximate 1650 grams, and that the emissions of
cadmium each day will total 23 grams. The expected mercury emission rate
will be well within the allowed EPA emission standard for 3200 grams per
day. Because the predicted emission rate will exceed 1600 grams daily,
however, the Metropolitan District Commission will be required to sample
and report its actual mercury emissions at least once each year.
There is no established emission limit on cadmium emissions
comparable to that for mercury. The expected one hour maximum concentration
of 0.012 micrograms/m3 that could result from incinerator emissions of
cadmium, however, does not appear to constitute a substantial danger to
human health or welfare. Atmospheric cadmium has not been sampled
routinely in the idoston metropolitan area, but samples taken elsewhere
support an assumption that background concentrations should not be greater
than 6 nanograms/m^ (.006 micrograms/m^). The sum total of assumed
maximum background levels, and maximum ambient concentrations resulting
from the proposed incinerator is below concentration values heretofore
associated with harm to human beings 100-200 nanograms/m^ (0.1-0.2
micrograms/m^).
Because the proposed incinerator location on Deer Island will be
in an area where particulate matter and sulfur oxides standards are now
being achieved (attainment area), it is necessary to determine that the
existing air quality will not deteriorate significantly due to incinerator
operation. This determination was made, and was based upon evaluating
the impact of the proposed incinerator against the Environmental Protection
Agency's Prevention of Significant Deterioration (PSD) criteria. The
evaluation indicated that none of the PSD criteria would be violated.
Marine Sediments and Water Quality - Incineration could effect
surface water quality. Particulate fallout could result in a slight
increase in heavy metal concentrations in the water (especially lead and
mercury) resulting in a minimal adverse impact. Aquatic biota are more
sensitive to heavy metal concentrations than terrestrial biota, but the
small amount of surface freshwater in the East Boston-Winthrop area which
is available for.contamination, would result in a negligible impact. A
beneficial impact could result due to the increase in pH from the
particulate fallout. This pH increase could moderate to some extent a pH
reduction due to sulfur dioxide emissions of the incinerator.
The greatest beneficial impact to be derived from implementing
the incineration alternative will be the removal of a significant increment
of pollution to Boston Harbor resulting from the complete elimination of
the sludge discharge to the Harbor. The sediments of the Harbor could be
improved to the point where the diverse, desirable marine life which the
Harbor is theoretically capable of supporting may become reestablished.
Biotic Communities - Plant life could potentially be affected by
emissions. Sulfur dioxide, released from the incinerator in gaseous form,
combines with moisture to form a dilute sulfuric acid which is harmful to
plant life. This could result in a moderate adverse impact. Particulate
32
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1985 GROUND LEVEL CONCENTRATIONS (GLC). OF AIR POLLUTANTS
(Ug/D3)
189
SO.
NO_
Pb
Cd
NOTES
ANNUAL
3 MONTH
24 BOOR
(Highest!
24 BOOR
(Second
Highest)
3 BOOR
1 BOOR
1.01 + J3.0 • 36.0
•• ™(J)
b. 6?"
2.71 *
• • N/A
b. N/A
11. 3 + 104.1 " 116.6
a. N/A
b. N/A
12.3 «• 93.3 - 107.8
•. 260
b. ISO
39.1 4-
m. H/A
b. N/A
79.9 +
ft. N/A
b. N/A
2.98 + 27.0 • 29.98
£' «n(2)
b. 60
8.00 *
a. N/A
b. N/
36.9 * 120.0 - 136.9
a. N/A
b/ N/A
36.9 * US - 131.9
S: ;260<"
117.4 «•
a. N/A
b. 1300
233.7 + ^
a. N/A
b. N/A
13)
4.81 + 86.5 - 91.
a. 100 ug/mP>
b. N/A
12.89 +
a. N/A
bV N/A
39.2 +
a. N/A
b. N/A ,
39.2 *
a. N/A
b. N/A
189.4 +
a. N/A
b. N/A
380.3 *
a. H/A8)
b. N/A
0.006 +•
a. N/A
b. N/A
0.01S 4- 1.0(5- 1.015
a. l.S ug/m3
b. N/A
0.06 +
a. N/A
b. N/A
0.06 +
a. N/A
. b. N/A
0.18 *
a. N/A
b. N/A
0.36 >
a. N/A
b. N/A
.0002 * ,006(6J .0062
a. N/A
b. N/A
.0004 4- •
a. N/A
b. N/A
0.002 •*>
a. N/A
b. N/A
0.002 4-
a. N/A
b. N/A
0.666 4
a. N/A
b. N/A
0.012 >
a. N/A
b. N/A
KEY
A * B - C
A • Incinerator
Contribution
B - Calculated
Background
C - Total GLC11'
a • Primary Air
Pollutant
Standard
b - Secondary Air
Pollutant
Standard
NOTES (1) All background concentration* based on
monitored air quality at Long Island except
as otherwise noted.
(2]_,This standard is only to be used as
•a guide.
(3) NO background concentration based on
monitored air quality at Bast Boston.
(4) A short tern NO* standard is under
consideration .
(5) Pfa background concentrations all based
on measured concentrations at Kenmore Square
reduced for-expected improvements related to
change in automobile population.
(6) The background concentration for Cd
is an estimated value based on concentrations
normally found in urban areas.
-------
fallout on plants may also have a moderate adverse impact. Particulate
dust could cause a screening of sunlight, resulting in a slightly lower
photosynthetic rate.
Public Health and Noise
Noise - Noise generating activities associated with implementing
the incineration alternative relate mainly to construction activities and
vehicles used to transport workers to the construction site.
Occupational noise levels would range from 82-97 dBA at 25 feet
(USEPA 1972), which would limit workers to three hours per day of direct
exposure (Hovey, 1972).
Health Impacts - Certain air quality impacts resulting from
incineration could result in respiratory interference for certain sensitive
persons. However, as none of the Federal Primary or Secondary Ambient
Air Standards will be violated, the proposed incineration can be considered
"safe" with respect to the public's health and welfare. Federal standards
are established to ensure sufficient quality of air for the general
population.
The use of pollution control equipment on vehicles can reduce
noise and air pollution.
Beneficial Impacts - Discontinuation of harbor disposal of sludge
would result in improved beach conditions which would be beneficial for
public health as well as recreational enjoyment.
Land Use Impacts - Expansion of facilities and construction of
incinerators on Deer Island will result in the loss of land available for
other uses of the Island. However, the improved condition of the harbor's
waters could result in the other Harbor Islands being used more beneficially.
Historical and Archaeological Sites - In 1941, Fort Dawes was
established at the tip of Deer Island. The Army Fort covered an area of
approximately 100 acres and was separated from the rest of the Island by
a 12 foot high concrete wall. The top of the hill served as the Harbor
Entrance Control Post during the Second World War. According to the 1972
Boston Harbor Islands comprehensive plan, the Fort was placed on caretaker
status in 1946. The Plan further describes the Fort as abandoned and as
fallen into disrepair. Currently, the Fort is not listed in the National
Register of Historic Places. Further, the Massachusetts Historical
Commission has stated that there are no immediate plans to nominate it to
the National Register, however, it is included in their inventory of
historical assets of the Commonwealth. Under Section 106 of the National
Historic Preservation Act of 1966, a determination is to be made as to
whether or not a site is eligible for listing on the Historical Register;
such a determination has not been made in the case of Fort Dawes. Prior
to design of the incinerator begins or expansion of facilities on Deer
Island occurs, an evaluation of the historical and archaeological assets
34
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of Fort Dawes will be required. This will be accomplished by the MDC
conducting an archaeological/historical survey of the area during its
updating of facilities planning. Upon completion of the survey, the MDC
will consult with the State Historical Commission to ensure compliance
with the National Historic Preservation Act.
Aesthetic Impacts - The impacts of construction and operation of
the expanded facilities would be negligible or minimal concerning noise,
appearance, and odor. The existing treatment plant on Deer Island already
produces odor, noise and visual impacts. While the plant is somewhat
isolated from the main residential areas of Winthrop, there will be
increases in the existing adverse effects upon the inmates of the Suffolk
County Prison. Th-i addition of increased noise and odor will probably be
in the range of :ninimal to moderate. An additional adverse impact will
result from the construction of the three incinerator stacks which could
be considered aestheticly displeasing. The major beneficial impact will
be the improvement in the aesthetics of Boston Harbor due to the removal
of the sludge discharge. Recreational uses of the harbor (bathing,
fishing, boating) may also be realized.
