sgEPA
United States
Environmental Protection
Agency
Region 1
J.F.Kennedy Building
Boston, Mass. 02203
EPA
Environmental
Impact Statement
Wastewater
Collection
and
Treatment Facilities,
Yarmouth,
Massachusetts
Fina
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER COLLECTION AND TREATMENT FACILITIES
YARMOUTH, BARNSTABLE COUNTY, MASSACHUSETTS
This Final Environmental Impact Statement responds to
questions on the Draft EIS and recommends a proposed
program for structural and non-structural solutions to
the wastewater problems and needs of Yarmouth.
Further information on this statement can be provided by:
Mr. Robert Mendoza
Environmental Protection Agency
Environmental and Economic Impact Office
J.F. Kennedy Federal Building
Boston, Massachusetts 02203
617-223-4635
-LEAD AGENCY-
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region I
JFK Federal Building
Boston, Massachusetts 02203
Technical Consultant
Anderson-Nichols & Co., Inc.
Boston, Massachusetts
Approved by:
MAR 10 1980
William R. Adams, Jr. / /I Final Date by Which
Regional Administrator \J Comments on the Final
Environmental Protection Agency Must be Received
Region I
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TABLE OF CONTENTS
PAGE
CHAPTER 0 - SUMMARY OF FINAL EIS AND
EPA COORDINATION PROCESS1
0.1 OVERVIEW 3
0.2 COST OF ALTERNATIVES 4
0.3 ENVIRONMENTAL IMPACTS 5
0.4 PREFERRED ALTERNATIVE 8
0.5 MONITORING/GRANT REQUIREMENTS 8
0.6 COMMENTS AND RESPONSES 9
0.7 EPA COORDINATION PROCESS 9
CHAPTER 1 - PREFERRED ALTERNATIVES 11
1.1 INTRODUCTION 13
1.2 REVIEW OF NEEDS EVALUATION 13
1.3 BASIS OF NEW ALTERNATIVES 14
1.4 DESCRIPTION OF ALTERNATIVES 14
1.5 GENERAL SCREENING OF SEPTAGE MANAGEMENT 15
ALTERNATIVES
1.6 ALTERNATIVE F-l 17
1.7 ALTERNATIVE F-2 23
1.8 ALTERNATIVE F-3 26
1.9 NON-STRUCTURAL MANAGEMENT PROGRAM 28
1.10 PREFERRED ALTERNATIVE 30
CHAPTER 2 - MONITORING/GRANT REQUIREMENTS 31
2.1 BASIS FOR REQUIREMENTS 34
2.2 REQUIREMENTS APPLICABLE TO ALL ALTERNATIVES 34
CHAPTER 3 - COMMENTS AND RESPONSES 37
3.1 INTRODUCTION 39
3.2 RESPONSES TO DRAFT ENVIRONMENTAL IMPACT 41
STATEMENT COMMENTS
APPENDIX A - LETTER FROM EPA TO YARMOUTH BOARD
OF SELECTMEN REGARDING NEW ALTERNATIVES A-l
APPENDIX B - LETTER FROM USGS TO EPA REGARDING
HYDROLOGIC STUDIES AT SITE D B-l
APPENDIX C - WRITTEN COMMENTS ON DRAFT ENVIRON-
MENTAL IMPACT STATEMENT C-l
APPENDIX D - LIST OF PUBLIC HEARING SPEAKERS D-l
APPENDIX E - PUBLIC HEARING TRANSCRIPT E-l
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LIST OF TABLES
NUMBER PAGE
0-1 ESTIMATED AVERAGE ANNUAL COSTS UNDER TWO 6
METHODS OF FINANCING
0-2 ESTIMATED COSTS UNDER TWO METHODS OF FINANCING 7
SEPTAGE HANDLING FACILITIES
1-1 COST SUMMARY - ALTERNATIVE F-l 20
1-2 COST SUMMARY - ALTERNATIVE F-2 24
1-3 COST SUMMARY - ALTERNATIVE F-3 27
3-1 COMMENT/RESPONSE MATRIX 40
LIST OF FIGURES
ENVIRONMENTAL IMPACT PROFILE 22
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CHAPTER 0
SUMMARY OF FINAL EIS AND EPA
COORDINATION PROCESS
This chapter provides a summary of the Final EIS and the process
whereby the public and various governmental agencies were involved
in its preparation.
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0.1 OVERVIEW
The Draft Environmental Impact Statement for Wastewater
Collection and Treatment Facilities, Yarmouth, Massachusetts,
was published by EPA on April 6, 1979. During the commenting
period which followed and at a public hearing held on May 21,
1979, EPA received a number of suggestions for changes and
improvements in the alternatives under consideration.
Pursuant to the stated intent of the public participation
process, EPA carried out a review of the recommendations.
As a result of the review, EPA determined that three new
alternatives should be considered. The major features of
these alternatives are described below:
0.1.1 Structural Measures
0.1.1.1 Alternative F-l
This alternative is similar to Alternative 4
of the Draft EIS. It includes the sewering
of Route 28 and wastewater and septage treat-
ment at Site D, a town-owned parcel on Buck
Island Road. In this alternative, and
Alternative F-2 and F-3 below, the septage
facility would serve both Yarmouth and Dennis,
This alternative would include the option of
treating up to 150,000 gpd at the Barnstable
Wastewater Facility.
0.1.1.2 Alternative F-2
Alternative F-2 calls for the construction
of a Yarmouth/Dennis septage facility at
Site D, The Route 28 water quality problem
would be handled by a strong non-structural
program as described below.
0.1.1,3 Alternative F-3
This is a two-phase alternative. The first
phase would be a Yarmouth/Dennis septage
treatment facility. The facility would be
compatible with the future addition of a
wastewater treatment system at Site D.
The second phase would be the sewering of
Route 28 and treatment at Site D.
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0.1.2 Non-Structural Measures
0.1.2.1 Alternative F-l
Each of the proposed structural alternatives
must be complemented by a strong non-structural
management program. This program, to be
required as a grant condition by EPA, will
include an array of measures including in-
spection, rehabilitation, and regular pumping
of on-site septic systems.
The implementation of on-site rehabilitation
will be facilitated by the availability of
Federal grant assistance.
Other recommended measures not tied to Federal
grant approval would include watershed pro-
tection zoning and the control of seasonal
housing conversions to provide for the up-
grading of on-site systems.
0.1.2.2 Alternative F-2
The measures proposed for F-l would apply
to Alternative F-2.
In addition, a special mandatory pumping and
rehabilitation program will have to be
applied to the Route 28 area.
0.1.2.3 Alternative F-3
During the first phase of F-3 the non-
structural measures slated for Alternative
F-2 will be imposed.
Following the sewering of Route 28, the
program called for in F-l would be continued
0.2 COST OF ALTERNATIVES
0.2.1 Present Worth Costs
Present worth costs represent the sum of the estimated
construction costs and plant operation and mainten-
ance costs accumulated over the 20 year lifetime of
the project. The costs include the combined use of
Federal, state and town funds.
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The present worth costs of the various alternatives
are summarized below:
Alternative F-l
-Treatment in Yarmouth only $8,998,240
-Treatment in Yarmouth and $9,023,775
additional 150,000 gpd
treatment in Barnstable
Alternative F-2 $2,587,200
Alternative F-3 (Phases 1 & 2) $5,123,955
Under Alternative F-2 and Alternative F-3, Phase 1,
there will be the additional requirement of a
strong town-enforced program of on-site rehabil-
itation and maintenance along Route 28. The
estimated costs for this program are about
$9,000,000. These are costs which would have to
be absorbed by the individual businesses and
property owners along Route 28.
