&EPA
United States
Environmental Protection
Agency
Region I
JFK Federal Building
Boston, MA 02203
    Wastewater Treatment Facilities
    for the City of New Bedford, MA
    Executive Summary
    Final Environmental Impact Statement
    July 1991

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  Executive Summary
  Final Environmental
    Impact  Statement
         July 1991
 Wastewater Treatment Facilities
for the City of New Bedford, MA


           Prepared By:

           United States
     Environmental Protection Agency
            Region I
         JFK Federal Building
         Boston, Mass. 02203
        Technical Assistance By:

         Arthur D. Little, Inc.
                        Date
LRegional Administrator
 U.S. EPA Region I

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                                EXECUTIVE SUMMARY
Background and Purpose

This Final Environmental Impact Statement (Final EIS) is the second of two documents that
constitute an analysis by the Environmental Protection Agency (EPA) of the City of New
Bedford's (City's) proposed plan to construct secondary wastewater treatment facilities to
bring the City into compliance with applicable state and federal wastewater treatment
requirements.  In 1987,  the United States, the Commonwealth of Massachusetts, and the
Conservation Law Foundation sued the City of New Bedford for violations of federal  and
state water pollution laws.  In settlement of the suit, the City signed a consent decree  that
contains, among other provisions, a federal-court-enforceable schedule for the City to  make
interim improvements to its existing primary treatment facility, and to construct secondary
wastewater treatment facilities to bring the City into compliance with the Clean Water Act.
The purpose of both the first  document of EPA's analysis, the Draft EIS, and this Final EIS is
twofold:  1) to ensure compliance with the provisions of the National Environmental Policy
Act (NEPA) and the Clean Water Act; and   2) to provide an independent review  and
assessment of all project information submitted by  the City in its Secondary Wastewater
Treatment Facilities Plan/Environmental Impact Report (FP/EIR).

The Draft EIS, which remains as a stand-alone document, focused on selecting  suitable
locations and appropriate technologies for the construction and operation of secondary
wastewater treatment facilities and presenting the environmental impact information needed to
evaluate potential alternatives for the facilities. The three components of the City's facilities
plan are: 1) secondary wastewater treatment plant siting, construction, and operation, 2)
sludge treatment and disposal, and 3) effluent discharge and outfall siting.

Several acceptable alternatives were presented in the Draft EIS, which was released in
November,  1989. These included a WWTP at either Site 1A  or 4A, use of chemically fixed
sludge as cover material at the proposed Crapo Hill landfill with a  five-year backup landfill  at
either Site 47  or Site 40 (the  latter contingent upon overcoming site acquisition obstacles and
the landfill layout avoiding the potential public water supply Zone II boundary), and the
effluent outfall at the 301 (h) site.  The location of  these sites is shown in Figure  1.

The City chose as its recommended plan a combination of secondary wastewater treatment at
Site 1A, effluent discharge through  the existing outfall pipe (after rehabilitation) at the
existing outfall site, and sludge dewatering  and chemical fixation at the WWTP site with use
of the chemically fixed  sludge as daily cover material at the proposed Crapo Hill landfill,
with a backup initial-phase landfill at  Site 47.  The only component of the City's proposed
plan that was  not acceptable to EPA (assuming the recommended mitigation measures are
taken) was the outfall site.

Issuance of the Draft EIS was followed by  a period during  which both government agencies
and the general public were invited to comment on the document.  A public hearing was also

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                                                N
             New Bedford
            Municipal Airport
                                             New Bedford
                                            Massachusetts
 LEGEND

City/Town Boundary

Roadway/Highway

Surface Water/Ocean
                                                         Miles
                                                       Scale 1:65.000
Adapted from COM. 1989
    Figure 1.  New Bedford Area Showing Sites 40, 47, 4A, 1A, and Crapo Hill

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 held during that period to solicit comments on the draft document. This Final EIS presents
 and responds to those comments; it also contains a review and evaluation of modifications to
>the City's recommended plan, and new information that has become available since the
.release of the Draft EIS. Additional analysis of the issues that were of greatest concern to
 EPA and the commentors has also been performed and the results are contained herein.