Energy Impacts - Recovery from Incinerator Off-Gas: In their
study recommending incineration to the MDC, Havens & Emerson, Ltd.,
included energy recovery from the hot off-gases of incineration. In the
system envisioned by Havens & Emerson, the efficiency was predicted at
38%, based on the fact that the loss of efficiency (about 15%) in fuel
burning normally used in power boiler computations need not be included.
The best efficiency of a complete system in the power industry is
approximately 38% which, with the 85% fuel efficiency, yields a boiler
efficiency of 45% in comparison to the 38% predicted by Haven & Emerson.
Autogenous Operation (Operation without Auxiliary Fuel):
Appendix S (Part B, Volume II) contains information on the state of the
art of multiple hearth incinerators, and addresses the question of operation
of the incinerators without fossil fuel imputs. In the incineration
system as proposed by the MDC, autogenous operation is theoretically
possible. The principal reason that additional fossil fuels are required
for incinerators (based on analysis of records, from existing plants) is
the inability of most facilities to control the amount of excess air
that is required for combustion. In existing plants, the combustion air
feed is fixed, usually at 150% of the volume required. As Appendix S
points out, the effect of this fixed quantity of air is that when the
incinerator is running at 50% of capacity, the air supply is 300% of
that required, or 200% excess air. Because the thermal energy required
to heat the incoming air is about 300 BTU/pound of air, this exerts a
powerful impact on fuel requirements.
For every 1% reduction in thermal efficiency below that calculated
for autogeny in 1985, the daily fuel requirement would be approximately
100 gallons per day (@143,000 BTU per gallon). Because the question of
energy input is so important, the MDC's consultant has developed an
incineration system in which the combustion air input is variable, depending
on the oxygen requirement and the percentage of incinerator capacity
used. Appendix S recommends several additional measures that could be
35
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taken by the MDC to further insure autogenous operation. In addition to
auxiliary fuel use, start-up fuel will be required. Each start-up will
require 4000 gallons of fuel (H&E, 1973), and based on existing plant
data (Appendix S), the start-up, frequency will be one start every 10
days. On this basis, the average daily auxiliary fuel requirement will
be 400 gallons.
Although the incineration alternative will require energy use
for operation which must be drawn from existing fossil fuel sources, this
use of fossil fuel can be offset by the inclusion of energy recovery.
The inclusion of energy recovery will produce more total energy than will
be consumed by the sludge management operation. The recovery of thermal
energy in excels of that required for start operations results in a total
net recovery of 52-54 x 109 BTU per year which is equivalent to 370,000
gallons of diesel fuel that will be saved annually by converting radial
diesel pump engines to electric motors. The use of fossil fuels for
start up pilot and auxiliary fuel can also be mitigated by partial use of
digester gas.
In contrast, the land application alternative required direct
energy inputs of 162x10^ BTU per year (fossil fuels), and an indirect
(chemical) energy input of 50x10^ BTU per year. Although this energy use
could be partially offset by nutrient energy recovery, land application
would result in a total net energy use of 161x10^ BTU per year.
Economic Impacts - Implementation of the incineration alternative
will result in increased costs to the MDC and the member communities
households which range from $3.41 - $4.16 increased cost per household,
based on annual costs after grants; depending upon the ultimate method
and location of ash disposal.
The beneficial economic impact of the incineration alternative
results from the generation of construction jobs with federal grant funds.
The 360 man years of effort required translates into about 120 jobs over
a three year period.
c. Implementation Considerations
There are several pieces of federal and state legislation which
would have an effect upon the implementation and feasibility of the
incineration alternative and which must be taken into consideration in
the analysis of that alternative.
(1) On January 16, 1979, EPA published in the Federal Register
a series of regulations which are referred to as the "Interpretive Ruling."
Specifically, the Interpretive Ruling governs the analysis of new sources
of air pollutants, and whether or not such new sources need to be
compensated for by concomitant reductions within the same air shed. This
policy covers all major sources locating in a non-attainment area, or
significantly impacting a non-attainment area. A major sewage sludge
incinerator under this policy is defined as having potential emissions
greater than 100 tons per year. Any source subject to this policy can
36
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not be built unless several stringent conditions are met. One such
condition is the greater than "one-for-one" emissions offsets that must
be found by the proposed source.
(2) Amendments to the Clean Air Act were passed (as PL 95-95) in
August 1977. Among other provisions, the 1977 Clean Air Act Amendments
contains requirements on the Prevention of Significant Deterioration
(PSD), air quality maintenance, that determinations of Best Available
Control Technology must be performed on a case-by-case basis. On June
19, 1978, EPA promulgated the Prevention of Significant Air Quality
Deterioration (PSD) regulations. The PSD regulations cover all pollutants
regulated by the Clean Air Act, however, increments limiting pollutant
concentrations have been set for particulate matter and sulfur dioxide.
All sewage sludge incinerators locating in an attainment area or significantly
impacting an attainment area, and having the potential to emit more than
250 tons per year of any pollutant regulated under the Act, must receive
a PSD permit for that pollutant.
(3) The Resource Conservation and Recovery Act of 1976 (PL 94580,
RCRA) required formulation of regulations defining hazardous wastes and
the management and disposal criteria for such wastes. Draft regulations
were published (February 6, 1978) detailing ultimate disposal of hazardous
wastes and the environmental constraints on disposal facility siting.
Regulations defining hazardous and non-hazardous wastes are still in
preparation. Initially sewage sludges were designated as potentially
hazardous materials. If the MDC sludges were considered hazardous as
defined by RCRA, their processing, transportation and disposal would be
controlled by federal regulation under that act. If non-hazardous, the
sludge's management would be controlled by state regulations of the
Commonwealth of Massachusetts. A designation of "hazardous" would mean
that the incineration facility would have to meet the performance criteria
for hazardous waste facilities (see Table III-2, Part B, Volume I).
After incineration or other processing, the residue would have to undergo
additional testing to see if it would be subject to RCRA.
Recent federal guidance (December 1978) indicates that
municipal sewage sludges will no longer be considered subject to the
hazardous waste provisions of RCRA. They will, however, be subject to
guidelines being developed by the EPA in accordance with Section 405d of
the Clean Water Act. Thus the federal treatment requirements for the
incinerator ash residue remain incompletely defined.
d. Summary of Analysis
The analysis of incineration took into consideration the
alternative's use of resources and energy, its economic cost, and the
social and environmental impacts of implementing such an alternative. As
a result of the analysis performed, and in comparison to the other
alternatives studied, it was determined that incineration represents the
most feasible and least environmentally adverse option for disposing of
the MDC's primary sewage sludge; and thus alleviating the continuing
water quality problem created by present sludge disposal practices.
37
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Although some air quality problems are associated with the alternative of
incineration, neither state nor federal air quality standards would be
violated. Further, the analyses indicated that the incinerators in and
of themselves would not result in an' environmental tradeoff, i.e., improved
water quality for degraded air quality. The use of a high energy scrubber
system would mitigate to a great extent the emissions of the incinerator.
*
Finally, incineration was found to be the only alternative which
could provide the continuous capability to dispose of the primary sludge
and thus ensure cessation of discharge to Boston Harbor. The construction
of incinerators would also not preclude the use of other sludge disposal
options which make use of resource reuse, (i.e., composting) as could be
effectively implemented.
38
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B. Summary of Level I Analysis
The preceeding alternatives analysis resulted in the selection of
incineration with energy recovery as the only option which could provide
for the continuous disposal of primary sludge while also being the most
environmentally sound method.
The No Action alternative is illegal and, therefore, cannot be
implemented. Aside from the legal constraints the alternative of no
action was also found to have serious environmental impacts as a result
of the continuous sludge discharge to Boston Harbor. The ocean disposal
alternative is also prohibited by federal law and, therefore, its
implementation would be illegal. Analysis of this alternative showed
that severe environmental impacts to the marine environment would be
incurred even if implementation were feasible. As a result, both the No
Action and Ocean Disposal alternatives were eliminated from consideration.
Several land disposal alternatives were analyzed and while the concept
of reuse rather than destruction is worthwhile, all the land disposal
options analyzed had several major problems associated with them. The
cost of land application was so high that -it was judged not to be
cost-effective in comparison with alternate sludge disposal methods.