0.2.2 Costs to Individuals
The present worth cost is EPA's method of comparing
various alternatives. Present worth does not
provide the individual property owner with knowledge
of his own out-of-pocket costs. These costs generally
include taxes and service area charges to pay for
the Town's share of construction and the annual
operations and maintenance costs of any wastewater/
septage treatment and collection system. Additional
costs are those associated with the individual
property owner's pumping and maintenance of his
on-site system.
Tables 0-1 and 0-2 contain annual costs if con-
struction costs are recovered from either users only,
or taxes only,and include equivalent annual costs
of on-site system maintenance.
0.3 ENVIRONMENTAL IMPACTS
There are no significant adverse impacts associated with
Alternative F-l. The impacts, both adverse and beneficial,
essentially are the same as those assigned to Alternative
4 of the Draft EIS.
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TABLE 0-1
ESTIMATED AVERAGE ANNUAL COSTS
UNDER TWO METHODS OF FINANCING
WASTEWATER FACILITIES IN YARMOUTH
ALTERNATIVE F-l
Local Share of
Construction
Cost
Operation and
Maintenance
Costs***
Cost of Septage
Handling Con-
struction
Cost****
Cost of Septage
Handling
O&M****
Total Cost
AVERAGE ANNUAL COSTS
Users Pay All Local
Share of Construction
and All O&M
Service Area
Users
$580
$85 to $3400
0
0
$665 to $3980
Balance
o f Town
0
0
$4.50 per
1000 gal.
$10.00 per
1000 gal.
$14.50 per
1000 gal.
Town -Wide Sharing of
Local Share of Construction
Users Pay All O&M
Service Area
Users*
$41
$85 to $3400
$6
0
$132 to $3447
Balance
of Town**
$17
0
$2.50
$10.00 per
1000 gal.
$19.50 plus
$10.00 per
1000 gal.
* Based on an assessed value of $100,000.
** Based on an assessed value of $40,000.
*** Based on individual water use.
**** These numbers represent only the cost of septage disposal.
Source: Anderson-Nichols & Company, Inc., 1979
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TABLE 0-2
ESTIMATED COSTS
UNDER TWO METHODS OF FINANCING
SEPTAGE HANDLING FACILITIES
ALTERNATIVE F-2
Users Pay All Local
Share of Construction
and All O&M
Taxpayers Pay Local
Share of Construction,
Users Pay All O&M
Construction
Cost
$4.70 per 1000
gallons of septage
$2.30 tax increase based
on $40,000 property
Cost of O&M
$10.40 per 1000
gallons of septage
$10.40 per 1000
gallons of septage
Total Cost
$15.10 per 1000
gallons of septage
$2.30 additional tax
$10.40 per 1000 gallons
NOTE:
1. Tax increase is based only on that portion of capital
cost attributable to treatment of septage from Yarmouth.
Users from Dennis would either pay on a per 1000 gallon
basis or through an intermunicipal agreement.
2. Cost of septage handling does not include the cost of
the hauler. The amount shown is that which would be
charged to the hauler; the homeowner would pay more.
Source: Anderson-Nichols & Company, Inc., 1979
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Alternative F-2 and F-3 would both have significant adverse
financial impacts to property owners on Route 28 in the
form of expensive on-site septic system rehabilitation
and placement programs.
During the preparation of the Draft EIS it was determined
that sewering along Route 28 would be more cost-effective
than an on-site improvement program.
Under Alternative F-2 and Phase 1 of Alternative F-3, there
are potentials for minor adverse impacts on water quality
in the Route 28 area. The minor, rather than a significant
rating, is based on the assumed enforcement of a special
mandatory inspection, rehabilitation and pumping program
along Route 28.
0.4 PREFERRED ALTERNATIVE
Alternative F-l is EPA's PREFERRED ALTERNATIVE for Yarmouth.
The basis for this recommendation is as follows:
It is the only alternative that does not have significant
adverse environmental impacts.
It is the one alternative which provides the most cost-
effective solution for present and future wastewater
disposal problems along Route 28.
It takes advantage of the Town's present eligibility
for Federal and State construction grants. There are
no assurances of the continued availability of such
funds at a later date.
It is consistent with the Water Quality Management
Plan for Cape Cod (208 Plan) prepared by the Cape Cod
Planning and Economic Development Commission.
0.5 MONITORING/GRANT REQUIREMENTS
EPA will require monitoring and mitigation measures as a
condition of any grant offer to Yarmouth to assist in the
construction of wastewater or septage facilities. The
major elements of the program are as follows:
0.5.1 Facilities Planning
Complete eligibility analysis and determine
ultimate wastewater/septage flows.
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Perform detailed hydrological evaluation of
Site D pursuant to USGS requirements if more
than 0.5 mgd of wastewater is to be applied
to the site.
Refine nonstructural program and establish
schedule for adoption/implementation.
Determine archaeological resources of Site D.
Select one of the preferred alternatives.
0.5.2 Mitigating Measures
Institute various construction period mitigating
measures as described in Draft and Final EIS.
Adopt non-structural program applicable to the
selected alternative.
0.6 COMMENTS AND RESPONSES
During the preparation of the Draft EIS a comprehensive
program of public participation was carried out. The
various workshops, newsletters, questionnaires and meetings
were previously described in Appendix A of the Draft EIS.
Following the publication of the Draft EIS written comments
were received from the public and various Town, Regional,
State and Federal Agencies. Additional statements and
questions were aired at the Public Hearing on May 21, 1979.
Some of the more persistent questions related to septage
disposal and the need for sewers along Route 28 and areas to
the South of Route 28. As noted above, EPA has considered
the concerns of the public and has included additional
acceptable wastewater alternatives in this Final EIS.
Those comments of a more general nature, which are not re-
flected in the new alternatives have been answered in detail
in Chapter 3 of this Final EIS,
0.7 EPA COORDINATION PROCESS
EPA's coordination process subsequent to the publication
of the Draft EIS has included:
A field trip to Yarmouth to review sewer needs issues
south of Route 28.
An October 10, 1979 letter to the Town of Yarmouth
describing the new alternatives under consideration
by EPA,
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A meeting with the Yarmouth Water Quality Advisory
Committee on November 20, 1979 to review the new
alternatives prior to publication of the Final EIS.
The preparation of this Final EIS along with responses
to various written and public hearing comments.
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CHAPTER 1
PREFERRED ALTERNATIVES
This chapter describes the additional alternatives developed in
response to comments on the Draft EIS.
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1.1 INTRODUCTION
The Yarmouth Draft EIS evaluated five wastewater alterna-
tives for the Town. The preferred alternative, based on
a review of environmental and financial concerns, was
identified as the Barnstable Alternative (Alternative 3).
Under Alternative 3 the Route 28 commercial area would be
sewered and wastewater would be treated at the Barnstable
Wastewater Facility. A separate septage facility on the
Town-owned Site D on Buck Island Road was to serve the
needs of both Yarmouth and Dennis.
During the course of the review of the Draft EIS, Barnstable
advised Yarmouth it would not be able to accept sewage
flows from Yarmouth in excess of 150,000 gpd. This was
less than the average summer flows of 360,000 gpd antici-
pated from the Route 28 area under Alternative 3.
With the loss of the Barnstable Alternative as a viable
option, EPA initiated an investigation of other cost-
effective and environmentally acceptable alternatives.
These investigations were influenced by both written
comments, public hearing statements and subsequent dis-
cussions with the Yarmouth Water Quality Advisory Committee
and the Cape Cod Planning and Economic Development Commission,
A repeated concern of all groups was a priority need for an
improved septage disposal facility.
Three new alternatives, all of which would be acceptable
to EPA under the conditions cited in Chapter 2 of this
Final EIS, are described in the sections which follow:
1.2 REVIEW OF NEEDS EVALUATION
As part of this EIS, EPA conducted an extensive data
collection and evaluation program to determine wastewater
disposal problem areas in Yarmouth. The program included
the review and evaluation of: previous reports, soils
information, water quality information, septage pumping
records, and septic system repair records; and numerous
meetings with the public and interviews with town officials.