 The Draft EIS is not reproduced in this document, but modifications of and additions to it are
 contained in the Final EIS as necessary. A reexamination of the conclusions and
 recommendations made by EPA in the Draft EIS is presented in this document, taking into
 account public  and agency comments and the technical information and modification
 generated since the release of the Draft EIS.  Additional recommendations and mitigation
 measures are proposed as necessary.
 Modifications to the Proposed Action
 The following discussion summarizes modifications to the City's original recommended plan
 and new information that has become available since  the release of the Draft EIS. The
 modifications summarized herein are from the City's  Supplemental Final  FP/EIR (CDM,
 Volume VII, 1990).  Supplemental facilities planning  was undertaken by  the City after
 revisions that were made to some of the recommendations from the Final FP/EIR were
 deemed unacceptable by EPA and other reviewing agencies and not in compliance with the
 Massachusetts Environmental Policy Act (MEPA) (March 5, 1990 MEPA certificate).

 Secondary wastewater treatment plant

 The space previously allocated for future use of a combined sewer overflow (CSO) treatment
 facility is no longer required. A Draft CSO Facilities Plan, completed on October 1,  1989,
 did not recommend a separate CSO treatment facility  at Fort Rodman.  The Draft CSO
 Facilities Plan recommended storing combined sewerage during storm events, and pumping
 the stored  flow back to the plant as  soon as the wet weather flows subside.  The Final CSO
 Facilities Plan (CDM, 1991) recommends that only the CSOs in Clarks Cove (Groups 1 and
 2) would be stored during storm events and pumped back to the plant as  soon as the wet
 weather flows subside; the remainder of the CSOs (Groups 3 to 6) will be separated.

 A series of cost-saving measures resulting  from a value engineering analysis were
 recommended by the City in the Final FP/EIR, submitted after EPA's Draft EIS. Most of
 those measures were rejected by EPA and  other reviewing agencies.  As  a result, the  City
 restored the mitigation measures provided  in the  City's original recommended plan  (i.e., Draft
 FP/EIR), with the exception that educational and day  care programs which were originally to
 have been relocated  to new facilities at the former "Poor Farm," will instead be moved  to
 other suitable locations in the City in efforts to reduce the financial impact  of relocating those
 programs.

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Collection system modifications

Recommendations made in the Draft FP/EIR for the collection system were modified in the
Final FP/EIR in January 1990.  The modifications to the existing wastewater conveyance
system can be divided into three categories:
              Site-specific modifications required to deliver wastewater and to convey treated
              effluent to specific WWTP sites

              Upgrades and replacements associated with the existing conveyance system that
              are needed regardless of WWTP site

              Extension to the existing conveyance system to serve unsewered areas of New
              Bedford
Sludge management strategy
Due to of uncertainties regarding the use of the Crapo Hill landfill for disposing of
chemically fixed sludge as daily cover, the City has initiated supplemental sludge
management facilities planning.  The purpose of the Supplemental Sludge Management
FP/EIR is to develop an alternative 20-year sludge management plan and identify alternative
sites and technologies (including volume reduction and reuse options) that could meet the
City's disposal requirements in the event that the recommended plan proves infeasible.

The precise wetlands delineations at Site 47 performed for the City by Normandeau
Associates in July 1990, which was confirmed by the U.S. Army  Corps  of Engineers,
indicated some potential wetlands areas  along the  proposed golf course access road.  The
western edge of the golf course, just beyond the fairways, is  close to extensive areas of
wetlands vegetation supported by poorly drained soil.  The preferred alternative for accessing
the site is to construct a pile-supported access road between Shawmut Avenue and the site.
This alternative route would also parallel the railroad.  The portion of the road located within
wetlands (approximately 67 percent) would be constructed on timber pilings in order to avoid
filling any wetland areas.  To minimize  construction impacts in the wetlands, the bridge
would  be  constructed in stages, with the construction equipment for each stage located on the
previously constructed bridge segment.