Aside from costs, there are several adverse impacts associated with the
alternatives. Adverse air impacts (CO emissions) are associated with
land application. In addition, its metals content could preclude the use
of sludge, or of a compost made from the sludge, on food chain crops. It
should be noted that sludge, even with a measurable metals content, could
be used safely for land application subject to sludge application rate
constraints specifically designed to protect soil, plants, ground and
surface waters, and human health. Implementation problems also exist
with the land disposal alternatives because the land requirements would
be impossible to meet. Lack of land availability makes the alternative
impossible to implement. Finally, the option of producing compost for
non-food chain uses was evaluated. While this alternative, if currently
implemented, would be insufficient to handle the entire sludge load,
composting could be employed in conjunction with another alternative.
A continuous program of composting would not only make use of the sludge
as a resource, but would provide for a flexible solution to the sludge
management problem.
Incineration was analyzed and evaluated. Incineration would not make
use of the nutrient resources in the sludge, however, the inclusion of an
energy recovery system would allow for resource recovery in the form of
heat. Although incineration would also have certain air impacts associated
with it, it was the only alternative analyzed which could dispose of the
entire primary sludge load thus avoiding the adverse environmental impacts
of continuing the discharge of sludge to the Harbor. Incineration was
found to be the least environmentally adverse alternative and thus the
Level 1 analysis selected incineration as the recommended alternative.
39
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C. Alternatives Analysis - Level 2
The Level 1 analysis of alternatives resulted in the selection of
incineration with energy recovery as the method of choice for the disposal
of the MDC's primary sludge. As was previously stated, the ultimate
method and location of the incinerator ash residue was not considered in
the Level 1 analysis since the feasibility and selection of incineration
was not regarded as dependent upon ultimate ash disposal.
The question of ash disposal was addressed in the second level of
analysis where the basic alternative of incineration was refined, based
upon the methods and locations for ultimate ash disposal. Taken into
consideration during this level of analysis were the implications of the
Resource Conservation and Recovery Act (PL 94-580, RCRA) previously
discussed. The question then existed as to whether RCRA would classify
sewage sludges and ash resulting from incineration as potentially
"hazardous" materials. As a result, alternatives were created which
would allow for the handling of the MDC ash as either a "hazardous" or
"non-hazardous" material. Those alternatives considered were:
1. Explanation of Alternatives*
Alternative 1
Dry ash to be transported to a terminal by barge, thence to
an inland commercial landfill site by highway.
Alternative 2
Ash disposal to be on site in an enclosed, sealed fill area
(cofferdam) on the east (ocean) side of Deer Island. This alternative
assumed ash to be a non-hazardous waste.
Alternative 8
Dry ash would be transported via truck to a landfill in the
Fort Dawes area of Deer Island. This alternative assumes the ash to be a
non-hazardous waste.
Alternative 9
Assuming the ash to be a non-hazardous waste, it would be
transported via barge from Deer to Spectacle Island for disposal as fill.
Trucks or front-end loaders would carry the ash from the barges to the
actual disposal site.
Alternative 10
Alternative 10 has the same operational scheme as Alternative
2. It differs in that this alternative deals with the ash as a hazardous
40
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waste. The cofferdam would be located on the west (harbor) side of Deer
Island to facilitate recycling of leachate for treatment of hazardous
ash.
Alternative 11
Alternative 11 has the same operational scheme as Alternative
8. It differs in that this alternative deals with ash as a hazardous
waste requiring determination of impact on aquifers or lining of fill
site. Dry ash disposal would be via truck to a landfill in the Fort
Dawes area of Deer Island.
*Note: For consistency, the numbers used in describing alternatives, are
the same ones used in Part B, Volumes I and II of this EIS. Alternative
numbers 3, 4, 5, 6 and 7 refer to the options of ocean disposal, land
application and no-action previously eliminated.
2. Impacts
Environmental Impacts - The environmental impacts of the
aforementioned feasible alternatives were evaluated on a comparative
basis. In the analysis performed (summarized in Tables A-1 - A-4, a
tabulation of common and differentiating impacts of these alternatives
was prepared, with the following descriptive categories being used:
Area of Impact: area of concern to be impacted or affected,
including: Soils, Marine Sediments and Water Quality, Surface and
Groundwater Quality and Quantity, Air Quality, Biotic Communities, Public
Health and Noise, Economic Impacts, Energy Impacts, Land Use Impacts,
Transportation Impacts, Historical and Archeological Impacts, and Aesthetic
Impacts.
. Action: Short description of the action causing the impact.
. Type of Impact: Short term construction impacts or long term
operational impacts.
Assessment of Impact: Adverse, potentially adverse, or beneficial.
Areal Extent: Either localized within a few kilometers of the
site, regional pertaining to the surrounding counties, or national.
While all impacts theoretically have universal implications, the
detectability of impacts is the basis of areal extent.
Process and Disposal Inputs - Monetary Costs - Inputs of labor,
energy, materials, land, and monetary costs for construction and operation
of the incineration alternatives are given in Part B, Volume I (Sections
III and IV) and Volume II (Appendix T). Summaries of the required input
are shown in Tables A-5 and A-6. In addition to labor, energy inputs,
materials and land, Table A-5 also includes the energy recovered from
digester gas.
41
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TA9LE A-
Area of Impact
Soils
DIFFERENTIATIHG IMPACTS OF ALTERNATIVE 1
(Inland Fill)
Action
Increase in heavy metals
concentration of landfill
cover soil
Assessment
Type of Impact of Impact Aroal Extent
Potential Potentially Landfill site
long term Adverse
Landfill operation, resulting Potential
in erosion and soil structure long tern
destruction
Potentially Landfill site
Adverse
Marine sediments
and water quality
Dredging and construction for
bargind
Short tern
Potentially Localized, near channel
Adverse
Surface and Ground- Malfunction of leachate con- Potential
water quality and trol at landfill short term
quantity
.Potentially Local, near fill site
Adverse
Air quality Emissions due to as trans-
portation (fuel usage °
.10,690 gal/yr)
Long term
Biotic Communities Heavy metal uptake by vegetation Potential
growing upon final landfill cover Long term
Loss of vegetation at landfill
site
Short term
Adverse Localized, along truck
routes
Potentially Landfill site
Adverse
Adverse
Landfill site
Public Health and
Noise
Energy
Land Use
Transportation
Historical and
Archaeological
Noise and Emission fron ash Long term
transportation.
Malfunction of leachate con- Potential
trol and contamination of Long term or
useoble aquifer or surface Short term
waters.
Use of Fossil Fuels Long tern
(158,520 gal/yr)
Ose of additional landfill Long term
area causing displacement of the
other uses
Truck transport (10 trips/day) Long term
much of which is through resi-
dential neighborhood)
Use of landfill sites (No known Potentially •
historical and archaeological Adverse
resources nearby)
Adverse Sensitive reception near
truck routes
Potentially Localized near landfill
Adverse site
Adverse Regional
Adverse Local
Adverse Along truck routes
Potentially Regional
Adverse
42
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TABLE
A-2
Area of Impact
Marine sediments
•and water quality
Surface and ground-
water quality and
quantity
Air Quality
DIFFERENTIATING IMPACTS OF ALTERNATIVES 2 AND 10
(Cofferdam Fill)
Action
Construction of cofferdam re-
sulting in a habitat loss of
2.8 ha (7 ac)
•Rupture of cofferdam (prin-
cipanny for hazardous waste)
Emissions due to ash trans-
portation
Assessment
Type of Impact of Inpact
Long term
Adverse
Areal Extent
Localized, near Deer
Island
Potential short Potentially Localized, near Deer
term' long term Adverse for Island
for hazardous hazardous
waste . waste
Long term
Potentially
Adverse
Localized, near Deer
Island
Biotic Communities Construction of cofferdam
causing habitat loss.
Rupture of cofferdam
Long term
Adverse
Localized, near Deer
Island
Potential long. Potentially Localized, near Deer
term or short Adverse Island
term
Public Health
Noise
•Rupture of cofferdam
Potential long Potentially Localized, near Deer
term or short Adverse Island
term
Energy
Noise generation during
cofferdam construction (pile
driver)
Noise emissions from ash
transport
Use of fossil fuels
(147,900 gal/yr)
Short term Potentially Localized, near Deer
Adverse Island
Long term
Primary long
term
Potentially Deer Island
Adverse
Adverse
Regional
Land Use
Cofferdam site usage causing
displacement of other uses.