The needs survey concluded with the finding that the resi-
dential sections of town do not require sewering but that
these areas require more frequent sampling and testing to
monitor water quality and prohibition of conversions from
seasonal to year-round use where on-site disposal systems
are inadequate. Further, the needs survey found that
sewering is the most cost-effective solution to the
resolution of wastewater disposal problems along Route 28.
The Draft EIS concluded with the recommendation that the
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town sewer the commercial strip and pump the wastewater
to the Barnstable sewage treatment facility and dispose
of septage from both Yarmouth and Dennis at Site "D".
In response to local requests, representatives of EPA
met with Town and CCPEDC officials prior to the pre-
paration of this Final EIS to review some questions about
additional sewer needs south of Route 28. Although there
are some isolated problem areas, it was generally agreed
that a strong program of non-structural measures would
be adequate to protect public health.
Additional investigations of needs to enable the town to
qualify for grant assistance for funding of individual
on-site system repairs are recommended in Chapter 2 as
part of future facilities planning requirements.
1.3 BASIS OF NEW ALTERNATIVES
Following public review of the Draft EIS, it was estab-
lished that many people or agencies questioned the "need"
for sewers on the commercial strip and/or were concerned
with the groundwater impacts of septage disposal at
Site "D" and/or wanted either an environmentally safe
septage disposal facility or more wastewater treatment
capacity to serve additional future need areas. Further,
as previously noted, it was established during the review
process that the Town of Barnstable would accept only
150,000 gallons per day of wastewater from Yarmouth
rather than the 360,000 gallons per day as recommended in
the Draft EIS, It was, therefore, determined that
additional wastewater management alternatives would be
made available to the Town that would be acceptable to
EPA for funding through the construction grants program.
1.4 DESCRIPTION OF ALTERNATIVES
Following a number of meetings between Yarmouth town
officials and representatives of EPA, it was established
that EPA could sponsor three alternative actions. The
three alternatives were presented to the Town in a letter
from EPA's Municipal Facilities Branch on October 10, 1979.
(See Appendix A). The alternatives are as follows:
1.4.1 Alternative F-l
As recommended in the Draft EIS, the commercial
strip on Route 28 will be sewered and the waste-
water collected will be treated with septage from
the remainder of town and the Town of Dennis at
Site "D". This alternative is workable with or
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without 150,000 gpd being transported to
Barnstable. However, the Barnstable option is
desirable because it leaves capacity in Yarmouth
for potential future needs. A major element
within this alternative is the institution of a
strong on~lot system management program for the
unsewered portion of town.
1.4.2 Alternative F-2
The design and construction of a septage treatment
facility at Site "D" in conjunction with a strong
on-lot system management program including some
very positive controls within the previously pro-
posed sewered area on Route 28.
1.4.3 Alternative F-3
The immediate design and construction on Site "D"
of a septage treatment facility that would be com-
patible with or convertible to a future wastewater
facility should non-sewering measures in the Route
28 area prove unsatisfactory. This alternative is
completely contingent upon the type of septage
treatment facility recommended and more specifically
whether or not it could be converted into a com-
bination septage/wastewater treatment facility.
As with the other alternatives, a major element of
this alternative is a strong on-lot system manage-
ment program,
1.5 GENERAL SCREENING OF SEPTAGE MANAGEMENT ALTERNATIVES
Given the comments on the Draft EIS and the resultant
three alternatives described above, it was necessary to per-
form an additional screening of septage management alter-
natives to define those alternatives that would meet
groundwater quality criteria. A summary of the results of
the screening are presented below:
1.5.1. Alternative A
Septage lagooning followed by infiltration/evapor-
ation lagoon. This alternative is identical to
that proposed as part of the Barnstable alter-
native in the Draft EIS. It was excluded from
further consideration because the fate of applied
nitrogen infiltrating into the groundwater could
not be established based on existing systems in
operation in Connecticut and Massachusetts. Thus,
the potential exists that the quality of the
affected groundwater could exceed 10 mg/1 nitrate
(the U.S. Public Health drinking water standard)
after recharge.
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1.5.2 Alternative B
Collection, storage, and land application of
raw septage by surface application (ridge and
furrow, spray irrigation) or subsurface appli-
cation (plow furrow cover, sub-soil injection,
terreator). This alternative is excluded from
further consideration because in addition to
handling and potential odor problems in the
populated area, there is insufficient land avail-
able: the process would require 200 to 600 acres
based on nitrogen and phytotoxic metal constraints,
1.5.3 Alternative C
Septage preapplication treatment followed by land
application of the liquid portion either alone or
in combination with pretreated wastewater. This
alternative would include heavy metals removal and
the return of all filtrates, centrates, supernatants,
leachates from wastewater, sludge or septage pro-
cessing to the head of the preapplication treatment
process for ultimate disposal after storage by ridge
and furrow irrigation of reed canary grass on Site
11D".
For the development of this alternative,average
septage characteristics were assumed - future
design work shouldinclude the quantification of solids,
oxygen demand, metals (zinc, copper, nickel, cadmium)
nitrogen and phosphorus in the septage, particularly
that from the commerical strip. Further, it is
recommended that pilot scale or bench scale tests be
performed during the design work to determine the
optimum doses and pH for multi-metal removal and
sludge dewatering. Sulfide precipitation appears
promising for the metals of concern based on pH
considerations.
Metals build-up in septage results from the tendency
of metals in wastewater to settle to the bottom
of a septic tank rather than be distributed to the
land through the leaching field. The greater the
period between septic tank pumping,the greater the
build-up.
1.5.4 Alternative D
Septage preapplication treatment using the BIF
Purifax process (superchlorination) plus heavy
metals removal followed by land application as des-
cribed above. In addition to the concern for
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potential carcinogenic and/or toxic chlorinated
organic compounds (which would not be removed by
dechlorination) the BIF Purifax process would be
significantly more expensive than the above-des-
cribed process. Based on figures made available
by the equipment manufacturer, a cost comparison of
Alternatives C and D was performed and it was
determined that the total present worth cost of the
BIF Purifax process was 33% to 66% more expensive;
the capital costs were 30% to 90% more expensive and
the annual operation and maintenance costs were
44% more expensive. (The range of differences is
due to the equipment manufacturer's alternative
process layouts.)
Given the above anlaysis of septage management
alternatives, the selected process to be used in the
analysis of the three alternatives available to
the town is that described as Alternative C.
1.6 ALTERNATIVE F-l
EPA has determined that if the Town of Yarmouth desires, it
will fund the design and construction of a collection system
to serve the Route 28 commercial strip with wastewater and
septage treatment and disposal at Site "D".
1.6.1 Description of Alternative
This alternative is not unlike that described in
the Draft EIS except that the envisioned septage
disposal portion is better defined and a portion
of the wastewater generated on Route 28 would be
handled by the Barnstable Treatment Facility. To
further define this alternative, Alternative F-I-A
refers to the treatment of all wastes at Site "D"
and Alternative F-l-B refers to the Treatment in
Barnstable of 150,000 gpd of wastewater from the
commercial strip with the remainder treated at a
facility at Site "D".
1.6.1.1 Alternative F-l-A
1.6.1.1.1 Collection System
8" and 10" gravity sewers along both
sides of Route 28.
Three major pumping stations pumping
wastewater to a fourth major pumping
station at Parkers River. Wastewater
would be conveyed through approximately
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9000' of 10" force main (located in
existing streets) to a combined sep-
tage wastewater treatment facility
at Site "D".