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 Expanded Technical Evaluations
 Secondary effluent discharge

,EPA and the Massachusetts Department of Environmental Protection (DEP) requested
 additional water quality monitoring in Buzzards Bay during the Summer of 1990 (July
, through September) in order to better predict the relative impacts of the two proposed outfall
..locations on dissolved oxygen and nutrient levels.  EPA's assessment of the results of the
 1990 monitoring is presented in Chapter Two of the Final EIS.  As part of the evaluation of
.new data, EPA examined the issues of nitrogen saturation at the existing site, the contribution
. of biological oxygen demand and nitrogen from other sources, and possible double accounting
 of sources. Predicted  "average" and "worse-case" conditions were used to model expected
 water column dissolved oxygen concentration depression under various effluent discharge
 scenarios. The technical evaluation in  Chapter Two supports EPA's final recommendations
 presented in this Executive Summary.
 Comments on the Draft EIS

 After the release of the Draft EIS, EPA held a public hearing and distributed notice of the
 document's availability to an extensive mailing list, and provided copies to several public
 repositories in order to allow for public and agency review.  A number of comment letters
 were received from federal and state agencies, local officials, and the general public.  These
 comments addressed various aspects of the Draft EIS, including its  technical scope and
 adequacy, the alternatives considered, the analyses conducted, the decision-making
 methodology, and the  recommendations made.  The majority of comments received concerned
 the following issues: air quality, odors, and noise; ecology; land-use conflicts; socioeconomic
 impacts; transportation and traffic impacts (particularly at Site 1A); adherence to state and
 federal policies and regulations; water quality and resources; proposed technology and design;
 and potential  for impacts to cultural and historic resources.  A list of issues was developed
 from the comment letters and each  issue is addressed in the Final EIS.
 Acceptability of the City's Recommended Plan
 Final EIS recommendations for management options and mitigation measures

 Table 1 summarizes EPA's recommendations for the three primary components of the
 facilities plan: 1) secondary wastewater treatment plant siting, construction, and operation, 2)
 sludge treatment and disposal, and 3) effluent discharge and outfall siting.  A discussion of
 environmental impacts, recommended management options, and required mitigation measures
 is presented for each component of the plan.

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                       Table 1.  Acceptable Management Options
Secondary WWTP         Solid Disposal             Effluent Outfall



Site  1A*                   Crapo Hill*                301(h) Site with Diffuser*

Site  4A                    Site 47 (Initial Phase)*      Existing Site with Diffuser

                           Site 40
* Indicates EPA's preferred alternative.  For solids disposal, the preferred alternative is
 chemically fixed sludge to Crapo Hill Landfill, with backup landfill capacity at Site 47 for
 disposal of either chemically fixed or lime-stabilized sludge.

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 Secondary wastewater treatment plant

 The recommended management option for WWTP siting is the Fort Rodman site, Site 1A. In
rthe Draft EIS, EPA had deemed both  Sites  1A and 4A (the Standard-Times Field site) as
.environmentally acceptable. Although EPA still considers Site 4A environmentally acceptable
.'for WWTP siring, the New Bedford City Council  voted (May 1990) to select Site 1A for
' locating the proposed WWTP.  Because the City's preferred site, Site 1A, is environmentally
. acceptable to EPA,  EPA's final recommendations  and mitigation plans are presented for Site
 1A only.
      has reviewed and concurs with the City's plan for WWTP construction at Site 1A as
 described in the Supplemental Final FP/EIR provided that the required mitigation measures
 are implemented. Mitigation includes efforts to preserve  historical structures (through layout
 modification or relocation), or to record data from these structures. Because the site provides
 little opportunity for major changes to the plant layout, it is anticipated that the focus of the
, mitigation efforts will be on data recovery before the structures are removed.  Overall, it is
 expected that Taber Park and the proposed enhancement of the existing historic district will
 be an improvement over current site conditions.  The Taber Park design will incorporate
 historic uses to the fullest extent possible. Specific  mitigation measures will be developed as
 pan of the consultation  process under Section 106 of the  National Historic Preservation Act.
 Discussions regarding mitigation have been initiated between  the Massachusetts Historical
 Commission (MHC), the City, EPA, and other regulatory agencies.

 Sludge treatment and  disposal

 The recommended management option for sludge disposal is to reuse chemically  fixed sludge
 as daily cover material at  the proposed Crapo Hill landfill with a 5-year backup sludge-only
 landfill  at Site 47. In the Draft EIS, EPA had deemed chemical fixation an acceptable sludge
 treatment technology and  both Sites 47 and 40 environmentally acceptable sites for a 5-year
 backup  landfill.  Although EPA still considers Site 40 environmentally  acceptable for landfill
 siting (contingent upon  overcoming site acquisition  obstacles and the landfill layout avoiding
 the potential public water supply Zone II boundary), because the City's preferred site, Site 47,
 is environmentally acceptable to EPA, EPA's final recommendations  and mitigation plans are
 presented for Site 47 only.