Primary long Adverse
term
Local
Aesthetic
Cofferdam construction
Short term. Adverse
Long tern
Localized, near Deer
Island
43
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DIFFERENTIATING IMPACTS OF ALTERNATIVES 8 AND 11
(Fill on Deer Island)
Area of Impact
Soils
Action
Increase in heavy metals
concentration of landfill
cover soil
Landfill operation resulting
in erosion and soil structure
destruction
Type of Impact
Potential
Long term
Potential
Long term
Potentially
Adverse
Potentially
Adverse
Areal Extent
Landfill site
Landfill site
Surface.and ground- Malfunction of leachate con- Potential
water quality an< 'trol at landfill short term or
quantity long term
Potentially
Adverse
Local near fill site
Air Quality
Emission due to ash trans-
portation (Fuel usage 320 gal/yr)
Long term
Potentially Localized, near Deer
Adverse Island
Blotic Communities Heavy metal uptake by vegetation Potential1
growing upon final landfill cover Long term
Loss of vegatntion at landfill
site
Short term
Potentially Landfill site
Adverse
Potentially Landfill site
Adverse
Public Health and
Noise
Energy
Noise and emission from ash
transportation
Malfunction of leachate
control at landfill
Use of fossil fuels
(Fuel usage • 147,900 gal/yr)
Long term
Potential *
short term or
long term
Long term
Potentially Deer Island
Adverse
Potentially Localized, near Deer
Adverse Island
Adverse
Regional
Land Use
Use of landfill area causing
displacement of landuse (Pro-
bable fill site is within Fort
Daves
Long tern
'Adverse
Local
Historical and Ume of Fort Davses area as land- Potential
Archeological fill *lte (possible historical Adverse
resources)
Potentially Regional
Adverse
Aesthetic
Use of Fort Denes as a land-
fill
Long tent
Adverse
Local
44
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TABU
A-4
Area of Impact
Marine sediments
and water quality
DIFFERENTIATING IMPACTS OP ALTERNATIVE 9
(Fill on Spectacle Island)
Assessment
Action Type of Impact of Impact
Dredging and construction
for barging
Short term
Adverse
Areal Extent
localized, near channel
Surface and ground- Malfunction of leachate
water quality and control at landfill
quantity
Potential short Potentially
term or long Adverse
term
Localized) near Spectacle
Island
Air Quality
Emissions due to ash
transportation (Fuel
usage - 1,065 gal/yr)
Long term
Potentially
Adverse.
. Localized, near Spectacle
Island
Biotic Communities
Public Health and
Noise
Heavy metal uptake by
vegetation growing upon
final landfill cover
Loss of vegetation at
fill site
Noise and emissions from ash
transporation
Malfunction of leachate con-
trol at landfill
Potential
long term
Short tern
Long term
Potential
long term or
short term
Potentially Spectacle Island
Adverse
Potentially Spectacle Island
Adverse
Potentially Localized, near Spectacle
Adverse Island ' •
Potentially Localized, near Spectacle
Adverse Island
Energy
Use of fossil fuels
Fuel usage • 148,865 gal/yr
Long tern
Adverse
Regional
Land Use
Landfill site usage causing
displacement of other land uses
Long term
Adverse
Local.
Historical and
Archeological
Sites.
Use of. landfill site (Pre-
historic sites are known to
exist on Spectacle Island
Potential Potentially Regional
Long term ' Adverse
45
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TABLE
A-5
ON-SITE ANNUAL ENERGY USE
Electrical
Fuel
Chemical
Total
ON-SITE ANNUAL ENERGY PRODUCTION
Electrical
Fuel
Total
NET ON-SITE ENERGY PRODUCTION
NET ON-SITE' ELECTRICAL
ENERGY PRODUCTION
TRANSPORT £ DISPOSAL ENERGY USE
NET ENERGY PRODUCTION
Total
Equivalent Fuel Production
(Gallons of #2 Diesel Fuel/Yr.)
INPUT
_1
57.6 x
21.1 x
50 x
126.7 x
161 x
650 x
811 x
662 x
103 x
1.53 x
RESOURCE USE AND
109
109
109
109
109
109
109
109
109
109
_2
57.6 x
21.1 x
50 x
126.7 x
161 x
650 x
811 x
682 x
103 x
9.3 x
109
109
109
109
109
109
109
109
109
106
PRODUCTION '
ALT
_8
57.6 x
21.1 x
51) x
128.7 x
161 x
650 x
811 x
682 x
103 x
4.58 x
E R
109
109
109
109
109
109
109
109
109
107
NATIVE
_9
57.6 x
21.1 x
50 x
128.7 x
161 x
650 x
811 x
682 x
103 x
1.52 x
109
10*
109
109
109
109
109
109
109
108
57.
21.
50
128.
161
650
811
682
103
9.3
10
6 x 109
1 x 109
x 109
7 x 109
x 109
x 109
x 109
x 109
x 109
x 106
57.6
21.1
50
128.7
161
650
611
682
103
4.58
11
x 109
x 10?
x 109
x 109
x 109
x 109
x 109
x 109
x 109
x 107
680 x 109 662 x 109 682 x 109 662 x 109 682 x 109 682 x 109
4.76 x 106 4.77 x 106 4.77 x 106 4.77 x 106 4.77 x 106 4.77 x 106
All units in BTU/year except where'noted
46
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TABLE A'-6
COSTS OF ALTERNATIVES (197B DOLLARS)
ALTERNATIVE
Capital Costs
Without Grant
With Grant
Annual Capital Costs
without Grant
With Grant
Annual Operating Costs
Credit for Electrical Energy
Total Annual Costs
Without Grant
With Grant
1
$31,099,100
7,774;775
2,885,900
748,005
2,653,655
441,000 .
5,098,555
2,960,660
2
$34,802,100
8,700,525
3.196,500
800,930 .
2.213,020
441,000
4,968,520
2,572,950
8
$30,591,100
7,647,775
2,810,500
704,435
2,213,090
441,000
4,582,590
2,476,525
9
$31,163,100
7,790,775
2,832,850
720,975
2,256,975
441,000
4,648,825
2,536,950
10
$34,824.100
8,706,025
3,198,500
801,460
2,212,995
441,000
4,970,495
2,573,455
11
$30,591,100
7,647,775
2, 610,500
704,435
2,213,090
441,000
4,582,590
2,476,525
47
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3. Implementation Considerations
Each of the alternatives describing the methods and locations for
ultimate ash disposal has problems associated with implementation.
The major barriers to implementation of each alternative are:
Alternative 1: Transportation of ash to the fill site (Plainville)
would be under various constraints and could pose implementation problems.
In addition, Alternative 1 requires access to roll-on, roll-off facilities
not now available. The lack of such facilities means that this alternative
would not be cost-effective. Finally, although this alternative is based
on use of an existing fill site, the possibility that the ash will be
considered hazardous cannot be ignored. The Plainville site is not approved
for hazardous wastes..
. Alternatives 2 and 10: The principal implementation barrier to
Alternative 2 is the use of coastal area for fill. The City of Boston's
Conservation Commission has authority over shoreline changes. Based on
EPA's guidelines and criteria for implementing Section 404 of the FWPCA,
the Corp of Engineers may not be able to grant the required permits for
ocean fill of ash.
. Alternative 8 and 11: Use of the Fort Dawes area for fill of
ash, either hazardous or non-hazardous, is complicated by the Boston
Harbor Islands Master Plan, which includes use of Fort Dawes as a
recreational site. Approval for change would be necessary.
. Alternative 9: In the case of hazardous ash, the leachate
from the ash fill must be treated for metals removal (in Appendix T, Part
B, Volume III, treatment costs were included for this) and an NPDES permit
would be necessary for discharge. The Spectacle Island site has been
used as a fill area for municipal refuse, and installation of leachate
control would be difficult. Because of limitations on the use of the
harbor islands, the only landfill possible would be use of non-hazardous
ash for surface contour regrading. The Boston Harbor Islands Plan proposes
use of Spectacle Island within five years for passive recreation.
Alternatives 10 and 11: Preparation of fill for hazardous
wastes will require obtaining a permit in accordance with draft provisions
of the Resource Conservation and Recovery Act (P.L. 94-580), and monitoring
of groundwater observation wells, and collection and treatment of leachate
must be done.