1,6.1.1.2 Treatment/Disposal
A combination of wastewater and pre-
treated septage would be subject to
further preapplication treatment by
an aerated lagoon with 30 day holding
capacity. Winter flows would be
stored in a storage lagoon and the
well oxidized wastewater would be
applied to approximately 90 acres
of reed canary grass for 9 months of
the year at a rate of 0.42 mgd.
The application of wastewater to the
crops grown could utilize any of the
conventional surface distribution
methods including: ridge and furrow
irrigation, surface flooding or
border strip irrigation. The dis-
tribution systems most used for
ridge and furrow irrigation consist
of open ditches with siphon pipes
or gated surface piping. The open
ditch system may be supplied by dis-
tribution ditches or canals with
turnouts, or by buried pipeline with
valved risers. Gated surface piping
systems generally consist of aluminum
pipe with multiple gated outlets,
one per furrow. The pipe is connected
to hydrants which are secured to
valved risers from underground piping
systems. Surface flooding and border
strip irrigation consists of directing
a sheet flow of water along border
strips or cultivated strips of land
bordered by small levees. The surface
flooding method may be particularly
good for grass crops.
The harvesting of the reed canary
grass can be accomplished with con-
ventional farming equipment (mowers,
balers, etc.)
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1.6.1.1.3 Septage Pretreatment
Chemical addition and aeration,
coagulation/flocculation, precip-
itation, settling, dewatering on
sand beds, sludge disposal in a
secured landfill with all leachates,
filtrates and supernatants conveyed
to the wastewater treatment lagoons
or to the head of the septage pre-
treatment system.
1.6.1.2 Alternative F-l-B
1.6.1.2.1 Collection System
8" and 10" gravity sewers along both
sides of Route 28.
Two pumping stations pumping waste-
water to a third station at Parker's
River. Wastewater would be conveyed
through approximately 9000' of 10"
force main (located in existing
streets) to a combined wastewater
septage facility at Site "D". One
pumping station at Mill Pond con-
veying wastewater through approxi-
mately 13,000' of force main (located
in existing streets) to the Barnstable
facility.
1.6.1.'2. 2 Treatment/Disposal
Flows from West Yarmouth will be
treated at the Barnstable facility.
At Site "D" a lagoon system, as des-
cribed above, with wastewater applied
to approximately 70 acres of reed
canary grass at a rate equal to
0.27 mgd.
1,6.1.2,3 Septage Pretreatment
Same as described for Alternative
F-l-A,
1.6.2 Economic Considerations
Table 1-1 presents a comparison and summary of the
various costs of Alternative F-l-A (combined septage/
wastewater treatment in town at Site "D") and
Alternative F-l-B (treatment of 150,000 gpd of
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TABLE 1-1
COST SUMMARY
ALTERNATIVE F-l
A. CAPITAL COST F-l-A F-l-B
1. Collection System
a. To Barnstable 0 $1,205,000
b. To Site "D" $3,850,000 2,965,000
2. Treatment/Disposal
a. At Barnstable 0 314,145
b. At Site "D" 2,333,700 1,821,000
3. Total Capital $6,183,700 $6,305,145
B. PROJECT COST
1. Implementation Costs $1,740,000 $1,711,000
2. Total Project Costs $7,923,700 $8,016,145
C. ANNUAL COSTS
1. Collection System O&M $ 42,500 $ 46,500
2. Treatment O&M
a. At Barnstable 0 19,750
b. At Site "D" 127,000 102,000
3. Total Annual Costs $ 169,500 $ 168,250
D. SALVAGE VALUE
1. Collection System $2,074,750 $2,326,500
2. Treatment Disposal 720,000 660,545
3- Total $2,794,750 $2,987,045
E. PRESENT WORTH O&M $1,849,245 $1,835,610
F. PRESENT WORTH SALVAGE $ 774,705 $ 828,000
G. TOTAL PRESENT WORTH $8,998,240 $9,023,755
(B+E-F)
Source: Anderson-Nichols & Co. Inc., 1979.
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wastewater from Yarmouth in Barnstable with the
remainder of the wastewater and the septage
treated in town at Site "D"). The reader will
note that although the cost of the treatment/
disposal facility at Site "D" is slightly smaller
in Alternative F-l-B, the collection system costs,
given the need to pump 13,000' to Barnstable, in
the same alternative are slightly higher. Thus,
the total capital costs of the two alternatives
are effectively equal,as are the total project
costs, annual costs and present worth costs of
the two alternatives.
As described in Section 1.4.1,the advantage in
keeping the option of pumping wastewater is that
Yarmouth would then have reserve capacity available
for potential future needs. The implementation of
this reserve capacity could be achieved in two
ways. First, if the town were to implement Alter-
native F-l-A and maintained an option on use of
the Barnstable facility then it would be necessary
to add a force main from and replace the pumps in
the most westerly pump station on Route 28 located
near Mill Pond. Second, if the town were to im-
plement Alternative F-l-B, then it would be necessarv
to modify the three pump stations on Route 28
tributary to Site "D" and enlarge the aerated
lagoons, storage lagoon and distribution system at
Site "D". An analysis of the costs of these two
enlargement methods indicates that (these two
alternative reserve capacity development) costs
are equivalent.
1.6.3 Non-Economic Considerations
Given the experience in negotiating intermunicipal
agreements for the disposal of wastewater from
one community at another community's wastewater
treatment facility, it is expected that an agreement
between Barnstable and Yarmouth may not be quickly
achieved. Thus, it is suggested that Yarmouth
develop Site "D", that is Alternative F-l-A, and
continue to negotiate with Barnstable for use of
the reserved 150,000 gpd capacity if and when
needed sometime in the future.
1.6.4 Environmental Considerations
The environmental impacts of this alternative would
be similar to those identified for Alternative 4 of
the Draft EIS. (See Figure 1)
- 21 -
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NJ
ISJ
Yarmouth EIS
Environmental Impact Profile
Wastewater Collection &
Treatment Facilities
Category of Impact
HYDROLOGIC
WATER QUALITY
GROWTH
FINANCIAL
ECONOMIC
AIR QUALITY
NATURAL SYSTEMS
AESTHETICS
SENSITIVE AREAS
MUNICIPAL FACILITIES
ENERGY
HISTORIC / ARCHAEOLOGIC
Category of Cost
COLLECTION / TREATMENT
Alternatives - Type & Intensity of Impacts
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-------
1.7 ALTERNATIVE F-2
EPA has Determined that if the town desires, it will fund
the design and construction of a septage disposal facility
with the provision that the town adopt a strong on-site
wastewater disposal system management program.
1.7.1 Description of Alternative
Alternative F-2 includes the construction of a
septage disposal facility to handle present and
20 year design septage flows from Dennis and
Yarmouth (including the Route 28 commercial strip).
1.7.1.1 Collection System
Septage collection would be performed by
private septage haulers.
1.7.1.2 Treatment/Disposal
Pretreated septage would be further
treated by an aerated lagoon. Winter flows
would be applied to approximately 70 acres
of reed canary grass for 9 months of the
year at a rate of approximately 0.05 mgd.
1.7.1,3 Septage Pretreatment
Chemical addition and aeration, coag-
ulation/flocculation, precipitation,
settling, dewatering on sandbeds, sludge
disposal in a secured landfill with all
leachates, filtrates and supernatants
conveyed to the aerated lagoon system
or to the head of the pretreatment system.
1.7.2 Economic Considerations
Table 1-2 presents a summary of the capital, annual
and present worth costs associated with the con-
struction of a septage disposal facility at Site "D".