 EPA acknowledges that odor problems with chemically fixed sludge have been encountered in
 isolated instances using one of the patented processes  (ChemFix™), and that these problems
 have been associated with conditions under which the sludge  has been treated. However, it is
 expected  that these problems can be readily addressed by standard mitigation measures.
 EPA's continued approval of this form of treatment is contingent upon  implementation of any
 necessary mitigation to  preclude detectable odors from the treated sludge.  Should it be
 determined that  mitigation is not possible, or not adequate to ensure the goal of no detectable
 odors, the City will have to address this issue in its Supplemental Sludge Management
 FP/EIR.

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The City plans to construct a backup sludge-only landfill and access road (with a goal of no
wetlands impact) at Site 47.  In order to avoid impacting wetlands, the landfill option
recommended for Site 47  is a 5-year, rather than a 20-year landfill.  The 5-year capacity will
provide an environmentally acceptable alternative for temporary use should the Crapo Hill
landfill not obtain the Proposition 2-V2 override required for its construction.  EPA concurs
with the City's sludge management strategy outlined previously in this Executive Summary.
Should alternative management options for sludge disposal become necessary, EPA will
review and assess the alternatives as appropriate under NEPA. If necessary under 40 CFR
§1502.9(c), a Supplemental Final EIS addressing alternative sludge management options will
be prepared.

The recommendation of Site 47 for a backup sludge-only landfill with a 5-year capacity
includes some mitigation. The more precise wetlands delineations performed for the City by
Normandeau Associates in July 1990, and confirmed by the U.S. Army Corps of Engineers,
indicated some potential wetlands areas along the proposed golf course access road. The
western edge of the golf course, just beyond the fairways, is close to extensive areas of
wetlands vegetation supported by poorly drained soil.  To address this problem, the City has
recently proposed to construct an access bridge that would avoid impacts to existing wetlands.
Although it adds to the cost of the facilities plan, EPA recommends this design as it is
protective of existing wetlands at Site 47.

Construction of a landfill  at Site 47 will avoid any areas within the 100-year floodplain. The
delineation of this line was reconfirmed through further analyses of potential flooding within
the local drainage basin.   Potential groundwater contamination from the solids disposal
landfill is considered a significant issue. Site 47 was selected in part because of lack of
potential groundwater sources in the area, and hence, the low potential for impact of aquifer
water supplies.  The City's proposed landfill design (CDM, Volume V, 1990) incorporates a
leachate collection system and surface  water sediment control features that  should protect
adjacent wetlands from long-term hydrologic impacts, and groundwater from potential
leaching.  A leachate pumping station, consisting of a separate, prefabricated  wet well and dry
well, will be constructed.  The dry well will contain two non-clog sewage pumps with
appropriate controls.  Leachate will be pumped to a gravity sewer that  connects to  a sewer
along Shawmut Avenue.   In order to control transport of eroded soils and solids,
sedimentation basins will  be constructed in exposed areas  of the landfill.  All site runoff will
pass through a sedimentation basin prior to discharge  to adjacent wetlands.  In addition, the
design of the landfill includes double liners  and groundwater monitoring wells to further
ensure that the landfill does not release contaminants to the groundwater.

Site 47 contains one small area of archaeological sensitivity and a Phase II  detailed
investigation was conducted to better define the significance of this area.  The report
concluded that Site 47 contains no archaeological resources potentially eligible for National
Register listing and that no mitigation  will be required. MHC has requested additional
information from the Boston University Office of Public Archaeology (OPA) before
completing its review. If MHC's conclusions are different from the finding of the report,

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specific mitigation measures for any anticipated impacts at the proposed landfill site will be
developed as pan of the consultation process under Section 106 of the National Historic
Preservation Act.
Secondary effluent outfall

The City's recommended management option for outfall siting is rehabilitation of the existing
outfall at the existing site with no diffuser added.  EPA's Draft EIS concluded, however, that
the potential environmental impacts resulting from secondary effluent discharge at the existing
site would be unacceptable and that only a new outfall and diffuser at the 301 (h) site would
be environmentally acceptable.