In summary, all feasible alternatives are subject to implementation
difficulties but of these six alternatives, 8 and 11 will probably have
the fewest implementation problems. Alternatives 2 and 10 have implementation
difficulties which may be insurmountable, particularly in combination
with the increased cost for cofferdam construction. Alternative 9 cannot
be implemented unless the ash is considered non-hazardous.
48
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4. Summary of Analysis
The selection process, at this point, was principally based on
implementation and relative impact.' Alternative 2 and 10, which include
filling of ash in cofferdammed areas on either the ocean or harbor side
of Deer Island, (which are elements of the Applicant's Proposed Action)
were initially eliminated for the following reasons:
. The Boston Conservation Commission, which has review authority
over this action, would not accept harbor fill (Beal 1975) if there were
alternatives to this action.
. Based on EPA guidelines which must be used by the Corps of
Engineers in evaluating filling projects the Corp may not be able to
issue a filling permit if an alternative with lesser environmental impacts
is available.
. The cofferdam construction made these alternatives less cost
effective than Alternative 8, 9, and 11 with or without federal grants.
. The impact of harbor area lost associated with alternative
10 was considered unacceptable.
The potential impact of cofferdam tupture due to potential
storm damage and breaking of the cofferdam made both alternatives 2 and
10 unacceptable.
Interpretation of Executive Order 11988 and 11990 required
that no other viable alternatives exist before allowing wetlands fills or
desruption of floodplains.
Alternative 1, using inland fill at an existing fill site, was
eliminated for the following reasons:
. The. sludge analysis indicated that the ash might be a hazardous
material as defined by RCRA, and as such the.absence of landfills in
eastern Massachusetts licensed for hazardous wastes precluded use of this
alternative.
. Alternative 1 was.the least cost effective alternative with
or without federal grants.
. The resource costs and transportation impacts were such that
if other more cost effective alternatives were available this alternative
would be eliminated.
Alternative 8, using an inland fill on Deer Island for non-
hazardous wastes was also eliminated because of the initial assumption
made that the ash would be defined as hazardous. The sole difference
between Alternative 8 and 11 is the recycle of leachate for treatment.
49
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This meant that if the sludge ash should be considered non-hazardous
(probably due to a change in definition rather than a change in sludge
composition) there would be no reason not to proceed with Alternative 11.
Therefore, alternatives 9 and 11 remained and became the recommended
project alternatives. These had about the same level of implementation
problems and associated adverse impacts. While alternative 11 was
considered to be the most cost effective, its implementation could be
blocked due to its inconsistency with the Boston Harbor Islands Plan.
Therefore, alternative 9 was retained.
50
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D. Conclusions Level 2 Analysis
The EIS rejected all ash disposal alternatives which involved filling
of ash in a cofferdam on either the ocean or harbor side of Deer Island
(Alt. 2 and 10). Alternative 10 was eliminated not only on the basis of
the perceived detrimental impacts which would result from filling of the
harbor; but also due to the cost of cofferdam construction and the fact
that the Boston Conservation Commission has stated it would not allow
construction in the harbor if other alternatives existed. Alternative
2 was eliminated because of problems with implementation, and the relative
environmental impacts of that alternative. The implementation problems
associated with this filling alternative were mainly concerned with an
interpretation of existing Presidential Executive Orders (11990 and 11988)
covering federal actions affecting wetlands and floodplains. The
interpretation stated that any construction in wetlands would be prohibited
if any practicable alternative exists. Present federal policy and EPA
guidelines do not specifically prohibit such construction (filling),' but
do require that a floodplain/wetlands assessment of the project and its
alternatives be undertaken and a final decision as to practicability made
based on a comparison of their relative feasibility, economic costs and
environmental impacts. As a result, EPA cannot at this time eliminate
ash disposal alternatives solely on the basis that they require filling.
While the rationale behind the elimination of alternatives requiring
filling may be justified, more information on the actual "effects" and
impacts of filling should be made available before a final decision is
reached. Therefore, we are requiring that the MDC, as part of their
facility planning prepare an environmental assessment of alternatives 2,
9, and 11 and based on a review of that assessment, EPA and MDC will
select the option which proves to be the most environmentally sound and
cost-effective. Since the construction of a cofferdam and its subsequent
filling with ash will require that a Section 404 Dredge and Fill permit
be issued by the Corps of Engineers, the assessment will use the EPA
Section 404(b) guidelines to determine if the impacts are acceptable or
if less damaging alternatives are available.
51
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SECTION VI
Environmental Consequences
The environmental Impacts and consequences of all the alternatives
were presented and evaluated in Section III• Those impacts associated
with the selected incineration alternative and the feasible ash disposal
options were presented in Tables A-1 - A-4.
In general, the selection of incineration will result in several
major beneficial impacts being realized. These impacts include the
removal of a significant increment of pollution from Boston Harbor. The
proposed action will result in the removal of approximately 80% of the
sludge BOD load and an even larger portion of the sediment load now
imposed on Boston Harbor by the continued outpouring of digested sludge.
In addition, there will be an improvement in the aesthetics of the Harbor;
the possible removal of bans on commercial and recreational shellfishing;
and the increased availability of the Harbor for other recreational uses
(bathing, fishing, boating). The sediments of the Harbor will be improved
to the point where the diverse, desirable marine life which the Harbor is
theoretically capable of supporting may become reestablished.
The principle adverse environmental consequence which will result
from the implementation of the recommended plan is related to air quality.
The proposed scrubber system and required air pollution control devices
will, however, minimize the amount of incinerator emissions and thus
mitigate the adverse impacts to the air.
52
-------
SECTION VII
Public Participation
A. Public Hearing
The draft statement was available for review at least 30 days prior
to the hearing, and the public hearing was held on April 16, 1976 in
accordance with 40 CFR 6.402 (see Appendix AA). A transcript of that
public hearing is available for public review.
B. Public Workshops
In addition to the above, EPA, Region I held two public information
workshops during the course of this study for the express purpose of
informing concerned interests of progress on the project, and to elicit
comments and concerns from those parties.
The first workshop was held on September 4, 1975, in the 22nd floor
conference room of the J.F.K. Federal Building, Boston, Massachusetts.
This workshop outlined the scope of the project (including the basic
alternatives to be investigated) and explained the methodology to be used
in evaluating those alternatives. An informational handout was prepared
for the workshop and it was made available to the participants. Appendix
BB reproduces that handout, and lists the organizations that were
represented at the meeting.
The second public workshop was held at the same location on November
10, 1975. This meeting presented to the participants the results of the
environmental, energetic, and cost-effectiveness evaluations that had
been developed in the intervening period since the first workshop.
C. Receipt and Filing of the Draft and Final Impact Statement
The draft environmental impact statement was submitted to the Council
on Environmental Quality in March, 1976, for review by other Federal
agencies and the public.
As a result of the transfer of impact statement filing responsibility
from CEQ to EPA, (FR Vol. 42, No. 218, p. 58775), this Final EIS is being
submitted to the U.S. EPA, Mail Code A-104, Washington, D.C. 20460 for
clearing house action.
53
-------
APPENDIX
-------
APPENDIX A-l. CRSTER ANALYSIS
I. Background
EPA's Emission Offset Interpretative Ruling has established levels
of significance for the impact of a new major source located in a
clean zone (attaining NAAQS) on a dirty zone (not attaining NAAQS).
If the impact of the new source is greater than these significance
levels, then the source is subject to the requirements of the offset
ruling. In addition the source is subject to EPA's PSD regulations
as concerns its impact on the clean zone. This includes a demonstra-
tion that the impact of the source will not exceed the PSD defined
increments and that the source will not cause a new violation of any
NAAQS.
The problem at hand is that Deer Island is located in a non-attainment
AQCR for TSP, but the state has designated Deer Island itself as a
clean zone. The consultant's analysis of air quality impacts pre-
sented in the EIS, Part B, Volume II, Appendix V, p. 185, indicates
a potential for exceeding the significance levels for TSP (24-hour
average of 5 ug/m3 and annual average of 1 ug/m3). The applicable
Class II PSD increments (24-hour average of 37 ug/m3 and annual aver-
age of 19 ug/m3) are shown to be met.