Given that the difference between this alternative
and Alternative F-l is in the construction of a
collection system to serve the commercial strip,
the cost of Alternative F-2 should include repairing and
maintaining the existing on-site wastewater disposal
systems currently serving the commercial strip pro-
perties. In the Draft EIS it was determined that
the cost of upgrading or replacing all on-site
systems on the commercial strip would cost the
the individual owners approximately $9,000,000,
- 23 -
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TABLE 1-2
COST SUMMARY
ALTERNATIVE F-2
SEPTAGE DISPOSAL AT SITE "D"
rrjM
A. CAPITAL COST
1. Septage Receiving and
Pretreatment $477,000
2. Treatment/Disposal $810yOOO
3. Total $1,287,000
B. PROJECT COSTS
1. Implementation $321,750
2. Total $1,608,750
C. OPERATION & MAINTENANCE $100,000
D. SALVAGE VALUE 406,000
E. PRESENT WORTH O&M $1,091,000
F. PRESENT WORTH SALVAGE $112,550
G. TOTAL PRESENT WORTH $2,587,200
(B+E-F)
Source: Anderson-Nichols & Co. Inc., 1979.
- 24 -
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however, it was not established whether each
repair or replacement would be required immed-
iately, in five years, or in twenty years.
Therefore, the reader should be cautioned
against comparing the present worth costs pre-
sented in Table 1-2 with the present worth costs
presented in Table 1-1.
1.7.3 Non-Economic Considerations
Whether the Town of Yarmouth decides to adopt Alter-
native F-2 or not depends more on policy decisions
rather than economic decisions. That is, does the
town wish to sewer the commercial strip or simply
provide suitable septage disposal facilities?
1.7,4 Environmental Considerations
The impact evaluation for this alternative (see
Figure 1) would be similar to Alternative F-l with
the following exceptions:
1.7.4.1 Water Quality Impact
Direct
Long Term
Minor/Adverse
Impact Evaluation
This option assumes a strong non-structural
management program as described in Setions
1.9.1 and 1.9.2 below. The minor, as
opposed to a significant rating, assumes
the utmost vigilance in preventing water
quality degradation of Parker's River,
Mill Creek, Mill Pond, Lewis Bay and
Nantucket Sound.
1.7.4.2 Growth Impacts
Indirect
Long Term
Minor/Adverse
- 25 -
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Impact Evaluation
The financial costs of upgrading systems
and continuing septage pumping charges
could thwart the economic development
along Route 28.
1.8 ALTERNATIVE F-3
EPA has determined that if the Town desires, it would fund
the immediate design and construction of Site "D" of a
septage treatment facility that would be compatible with
or convertible to a future septage/wastewater facility
should non-sewering measures in the Route 28 area prove
unsatisfactory.
1-8.1 Description of Alternative
This alternative is essentially a two phase project
that would include the implementation of Alternative
F-2 initially and the implementation of Alternative
F-l-A or Alternative F-l-B sometime in the future.
Because of the similarities between Alternative F-3
and the combination of Alternatives F-2 and F-l-A
or F-l-B, a further detailed description of Alter-
native F-3 is not required.
1.8.2 Economic Considerations
Table 1-3 presents a summary of the project, annual
and present worth costs associated with the phased
construction of Alternative F-l-A in two steps.
That is, the construction initially of a septage
handling facility and the addition, in the tenth
year, of a collection system and expansion of the
treatment facility to handle combined wastewater and
septage. Again the reader is cautioned against com-
paring these costs to the cost presented in Table
1-1. First, because the total present worth cost
does not include the costs to be borne by individuals
on the commercial strip to keep their existing
on-site disposal systems in proper order - costs
which may serve only limited usefulness. Secondly,
the phased development analysis performed in accor-
dance with EPA regulations does not take into
account the probable increases in construction
cost given inflation.
- 26 -
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TABLE 1-3
COST SUMMARY
ALTERNATIVE F-3
ITEM COST
A. PROJECT COST
1. Phase I - Septage Facility $1,608,750
2. Phase II - Expansion in
Year Ten
a. Collection System $5,005,000
b. Facility Upgrade $1,319,000
c. Total Phase II $6,324,000
B. ANNUAL O&M COSTS
1. Phase I - Years 1-10 $ 97,000
2. Phase II - Years 11-20
a. Collection System $ 42,500
b. Treatment/Disposal $ 129,000
c. Total Phase II $ 171,500
C. SALVAGE VALUE IN YEAR 20
1. Phase I $ 406,000
2. Phase II
a. Collection System $2,972,375
b. Treatment Expansion $ 781,000
3. Total in Year 20 $4,159,375
D. PRESENT WORTH PROJECT COST
1. Phase 1 $1,608,750
2. Phase II $3,329,585
E. PRESENT WORTH O&M
1. Phase I $ 693,260
2. Phase II $ 645,340
F. PRESENT WORTH SALVAGE $1,152,980
G. TOTAL PRESENT WORTH $5,123,955
(D+E-F)
Source: Anderson-Nichols & Company, Inc. 1979
- 27 -
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1.8.3 Non-Economic Considerations
Whether the Town of Yarmouth decides to implement
Alternative F-3 or not again depends more on
policy decisions rather than economic decisions.
1.8.4 Environmental Considerations
The environmental impacts for Alternative F-3
would be comparable to those listed for Alternative
F-2 during phase one and Alternative F-l during
phase two with one exception. The financial impacts
would remain as significant due to the on-site
system rehabilitation costs on Route 28. These
costs would be rendered unnecessary after the con-
struction of sewers (see Figure 1).
1.9 NON-STRUCTURAL MANAGEMENT PROGRAM
Any alternative for septage treatment and wastewater collec-
tion and treatment must be supplemented with a strong non-
structural management program. Such a program is essential
if pollution from malfunctioning on-site wastewater dis-
posal systems is to be precluded.
The need for preventing problems from on-site systems is
self-evident; there are limited options for the treatment
of wastewater in Yarmouth. Present studies indicate a
limit on the capacity of Site D to accept wastewater in
an environmentally acceptable manner. The option of
treating wastewater at the Barnstable wastewater facility
is limited to not more than 150,000 gpd.
The non-structural program proposed below is the most
cost-effective and environmentally sound plan for the
Town of Yarmouth. There are slight variations in the
program to match the differences in the three alternatives
discussed in Sections 1.6 to 1.8.
1.9.1 Management Program Applicable to All Alternatives
The following are the major elements of a com-
plementary non-structural program which will
require approval by the State and EPA prior to
Step 3 grant approval:
Institute mandatory on-site system pumping
program upon completion of sewage/septage
facilities.
- 28 -
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Institute record keeping system to monitor
installation, repairs and pumping of septic
systems.
Institute inspection program to bring about
the elimination of malfunctioning on-site
systems.
Increase staff of Yarmouth Board of Health
to a level capable of carrying a full range
of inspections, violation abatement, water
quality monitoring and community education.
Institute a controlled program of groundwater
and surface water quality testing to detect
any trends indicating degradation in cooper-
ation with CCPEDC.
Initiate an educational program to encourage
water conservation measures and the proper
operation of on-site systems.
The following are additional elements of a non-
structural management program which should be
adopted locally as measures to augment the
above-listed requirements.
Amend zoning by-laws to provide for increased
lot sizes in areas where there are dimensional
or soil constraints limiting effective on-site
wastewater disposal or potentials for public
water well pollution.
Adopt regulations governing identification
of seasonal housing and evaluation of seasonal
units prior to their conversion to year-round
use to provide for the upgrading of deficient
on-site wastewater systems.
Adoption of amendments specifying the minimum
distance between a septic system and fresh-
water ponds and coastal embankments.
Adopt other non-point source controls for land-
fills, storm water runoff, road salt storage
and application, gasoline and oil storage
and spills as outlined in the Water Quality
Management Plan for Cape Cod.
- 29 -
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1-9.2 Special Management Programs Applicable
to Alternatives F-2 and F-3
Under Alternatives F-2 and F-3, the provision
of wastewater collection and treatment services
will either be delayed for ten years or not in-
stituted at all. This will call for extra
vigilance on the part of the Town of Yarmouth
in applying a strong management program along
Route 28. In addition to the measures proposed
in 1.9.1 above, the following special manacrement
programs will be required as a condition of
Step 3 grant assistance approval.*
Adopt a special mandatory pumping schedule
for all Route 28 water users which is based
on careful review of adequacy of existing
systems and periods of peak seasonal usage.