After an extensive technical analysis of supplemental water quality monitoring data collected
in Buzzards Bay during the Summer of 1990 (presented in Chapter Two of this Final EIS),
EPA still  believes that the 301 (h) site is the environmentally preferable outfall location,
because of its greater dilution capabilities, its greater compliance with water quality criteria,
and the potential improvement that would result in dissolved oxygen concentrations near the
existing discharge.  EPA acknowledges, however, that a discharge at the existing site with a
diffuser would also be acceptable, but only if the City can satisfy the regulatory requirements
that remain:

              Development of a Use Attainability Study for the purpose of downgrading
              some defined area  of the waterbody from Class SA to Class SB.  This would
              be done to more accurately reflect the uses associated with this waterbody.  SA
              waterbodies have as uses open shellfishing and excellent habitat for marine
              biota.  Neither of these uses will be met  in the vicinity of the existing  outfall,
              even with a diffuser.

              Development of an enforceable site-specific DO criterion for some area of
              water contiguous to the outfall.  The current DO standard for SA waters is 6
              mg/L; the current standard  for SB  waters is 5  mg/L. It is predicted that a
              secondary discharge at the  existing site with a diffuser will violate the SA DO
              standard and  the SB DO standard in the  bottom waters under critical summer
              conditions. Under the new Massachusetts water quality standards, a
              site-specific DO criterion may be developed for bottom waters, provided that
              the criterion is  protective of designated uses.

              Demonstrate a reduction  in effluent toxicity such that toxicity will not be
              predicted to occur  outside the mixing zone.


If the City chooses to pursue  the  alternative consisting of the existing site with a diffuser,
EPA would require the City to satisfy the above requirements,  to continue their Toxicity

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Reduction Evaluation (TRE) and Pretreatment Programs, and to implement a comprehensive
monitoring program as  a condition of the permit.

In order to determine whether there are any resources (shipwrecks) potentially eligible for the
National and State Register of Historic Places that could be affected by outfall renovations
(i.e., construction  at the 301(h) site or addition of a diffuser to the existing site), an
underwater archaeological documentation survey was conducted in  the Spring of 1989.  The
study did not include information on the identity, age, location, integrity, and potential
significance of all of the shipwrecks in the area.  Only three of the known wrecks in the study
area were discussed in  that report. Without complete data, MHC has been unable to
determine whether or not these resources are potentially eligible for the National and State
Register of Historic Places, and whether or not the outfall will affect  these resources.   If the
outfall is moved to the  301 (h) site, these resources could be impacted during construction of
the new outfall pipe. It is less likely that use of the existing outfall with a diffuser would
disturb  any archaeological resources because diffuser construction would take place in a
previously disturbed area.  If the City  opts to add a diffuser to the existing outfall rather than
moving it to the 301(h) site, it is possible that no mitigation will be required. However, if
MHC determines otherwise upon  review of the requested supplemental  information, mitigation
measures will be taken  to avoid or minimize any predicted impacts.  Any additional action
required of the City will be specified in the MOA.

In conclusion, EPA  believes that the City of New Bedford, as the entity that will have to
build and operate  these facilities,  should have the primary voice in determining which
combination  of sites and processes will most optimally serve its needs.  Throughout the
planning process EPA's role has been to evaluate the City's proposed program and
alternatives to it in accordance with NEPA to ensure that the sites and technologies chosen
are environmentally acceptable and will result in long  term compliance with  the Clean Water
Act.  While EPA  continues to support the 301(h) site as the environmentally preferred
management option, we find that  a secondary discharge at the existing site with a  diffuser
would also be environmentally acceptable contingent upon the City's ability  to satisfy  the
requirements outlined above.

Though EPA continues to recommend that the outfall be extended to the 301(h) site, we
recognize that other wastewater projects will draw heavily upon the City's financial resources.
The schedule for construction of the extended outfall (or for the addition of a diffuser  to the
existing outfall) will be negotiated by  EPA, the State, and the City in the context of the
federal/state enforcement  action.  During those negotiations, EPA will consider the City's
ability to finance the outfall  work in the context of the City's other obligations.  Also relevant
to the issue of scheduling is the possibility for coordination with Superfund cleanup activities
in New Bedford Harbor.  EPA's Superfund program had indicated  a  potential interest in
remediating areas south of the hurricane barrier.  The timing of any potential remediation
plans that could affect outfall construction will be factored into EPA's future negotiations
with the City.
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