The type of analysis that is presented in the EIS, Part B, is known
as a Worst Case Analysis. This utilizes assumed worst case meteor-
ology that is independent of wind direction in a simple Gaussian
diffusion model, e.g. PTMAX, to yield conservative upper bounds for
maximum expected concentrations, as described in EPA Guidelines. 1
This type of analysis is simple to do and is normally used as a quick
screening analysis. If the maximum concentration is less than the
regulatory limit of concern, then a more time consuming refined anal-
ysis is not needed. The analysis also cannot geographically locate
the areas of expected maximum concentration with any degree of accuracy.
Of course, if the maximum is under the limit of concern, one wouldn't
be too concerned where that maximum was. If the regulatory limits
themselves vary spatially, as in the case at hand, the screening
analysis should yield a maximum concentration less than the lowest
regulatory limit of concern.
1. Guidelines for Air Quality Maintenance Planning and Analysis
Volume 10 (Revised): Procedures for Evaluating Air Quality Impact of
New Stationary Sources, EPA Office of Air Quality Planning and
Standards, Research Triangle Park, North Carolina EPA-450/4-77-001,
1977.
1.
-------
If the worst case analysis indicates a potential for exceeding a
regulatory limit, then a more refined analysis is needed. This
analysis, while more resource consuming than the screening analysis,
should yield more realistic estimates of maximum expected concen-
trations and must have spatial resolution sufficient to identify
their locations. Refined analyses normally use observed meteorology
in a brute force approach that calculates hour-by-hour concentrations
for a suitably long period of record at many receptor locations.
Hourly concentrations can be averaged every 24 hours (normally mid-
night-to-midnight) to yield daily averages from which the maximum
daily average cp.n be extracted. Other averaging times are handled
similarly, including the annual average.
This Appendix presents such an analysis for the impact of the Deer
Island Facility on TSP levels. In the following sections, the model
and input data that were used are described, and the results presented.
In addition to daily and annual averages, results are presented for
averaging times of 1 hour, 3 hours and 3 months so that the results
for TSP can be used to generate predictions for NOX, S02 and lead
that can be compared to the PSD increments for S02, and used in NAAQS
analyses for all three pollutants. NAAQS analysis requires the ad-
dition of suitable background levels of pollutant to the modeled
predictions. The transformation of TSP concentrations to those for a
new pollutant is done by multiplying the predicted TSP concentration
by the ratio of the new pollutant emission rate to the TSP emission
rate. (Predicted concentrations are directly proportional to emission
rates.) The transformations and NAAQS analyses for all pollutants,
including TSP, are presented in Appendix A-2.
II. Description of Model and Input
A. The Model
As recommended by EPA Guidelines-'-, the EPA CRSTER model was used.
This is a steady-state Gaussian plume model that uses the well known
Pasquill-Gifford dispersion coefficients and Turner stability classi-
fication scheme. Plume rise is calculated via Briggs' formulas. A
radial receptor network is defined by the intersections of the 36
azimuthal directions (10°, 20°, ..., 360°) and 5 downwind distances
that are input by the user for a total of 180 receptors per computer
run. Multiple (up to 19) stacks can be input, but they are assumed
to be colocated. This is a conservative assumption. Up to one year
of meteorology can be input per computer run. This consists of hourly
values for windspeed and direction, stability class, mixing height
1. Guidelines on Air Quality Models, EPA Office of Air Quality
Planning and Standards, Research Triangle Park, North Carolina
EPA-450/2-78-027, 1978.
2.
-------
and temperature. The model has a preprocessor program that converts
hourly meteorological observations as would be recorded by National
Weather Service stations into the required model input. Other fea-
tures of the model are an urban-rural option, vertical wind shear
adjustment, trapping of plumes under elevated mixing lids and a terrain
adjustment. The model is well documented in a User's Guide, * and
the reader is referred to that document for a more complete descrip-
tion of the model.
B. Meteorology
The model was run for the 5 year period 1970-74 (each year was run
separately.) This length of record is consistent with EPA Guide-
lines. The meteorological input was processed from surface observa-
tions at Logan Airport and upper air soundings at Portland, Maine. Due
to the proximity of Logan to Deer Island, the meteorological data base
should be quite representative of the facility's site. Of the nearest
radiosonde stations (Albany, Portland, New York, Chatham) Portland is
judged to be the most representative of the site. The urban option
of the model was used.
C. Source Data
Table 1. Source Input
emission rate (2 units) 1.68 g/sec
stack height 45.72 m .(150 ft)
stack diameter .90 m
exit velocity 10.00 m/sec
exit temperature . 322.00 °K
stack base elevation 30.00 ft msl
Both stacks were colocated. Since each stack had the same source
parameters, only one stack was modeled with twice the maximum emission
rate per unit of .84 g/sec. The stacks will actually be separated by
40 ft, according to the EIS, Part B. While not negligible, this
distance is not great enough for us to be concerned with the over-
prediction that results from colocation. The stacks were located at
UTM co-ordinates (4690.7, 338.5). The stack height of 150 ft (the
analysis in Part B used 110 ft) is based on the downwash analysis in
the draft EIS for upgrading MDC, Vol. 2, p. A-412. It is EPA's under-
standing from FAA that this stack height will not be a problem for
aircraft operation at Logan Airport. The remaining stack parameters
were taken from the EIS, Part B, Vol. II, Table V-2. Note that this
table lists incorrect peak emission rates, although the consultant
used the correct emission rates in his modeling.
1. User's Manual for Single-Source (CRSTER) Model, EPA Office
of Air Quality Planning and Standards, Research Triangle Park, North
Carolina, EPA-450/2-77-013,1977.
3.
-------
D. Receptors
Ten receptor rings were chosen. Since the model can only handle 5
rings per run, this necessitated 2 runs per meteorological year.
However, the density of receptor coverage this afforded is believed
to yield adequate spatial resolution. The receptor rings were chosen
as follows.
The PTMAX model was run for the source parameters listed above. The
output was examined to determine likely distances to downwind maxi-
mum concentrations for those meteorological conditions thought to be
important in producing maximum short term concentrations. The 5
distances so chosen were: 0.37, 0.67, 1.21, 2.17 and 3.89 km. In
addition, the distances to 5 nearby air quality monitors of interest,
as determined from their UTM co-ordinates, were calculated: 4.23,
6.00, 8.05, 11.40 and 12.16 km. All the above distances were used
with the exception of 3.89 km. This distance was eliminated in order
to have a receptor at Cottage Hill in Winthrop, a distance of 1.79 km.
The 3.89 km distance was eliminated because of its proximity to the
4.23 km ring. Table 2 presents the locationsof the monitors and Cottage
Hill. Figure 1 depicts these locations and the receptor network.
Table 2. Locations of Monitors and Cottage Hill
Name X Y^ Distance Ring Azimuth Direction
(km)
Cottage Hill 4692.380 337.880 1.79 4 340° 34
Long Island 4686.537 337.766 4.23 6 190° 19
Revere 4696.154 336.000 6.00 7 335° 33-34
JFK 4691.615 330.500 8.05 8 277° 28
Kenmore 4690.400 327.100 11.40 9 269° 27
Quincy 4678.. 600 337.300 12.16 10 186o 18-19
The receptor heights were read from USGS maps. According to restric-
tions imposed by the terrain adjustment in the model, one receptor
height that was higher than stack height had to be adjusted downward
to be less than the stack height. This adjustment was only 20 ft and
it was at the last ring distance where the plant impact is shown to be
negligible. In general, topography does not present any problem for
this analysis. Table 3 presents the terrain heights that were input
to the model.
4.
-------
.Figure 1. Receptor and
Monitor Locations
5.
-------
Tab 1 *-•*_
Receotor Heiehts
RING DISTANCES (KM) =
.37
.67
1.21 1
.79 2.17
RING OIS1ANCES(KM)= 4.23
6.00 a
.05 11
.40 12.16
runni tutVAi
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-------
III. Results
A. Annual Average
Table 4. Maximum Annual Averages (ug/mj)
Level of Significance is 1.0 ug/m-*
Year Rings 1-5 Rings 6-10
.37 to 2.17 km 4.23 to 12.16 km
1970 .79 (.49) .14
1971 1.00 (.49) .14
1972 .97 (.44) .13
1973 .76 (.45) .13
1974 1.01 (.50) .15
Table 5. Maximum Annual Averages Over All Years
at Monitors and Cottage Hill (ug/m3)
Cottage Hill .24
Long Island .06
Revere .04
JFK .03
Kenmore .02
Quincy .02
The maximum annual average over all receptors and all years was 1,01
ug/m . The maximum for each year was always on the top of the hill
on Deer Island to the SE of the plant. The numbers in parentheses
in Table 4 are the maxima over all receptors not located on Deer
Island. These maxima were always 1.21 km to the ENE of the plant over
the water. The maximum over all years for this receptor was .50 ug/m3.