1.10 PREFERRED ALTERNATIVE
Alternative F-l is EPA's PREFERRED ALTERNATIVE for
Yarmouth. The basis for this recommendation is as
follows:
It is the only alternative that does not have signi-
ficant adverse environmental impacts.
It is the one alternative which provides the most
cost effective solution for present and future
wastewater disposal problems along Route 28.
It takes advantage of the Town's present eligibility
for Federal and State construction grants. There
are no assurances of the continued availability of
such funds at a later date.
It is consistent with the Water Quality Management
Plan for Cape Cod (208 plan) prepared by the Cape
Cod Planning and Economic Development Commission.
- 30 -
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CHAPTER 2
MONITORING/GRANT REQUIREMENTS
This chapter describes the monitoring and grant requirements which
EPA will apply to any of the recommended alternatives.
- 31 -
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2.1 BASIS FOR REQUIREMENTS
Pursuant to regulations adopted by the Council on Environ-
mental Quality in November 1978, agencies preparing en-
vironmental impact statements under the National Environ-
mental Policy Act are authorized to include monitoring
and mitigation measures as a condition of grant approvals.
EPA's regulations for the Implementation of Procedures on
the National Environmental Policy Act (November 6, 1979)
implement the CEQ directive.
Additional bases for monitoring and mitigation measures
include:
The consideration that the capacity of the septage
facilities under any of the alternatives is based
upon a flow related to a mandatory program of septic
system pumping,
The recommendations of the Water Quality Management
Plan for Cape Cod (208 Plan) which includes management
programs for water resource protection
EPA's regulations provide that prior to the award of
Step 2 or Step 3 grant assistance, EPA's Regional Ad-
ministrator must ensure that effective EIS derived miti-
gating measures are implemented by the grantee.
2.2 REQUIREMENTS APPLICABLE TO ALL ALTERNATIVES
The following is a list of requirements which have evolved
as part of the Yarmouth EIS process:
2.2.1 Facilities Planning Requirements
Complete eligibility analysis in accordance
with PRM-78-9 and PRM-79-8. This analysis
is essential for the funding of any on-site
system repairs or cluster systems in potential
problem areas south of Route 28 and in the
vicinity of Route 6A.
Determine ultimate wastewater and/or septage flows,
Perform hydrological evaluations for Site D as
required by normal facility planning require-
ments. If flows in excess of .5 mgd are to be
considered, perform additional hydrological
studies as specified by USGS in letter to EPA
dated August 17, 1979. (See Appendix B)
- 33 -
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Refine non-structural program as recommended
in Sections 1.91 and 1.92 and establish
schedule for adoption of by-laws and regu-
lations which is consistent with the schedule
for completion of construction of the septage
and/or wastewater facilities. This program
must be reviewed and approved by the State
and EPA prior to Step 3 approval.
The conceptual septage and combined waste-
water/septage land treatment alternatives which
have been developed as part of this Final EIS
were dependent on a number of site specific
and wastewater specific assumptions and planning
criteria. In order to finalize the design and
operational criteria for any one of these alter-
natives, a number of more detailed engineering
and analytical efforts will be required. The
most important of these analytical requirements
are itemized below:
Quantification of site soils and geo-
hydrological characteristics to include
soil texture, structure, permeability, in-
filtration rate and cation exchange
capacity (C.E.C.) and development of top-
ographical and groundwater contour/working
map.
Quantification of raw wastewater and septage
(particularly septage from commercial/indus-
trial establishments) to include:
TOD, BOD, solids and forms total and
Nitrogen and forms, total Phosphorus, pH.
Sodium, magnesium and calcium (SAR).
Total metals, particularly Cadmium,
Nickel, Copper and Zinc.
Pilot scale/batch jar tests to determine
optimum doses and pH for multimetal removal
efficiency and septage/sludge dewatering
efficiency. Sulfide precipitation appears
promising for the primary metals of concern
(Zn, Cu, Ni, Cd) based on pH considerations.
Crop harvesting and sales potential to include
public health agency approval of potential
end uses.
- 34 -
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Investigate archaeological resources on Site
D as specified by the Massachusetts Historical
Commission.
Select preferred alternative.
2.2.2 Mitigating Measures
Institute construction period mitigating measures
as identified in Section 6.8 and Appendix I
(Section 404 permits) of the Draft EIS and
Section 3.2.6.3 of the Final EIS.
Adopt non-structural program in accordance with
Schedule recommended in approved facilities
plan.
Adopt groundwater water quality monitoring pro-
gram at Site D. The requirements will be
determined by EPA/USGS, the State and CCPEDC
prior to Step 3 approval.
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CHAPTER 3
COMMENTS AND RESPONSES
This chapter summarizes EPA's responses to comments on the Draft
EIS which were submitted in writing or in person at the Public
Hearing on May 21, 1979.
- 37 -
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3.1 INTRODUCTION
The Draft Environmental Impact Statement was published on
April 6, 1979. During the period allowed for public
comments, April 6, 1979 to June 29, 1979, EPA received
18 written comments. These are numbered W-l to W-18 and
are reproduced in Appendix C.
At the public hearing held on May 21, 1979, statements on
the Draft EIS were made by 21 speakers. The various speakers
are identified as H-l to H-21. Appendix D includes a listing
of the speakers. Appendix E includes a transcript of the
public hearing.
3.1.1 Comment Matrix
The oral and written comments fall into a number of
fairly well-defined categories. These are summarized
as follows:
Need for sewers/service areas
Alternatives
Septage disposal
Non-structural measures
Water quality data
Aquifer protection
Groundwater hydrology
Costs
Miscellaneous
Table 3-1 summarizes, in terms of source, the number
of comments that focused on the above listed cate-
gories during the review period on the Draft EIS.
It is important to note the following:
Many of the speakers and writers had similar
comments on certain issues.
Some of the questions raised at the public
hearing were answered by representatives of
EPA at the public hearing.
- 39 -
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TABLE 3-1
COMMENT/RESPONSE MATRIX
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Local Agencies
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- 40 -
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A number of the speakers and writers covered
more than one subject.
A number of the questions raised about the
Draft EIS have been responded to in Chapters
1 and 2 of this Final EIS.
3.1.2 Response Procedure
In the sections that follow, EPA has prepared res-
ponses to all of the comments received. Since a
number of commenters have raised the same issue or
questions, an effort has been made to provide one
response wherever possible.
Each category or issue is introduced by an overview
of the major concerns of the commenters. This is
followed by a concise summary of the comment,or
comments,relative to the issue. The summary includes
an identification of the individual and/or agency
making the written or public hearing comments. The
identity of the commenter is included in Appendices
C and D.
3.2 RESPONSES TO DRAFT ENVIRONMENTAL IMPACT STATEMENT COMMENTS
3.2.1 Need for Sewers/Service Areas
A number of comments questioned the extent of the
area proposed for sewering under alternatives 3, 4,
and 5. Most of these comments cited areas to the
south of Route 28 where the condition of high water
tables and small lots were mentioned as problems.
The option to sewer such areas at a later date,
should problems arise, was recommended.
Another recommendation was for more detailed studies
of selected problem areas south of Route 28 as well
as elsewhere.
There were several questions on the technical analysis
of water quality and septic system pumping which
served as the basis for determining service areas and
a need for sewers.
Additional information was provided from several
sources to supplement previously developed data for
anticipated sewage flows from the Route 28 service
area.
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3.2.1.1 Needs South of Route 28
Comment: (W-7, W-14, W-3, H-l, H-16)
There is a potential for future sewer needs in
the relatively high density residential area
south of Route 28. Problems of a high water
table and small lots were cited.