In summary, the level of significance is exceeded only on Deer Island
itself. However, since this is a clean zone, predicted concentrations
on Deer Island should be compared with the Class II PSD increment of
19 ug/m3. This limit is easily met. Off of Deer Island, the level of
significance is not threatened with maximum impacts of one half this
level. The maximum impact at any monitor is only 6% of the level of
significance.
7.
-------
B. Daily Averages
f\
Table 6. Maximum and Highest Second-High Daily Averages (ug/mj)
Level of Significance is 5.0 ug/nH
Year Rings 1-5 Rings 6-10
.37 to 2.17 km 4.23 to 12.16 km
MAX HI-2-HI MAX HI-2-HI
1970 9.9.1 (5.05) 8.15 2.51 1.36
1971 12.34 (4.88) . 10.25 1.38 1.16
1972 9.18 (4.71) 8.99 1.83 1.26
1973 8.33 (5.92) 7.35 3.53 1.88
1974 9.86 (4.58) 8.18 2.12 1.36
Table 7. Maximum and Highest Second-High Daily Averages Over
All Years at Monitors and Cottage Hill (ug/nr*)
MAX HI-2-HI
Cottage Hill 3.51 2.55
Long Island 1.95 1.47
Revere .93 .63
JFK .81 .71
Kenmore .54 .48
Quincy .50 .36
The maximum daily average over all receptors and all years was 12.54
ug/m3. The maximum for each year was always on the hill on Deer Island
to the SE of the plant. The numbers in parentheses in Table 6 are the
maxima over all receptors not located on Deer Island. The maximum
over all years for these receptors was 5.92 ug/m^. Figure 2 more
clearly Illustrates the results for maximum daily TSP levels. This
map shows all areas over 4 and 5 ug/m-'. The level of significance
is exceeded on Deer Island and in several areas over the waters off
Deer Island within approximately 2 km distance of the plant. The only
land area where the significance level is threatened, aside from
Deer Island, is the neck right above Deer Island and below Cottage
Hill in the vicinity of Point Shirley.
The exceedances on Deer Island do not present a problem since Deer
Island is a clean zone. The applicable PSD Class II increment is 37
ug/m3, not to be exceeded more than once per year. Thus, it is the
highest second-high concentration, that is to be compared to the in-
crement. These are also presented in Table.6. The largest highest
second-high is 10.25 ug/nH on Deer Island. Finally, Table 7 indicates
that both the level of significance and PSD increment will not be
violated at any monitor or at Cottage Hill.
8.
-------
Figure 2. Maximum Daily TSP
(ug/m3), 1970 - 7A
9,
-------
C. 3-Hour and 1-Hour Averages
Year
1970
1971
1972
1973
1974.
Year
1970;
1971
1972
1973
1974
Table 8. Maximum and Highest Second-High
3-Hour Averages (ug/m-*)
•
MAX
27.53
39.79
29.39
39.57
39,81
Table
•
MAX,
57.23
69.70
68.75
79.90
69.09
Rings 1-5
37 to 2.17 km
HI-2-HI
24.30
37.24
24.47
28.92
25.66
Rings
4.23 to
MAX
10.92
7.61
9.05
17.55
9.33
6-10
12.16 km
HI-2-HI
8.78,
5.53
7.56
10.67
7.65
9. Maximum, and Highest Second-High
1-Hour Averages (ug/tp)
Rings 1-5
37 to 2.17 km
HI-2-HI
51.20
62.20
63.54
78.13
57.51
Rings
4.23 to
MAX
18.23
16.59
15.89
20.83
15.46
6-10
12.16 km
HI-2-HI
15.74
11.17
13.57
20.83
11.96
Table 10. Maximum and Highest Second-High
3-Hour and 1-Hour Averages Over All Years at
Monitors and Cottage Hill (ug/m3)
3-Hour 1-Hour
MAX HI-2-HI MAX HI-2-HI
Cottage Hill
Long Island:
Revere
JFK
Kenmore
Quincy
17.99
7.05
5.05
3.87
2.51
1.89
16.15
6.34
4.97
3.13
1.79
1.64
48.44
12.39
11.11
8.58
6.46
4.62
, 36.19
11.29
10.62
5.60
3.42
4.23
10.
-------
Because there is a 3-hour PSD increment for S02 (as well as a 3-hour
NAAQS) and a proposed 1-hour NAAQS for NOX, the above tables are
presented. The maximum and highest second-high 3-hour concentrations
over all years are 39.81 and 37.24 ug/m3. The maximum and highest
second-high 1-hour concentrations are 79.90 and 78.13 ug/m3.
D. 3-Month Average
The CRSTER model does not routinely print summary tables for the 3
month averaging time as it does for the annual, daily, 3-hour and
1-hour averaging times. If the tape output option of the model is
used, the user can write his own program to directly calculate 3-month
averages from this tape output. The model had already been run when
the request for 3-month averages came in, motivated by the new lead
standard. There was not enough time to rerun the model and write the
analysis program. Hence, the maximum 3-month average was estimated
from the printed daily and annual maximums.
Intuitively, the maximum 3-month average will fall between the maximum
daily average and the annual average for any particular year, but
much closer to the annual average.
Table 11. Maximum Daily and
Annual Averages (ug/m3)
Year Annual
1970 .79
1971 1.00
1972 .97
1973 .76
1974 1.01
EPA's subjective estimate for the maximum 3-month average would be
1-2 ug/m3.
The CRSTER printed output does give some additional insight into the
3 month averages. For each year, the model prints out the daily
maximum over all receptors for each day. By summing these daily
averages one can calculate 3-month averages. These will be conserva-
tive upper bounds because we are adding together daily maxima
irregardless of receptor location.
11.
-------
To illustrate this, let us consider two receptors, A and B. A is to
our west, B is to our east and we (the source) are facing north in
between A and B. On day 1, the wind blows west to east and the maxi-
mum daily average is 10 ug/m3 at point B while at point A the average
for this day is zero. On day 2, the wind blows east to west and the
daily maximum is 10 ug/m3 at Point A while at point B the average
for this day is zero. The two day averages at both point A and B
are 5 ug/nr. However, with the technique of adding daily maxima
we get a two day average of 10 ug/m^.
This technique was used for the year 1974 since that year had the
highest annual average concentration. First, the total of the daily
maxima for each month were calculated; from these running three
month averages were then calculated. The results are presented in
Table 12. The highest 3 month average thus caluclated was 2.71 ug/m .
To illustrate the conservatism built into this calculation, an annual
average of 2.42 ug/nH was calculated uaing the same technique. This
compares with the actual maximum annual average of 1.01 ug/m . If
the estimated 3-month average was overestimated by the same amount
as the annual average, the actual 3-month average would be 1.13 ug/nH.
Table 12. Calculated 3-Month Averages for 1974 Using
Method of Adding Daily Maxima
Period ug/m3
JFM * C+ 2.33
FMA 2.10
MAM 2.06
AMJ C 2.15
MJJ 2.49
JJA 2.58
JAS C 2.71
ASO 2.67
SON 2.68
OND C 2.50
NDJ 2.42
DJF 2.37
* JFM - January, February, March etc.
+ C - Calendar quarter
12.
-------
IV. Summary and Conclusions
Table 13. Summary of Results for TSP (ug/m3)
Predicted Regulatory
Concentration Limit
Maximum Annual 1.01 19.0
Maximum Annual off Deer Island .50 1.0
Maximum 24-hour 12.54
Maximum 24-hour off Deer Island 5.92 5.0
Highest Second-High 24-hour 10.25 37.0
Maximum 3-hour 39.81
Highest Second-High 3-hour 37.24
Maximum 1-hour 79.90
Highest Second-High 1-hour 78.13
Estimated 3-Month Maximum 2.71
For TSP, it is concluded that the PSD increments will be met in the
clean zone on Deer Island. In the dirty zone, off of Deer Island,
the level of significance for the annual average is met. However,
it is exceeded for the 24-hour average over waters adjacent to Deer
Island within approximately 2 km of the plant. The. only land area
in the dirty zone where the level.of significance is approached is
in the vicinity of Point Shirley. At the Revere monitor where
non-attainment is projected for background levels in the EIS. Part B,
the maximum annual concentration is predicted to be .04 ug/m* or 4%
of the level of significance. The maximum 24-hour concentration
at Revere is predicted to be .93 ug/m3 or about 19% of the level of
significance.
13.
-------
Appendix A-2
As mentioned in Part A-1 of this Appendix, the transformation of
Total Suspended Particulates (TSP) concentrations to those for a new
pollutant (SO2, Nox, Pb and Cd) is done by multiplying the predicted TSP
concentrations for any desired period (annual/ 3 month, 24 hour, 3 hour
and 1 hour) by the ratio of the new pollutant emission rate to the TSP
emission rate for that same period. The results of these calculations
are shown in Table 1 below.
Table 1
Ground Level Concentrations (ug/m^)
TSP*
SO*
No,
Pb
Cd
Annual
Average
3 Month
Average
Highest
24 Hour
Highest
3 Hour
Highest
1 Hour
Emission
Rate
Ratio
1.01
2.71
12.5
39.8
2.98
8.00
36.9
117.4
79.9 235.7
1.68 4.96
4.96
4.81
12.89
59.2
189.4
380.3
8.00
8.00
0.006
0.015
0.06
0.18
0.36
.00922
.00922
0.0002
0.0004
0.002
0.006
0.012
.00026
.00026
1.0 1.68 = 2.95 1.68 = 4.76 1.68 = .0055 1.68 = .000158
*Predicted by CRSTER model at various locations
These incinerator-produced Ground Level Concentrations (GLC) are then
added to predicted 1985 background levels of the same pollutants to
determine the total GLC. In the case of TSP and SO2, actual monitored
values for those pollutants at a monitoring location on Long Island, a
distance of 4.23 km (about 2 1/2 miles) from the proposed incinerator
site were used. This location was determined to be the location, with
air quality data available, that was most representative of the areas
around the incinerator where the GLC's due to the incinerators would be
a maximum. The measured values at Long Island are shown in Table 2.
14.
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Table 2
Measured Background Levels at Long Island (ug/m3)
Pollutant TSP SO?
Annual Average 35.0 27.0
Highest 24 Hour 104.1 120.5
Second Highest
24 Hour 95.3 115.3
It was assumed that since these data showed compliance with standards
no improvement could be counted on and that the 1977-78 data would be
representative of 1985 conditions. Nox was not monitored at the Long
Island station and therefore No,, data from a monitoring site in East
A
Boston, the closest site to the proposed incinerator, was used. The East
Boston site is in an area which is more populated and subject to many
more combustion emission sources than Deer Island and, therefore, data
from the site is not truly applicable to Deer Island. That data is
presented for comparison sake and it should be noted that judgements
based on that data will be conservative. The annual average background
1985 concentration for No was assumed to be 85.3 ug/m based on the East
Boston monitoring data.
Background level data on Pb and Cd were even harder to find. The
closest monitoring location measuring Pb was located in Kenmore Square.
Although this site is not at all representative of Deer Island, it was
the only data available and therefore was used for purposes of comparison.
The 1978 monitored 3 month average was 6.6 ug/m3. Nationally EPA has
estimated that switching to unleaded gasoline will reduce the lead
concentrations in an area by 89% in the ten year period from 1975 to
1985. If we assume that 30% of that reduction has taken place between
1975 and 1978 and calculated the 1975 value it would be 8.5 ug/m3.
Therefore, the calculated 1985 background level at Kenmore Square would
be 0.94 or 1.0 ug/m3.
No background levels foe cadmium have been measured in the Boston
area but air pollution experts at EPA's research facility at Research
Triangle Park, Durham, North Carolina were contacted and they indicated
that 6 to 9 manograms (10~9) per cubic meter were normal urban background
levels.
The addition of incinerator produced GLC and background levels is
shown in Table 3. The resulting total ground level concentration for any
particular time period (annual average, 3 month average, second maximum
24 hour or 3 hour period) is compared to the primary and secondary
standard. As is shown in Table 3 no violations of standards occur. In
the case of Nox the incinerator-produced GLC is presented but no 1985
15.
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background condition is presented. This statistic was not available.
As is noted in the Table, a short term Nox standard is presently under
consideration by EPA and may be promulgated as a one or 3 hour standard.
Table 3
Total
Incinerator Background Ground Standard
Produced + Level = Level (Primary/
Pollutant Time Period Level Concentration Secondary)
TSP
so2
Nox
Annual
24 hour
Annual
24 hour
3 hour
Annual
1 hour
1.01
12.5
2.98
36.9
117.4
4.81
380.3
+ 35.0
+ 95.3
+ 27.0
+ 115
+ (b)
+ 86.5
+ (b)
36.0
107.8
29.98
= 151.9
(b)
91.3
= (b)
75/60(*>)
260/150
80/NA
365/NA
NA/1300
100/100
(0
Pb 3 month 0.015 + 1.0 = 1.015 1.5/NA
(a) This number is not a standard but only a guide.
(b) No background statistics on SO2 for a 3 hour, or Nox for a 1 hour
period was available.
. (c) A short term standard for Nox is presently under consideration
but none has been promulgated
Note: All results are presented in ug/m3
16.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203
March 27, 1979
To: All Interested Parties, Governmental Agencies, Public Groups and
Citizens
Enclosed is a copy of the Final Environmental Impact Statement (EIS) on
the MDC Proposed Sludge Management Plan, Metropolitan District Commission,
Boston, Massachusetts which is being sent to you for review and comment.
This Final EIS has been prepared by EPA in accordance with Section 102(2)(c)
of the National Environmental Policy Act (NEPA) of 1969 (Public Law 92-
190). The Draft EIS was circulated for comment on March 3, 1976. The
public hearing on the Draft EIS was held on April 6, 1976 and a trans-
cript of that hearing is available for review. Comments received on the
Draft and EPA's responses are published in Section VII of Part B, Volume 1
of this Final EIS.
This Final EIS is made up of three volumes:
1. Part A
2. Part B - Volume I
3. Part B - Volume II (Technical Appendices)
Part A of the EIS presents an executive summary and incorporates the
latest interpretations of Federal legislation and guidelines.
However, we are circulating Parts A and B to all readers to insure that
all information is available to those who need it, and that all steps
in the decision process are clearly set forth. Please note that Part B
should be read in conjunction with Part A to clarify its content. Further,
judgements and conclusions which have changed as a result of changes in
Federal legislation, policy, regulations or guidelines are screened and
appear as lighter type in Part B. This is to advise the reader that
those portions have changed based on information presented and discussed
in Part A. Finally, new information added since the Draft EIS was printed
is identified by a black line in the right margin of Part B. All of Part
A postdates the Draft.
Comments on the Final EIS and on EPA's decisions regarding the proposed
project are welcome. Comments should be submitted to this Office within
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thirty(30) days of the date the Environmental Protection Agency publishes
notice of this EIS in the Federal Register. The study and design activity
proposed in the EIS cannot be initiated until at least 30 day's after the
notice of this Final EIS is published in the Federal Register. We
anticipate that publication will occur on or about May 2, 1979.
Because of the concern and controversy over this project, EPA will hold
two official Public Hearings on the Final EIS in order to explain the project
and to receive comments prior to making a final federal decision or taking
administrative action on the project. The Hearings will be conducted as
follows:
April 25, 1979 - 7:00 - 10:00 p.m.
Winthrop Junior High School, Winthrop, MA
April 30, 1979 - 1:30 - 5:30 p.m. and 7:00 - 10:00 p.m.
Faneuil Hall, Boston, MA
Individuals wishing to present testimony or comment at either Public
Hearing should contact EPA's Office of Public Awareness at 617-223-7223
at least one week in advance of the Hearing they wish to speak at in
order to receive a scheduled time to do so.
We hope you will take the necessary time to review this Final EIS and
attend the Public Hearings scheduled.
Please direct your comments and questions to:
U.S. Environmental Protection Agency
Environmental & Economic Impact Office
JFK Federal Building, Room 2203
Boston, MA 02203
Attn: Susan L. Santos
William R. Adams, Jr.
Regional Administrator
Enclosure
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