Response;
Subsequent to the public hearing on the Draft EIS,
representatives of EPA met with Town and CCPEDC
officials to review sewer needs south of Route 28.
Although the area is not without its problems, it
was generally agreed that a strong program of
non-structural measures could be carried out to
provide adequate public health protection.
Under alternatives F-l-B or F-3-Phase 2 limited
additional sewering may be possible for special
problem areas south of Route 28.
3,2.1.2 Sewage Flows Along Route 28
Comment: (W-9, W-3, W-ll, H-14)
Calculations of water usage along Route 28 show
higher flows than those used in Draft EIS.
Response:
The additional information submitted by the Yarmouth
Water Department tabulates peak-day flows.
Average annual water flows are used as the basis
for designing the proposed wastewater facility.
3.2.1.3 Availability of Federal Funds for
Future Service Areas
Comment: (W-10, H-l, H-16)
Option to sewer additional areas, using Federal
aid, should be available to the Town.
Response;
EPA has advised the Town of Yarmouth in a letter
to the Board of Selectmen, dated 10 October 1979,
that additional funding would be available to
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undertake additional studies of areas not pro-
posed for sewering " to demonstrate as
conclusively as possible the need or lack
thereof of sewers."
3.2.1.4 Investigation of Problems South of Route 28
Comment: (W-7, W-14, W-3)
Additional detailed studies of areas south of
Route 28 should be conducted.
Response:
See answer to 3.2.1.3 above. Additional studies
are now being conducted as part of CCPEDC's 3rd
year 208 funding program.
3.2.1.5 Basis for Service Area Designation
Comment: (W-2)
A number of questions have been raised on the
nature and accuracy of the evaluation used to
designate service areas.
Response;
The basis for sewer service area designation is
covered in Chapter 3 of the Draft EIS.
The conclusions for a limited sewer service area
along Route 28 represent a technical evaluation of
previous studies and additional surveys conducted
as part of the Draft EIS. It represents one of
the most comprehensive evaluations conducted as
part of any wastewater EIS conducted by EPA.
3.2,2 Alternatives
Several comments questioned ability of Barnstable waste-
water treatment facility to handle Yarmouth's long range
wastewater needs.
Others suggested a need to study additional alternatives
including a split alternative of sending only 150,000 gpd
to the Barnstable Wastewater Treatment Facility.
It was contended that the original facilities plan, pro-
posed a smaller scale system than the one identified as the
"Proposed Action" (Alternative 2) in the Draft EIS.
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3.2.2.1 Barnstable Wastewater Treatment Facility
Comment: (W-5, W-7, W-12, H-7)
Will the Barnstable wastewater treatment
facility be able to handle Yarmouth's
long range wastewater needs?
Response:
This comment was answered by the letter
from the Barnstable Board of Selectmen
(W-12) which advised of Barnstable's
ability to accept not more than 150,000
gpd of sewage from Yarmouth.
3,2.2.2 Split Alternative/Other Alternatives
Comment: (W-7, W-9, W-12, W-13, H-l,
H-5, H-16, H-19, W-8)
Additional alternatives should be con-
sidered, including one which would send up
to 150,000 gpd from the West Yarmouth
section of Route 28 to the Barnstable
wastewater treatment facility.
Response:
Additional alternatives have been eval-
uated in the Final EIS (Chapter 1). The
split alternative is one of the alter-
natives recommended for further consider-
ation by the Town of Yarmouth.
3.2.2.3 Facilities Plan Recommendations
Comment: (W-14, H-8, H-9)
It is contended that previous facilities
plan recommended smaller scale system
than the one identified as the "Proposed
Action" (Alternative 2) in the Draft EIS.
Response:
The Environmental Assessment Statement
for "Report on Proposed Sewerage System",
Yarmouth, Massachusetts dated September 1976
states that... "The proposed system would
be based on a year 2000 design flow of
5 million gallons per day". The Draft EIS
has identified this as the "Proposed Action"
or Alternative 2.
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3.2.2.4 Land Requirements
Comment; (W-14)
The Draft EIS has a prejudicial assumption
that land requirements for rapid infil-
tration are equal to land requirements
for spray irrigation.
Response:
The groundwater mounding criteria for
Site D, at rapid infiltration system
design flow rates, result in an appli-
cation area which is approximately equal
to the application area requirements for
nitrogen uptake by reed canary grass
using slow rate irrigation at growing
season flow rates.
In most cases, however, the land area
requirements for rapid infiltration are
on the order of 5 to 10 times less those
for slow rate irrigation.
3.2.3 Septage Disposal
Most of the comments relate to the general unaccept-
ability of the lagooning method of septage treatment
proposed under the preferred alternative (Alternative
3). Additional alternatives and study were recommended,
Septage disposal often was cited as the major problem
in Yarmouth.
Comments both favorable and against the Purifax pro-
cess, as included in the "Proposed Action", Alter-
native 2, were submitted.
3.2.3.1 Lagooning Method
Comment: (W-5, W-7, W-9, W-10, W-13,
W-14, H-l, H-3, H-5, H-7,
H-8, H-13, W-8)
Lagooning is not recommended as desirable
form of septage disposal for Yarmouth.
- 45 -
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Response:
Pursuant to positions stated by
Massachusetts Department of Environmental
Quality Engineering, the Massachusetts
Division of Water Pollution Control and
the CCPEDC, lagooning is not recommended
in the Final EIS.
3.2.3.2 Other Septage Alternatives
Comment: (W-2, W-3, W-10, W-14, H-l, H-3,
H-6, H-8, H-13)
Other alternatives for septage disposal
should be considered to satisfy an urgent
need in Yarmouth,
Response:
The Final EIS has addressed these comments
with a complete evaluation of septage dis-
posal alternatives in Chapter 1. The
option of treating septage in Barnstable
is not viable.
3.2.3.3 Septage Flows
Comment: (W-14, H-18)
Septage flows have been underestimated.
Response:
The Final EIS contains (Chapter 1) a
re-evaluation of septage flows based on a
pumping schedule consistent with the re-
commended non-structural measures which
accompany each of the recommended alter-
natives .
3.2,3.4 "Purifax" Process
Comment: (W-7, W-16, H-8, H-ll)
The "Purifax" process of chemical oxidation
with chlorine is not recommended by some
because of water quality impacts. Others
recommend the process and state the docu-
mentation of adverse impacts was not
adequate in the Draft EIS.
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Response:
A cost evaluation of the "Purifax" pro-
cess has been covered in Chapter 1 of the
Final EIS.
EPA has supplemented its previously stated
concerns about the chlorine oxidation
processes with an internal memo from
Harold P. Cahill, Director of the Municipal
Construction Division dated June 26, 1979.
The memo suggests factors to be considered
when seeking to mitigate any environmental
concerns associated with the process. It
is EPA's opinion that the chlorine oxi-
dation process may be applicable and en-
vironmentally sound under specified criteria,
3.2.4 Non-Structural Measures
Several comments expressed concerns on the EIS
recommendation that there should be some control on
the conversion of seasonal use to year-round use.
Other comments related to chemical pollution and
rehabilitation techniques.
3.2,4,1 Seasonal Home Conversions
Comment; (H-3, H-4)
Suggested controls on seasonal home con-
versions are too much control and a con-
cern to those who purchased seasonal
homes with a future intent to convert
for retirement use.
Response:
The purpose of the proposed controls is
to provide for the upgrading of deficient
on-site wastewater systems prior to
year-round use.
3.2.4.2 Chemical Pollution
Comment; (H-2)
Chemical pollution, such as salt in road-
ways is a major concern.
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Response:
As discussed in Chapter 1 of this Final
EIS and in the Draft EIS, the Town of
Yarmouth should adopt appropriate water
protection measures such as a watershed
protection by law. This,too,is con-
sistent with the Water Quality Manage-
ment Plan for Cape Cod.
3.2.4.3 On-Site Rehabilitation Costs
Comment: (W-2)
Why wasn't the rehabilitation technique,
upon which on-site rehabilitation costs
were based,included in the Draft EIS?
Were any of the systems noted in Appendix
E used to determine rehabilitation costs?
Response;
No specific technique was used. The types
of problems faced by the typical property
were evaluated and estimates were developed
for both simple and complex repairs and
rehabilitation. A weighted average was
used to determine an average cost per unit.
The systems listed in Appendix E were not
used to determine rehabilitation costs. The
forms of rehabilitation and replacement
noted in E.2 of the Draft EIS Appendix are
typical of those which might be anticipated
in Yarmouth.
3.2.4.4 Use of Appendix E
Comment: (W-2)
How was Appendix E information used in
EIS? What is its applicability to Yarmouth?
Response;
The non-structural alternatives information
was developed in support of a need for
strong non-structural program in Yarmouth,
as recommended in this Final EIS and under
Alternatives 3, 4 and 5 of the Draft EIS.
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3.2.5 Water Quality Data
Most of the comments questioned the adequacy of the
groundwater and surface water quality sampling pro-
gram. It was generally felt that more sampling would
be required to produce conclusive evidence of a lack
of pollution due to the operation of on-site waste-
water systems.
3.2.5.1 Adequacy of Sampling Program
Comment: (H-16, W-2, W-7, W-9, W-10)
Sampling program of surface water and
groundwater was not sufficient to make
statement that "the water quality and
sampling program produced no evidence
to link surface or groundwater problems
to on-site disposal systems".
Response:
As noted in the Draft EIS, under Section
5.17, a variety of sources were examined
to evaluate water quality in Yarmouth.
These sources were supplemented by the
sampling of coastal waters, ponds, and
privately owned wells. The well sites
were chosen based on their location and
the willingness of the well owner to
allow the test.
The evaluation revealed no evidence of
widespread water quality problems due
specifically to inadequate on-site dis-
posal systems.
EPA concurs in the several comments
suggesting a continuing program of sur-
face and groundwater sampling to detect
any degradation of water quality by
on-site or non-point sources. (See
Chapter 2 recommendations.)
3.2.5.2 Sampling Program Procedures
Comment: (H-16, W-2, W-7)
Technical questions relating to the
number, depth and criteria for well
location are raised.
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Response:
Within the limits of time and available
funds, wells were located in or down-
gradient from areas suspected of being
a potential source of pollution. A
greater distribution of well sites would
have been desirable, but existing private
wells were not always available in areas
such as those adjacent to Route 28.
A prescribed procedure for running the
water from the well for a specified
period was developed to ensure reasonable
compatability of all well testing efforts.
The parameters measured, within the limits
of available funds, were selected as those
which might indicate actual or potential
degradation in excess of drinking water
standards.
The detection of groundwater pollution
and the specific source of such pollution
is a science which is still in its infancy.
There is a need for checking the trends
of water quality levels over a period of
time in a manner designed, based on
available technology, to relate the effect
to the cause.
3.2.6 Aquifer Protection
Most of the comments related to the potential for
reclassifying the aquifer adjacent to Site D to
below drinking water quality standards.
Other comments discussed water quality impacts,
Purifax system of septage disposal and water
quality impacts of alternatives at Site C and D.
3.2,6.1 Aquifer Classification
Comment; (H-l, H-13, W-l, W-2, W-9,
W-13, W-16, W-18)
Aquifer reclassification adjacent to
Site D possible, according to EPA, but
not recommended by groups on Cape.
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Response;
In view of the possibility for utilizing
the aquifer adjacent to Site D for
future water supply, EPA recommends all
recharge should be at drinking water
standards.
One of the commentors is correct in
noting that there is no classification
of groundwaters in Massachusetts. The
"Water Quality Plan/EIS for Cape Cod"
suggests recommended standards for
groundwater on Cape Cod which are con-
sistent with the recommendation in the
preceeding paragraph.
3.2.6.2 Purifax Impacts
Comments: (H-5, H-13, W-16)
One comment favors the superchlorination
of septage (Purifax) while another group
finds it not acceptable.
Response:
An evaluation of the Purifax septage
process and its cost is included in
Chapter 1.
3.2.6.3 Precautions
Comment: (W-l)
Several recommendations for aquifer pro-
tection are recommended.
Response;
Any future use of Site D will be subject
to additional evaluations of the existing
groundwater hydrology as recommended in
Chapter 2.
As possible, collection systems will be
designed to avoid well field areas.
Where avoidance is not possible, appro-
priate mitigation measures will be
applied (see Chapter 2).
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3.2.6.4 Risks of Continuing Use of On-Site
Systems
Comment: (W-2)
What are risks to groundwater by con-
tinued use of on-site systems?
Response:
The major risks are those associated
with Alternative 1. No Action and des-
cribed in Section 6.712 of the Draft
EIS.
In watershed protection areas lack of
adequate density controls could lead to
annual nitrogen loadings in excess of
drinking water standards. (See page
2-61 of "Water Quality Plan/EIS for
Cape Cod".)
In high density areas and seasonal home
areas, lack of adequate management, re-
habilitation and conversion controls for
on-site systems could lead to increased
nitrogen loadings threatening drinking
water quality. In addition, surface
breakouts or soil saturation with raw
wastewater will constitute a public
health threat and a threat to ground
and surface waters when contaminated
wastewater overflows to catch basins and
surface water bodies.
The alternatives recommended in the Draft
and Final EIS include structural and non-
structural measures to prevent any
threats to groundwater quality.
3.2.6.5 Level of Impact Discussion
Comment: (W-2)
Why were not discussions of hydrological
and water quality impacts in Alternatives
3, 4 and 5 at the same level as for
Alternative 2?
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Response:
Alternatives 3, 4 and 5 of the Draft
EIS were based on a combination of
structural and non-structural measures
designed to preclude any significant
water quality and hydrological impacts.
The criteria described in Chapter 4 of
the Draft EIS provided the basis for
structural designs with minimal impacts.
Consequently, any significant hydro-
logical environmental impacts were pre-
cluded by the criteria utilized to design
the alternatives.
3,2.6.6 Septage Lagoon Groundwater Impacts
Comment; (W-2)
Why was no consideration given to the
effluent characteristics and resultant
groundwater effects of the application
of the lagoon effluent?
Response:
See Section 6.732 of Draft EIS. Based
on experience with existing facilities
in Massachusetts and Connecticut there
has been no groundwater contamination as
a result of the operation of well designed
infiltration/lagoon systems.
Various EPA publications and the New
England Interstate Standards have indi-
cated the suitability of this method of
septage disposal without groundwater
pollution.
As pointed out by the CCPEDC, there
have been recent examples of contamin-
ation where poorly designed or operated
septage disposal pits are in operation.
3.2.6.7 Septage Disposal Sites
Comment: (W-2)
Given the rationale that the septage
"site is not in the area of influence of
any of the municipal wells and thus will
not pose a significant risk to drinking
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water quality" why is the effluent
quality of other alternatives at Site
D a concern?
Response:
The concern relates to the stated desire
(see 3.2.6.1 above) of considering the
aquifer adjacent to Site D as a potential
future source of water supply which is
confirmed by present water quality at
the site. The concurrence of all pub-
licly owned waste treatment systems with
Best Practicable Waste Treatment Tech-
nology is also a prerequisite for funding.
The maintenance of drinking water standards
in the affected groundwater under Site D
would be a BPWTT requirement.
3.2.7 Hydrology
3.2.7.1 Effects on Water Table
Many respondents were concerned about the
impacts of lowering the water table in
the service area by sewering. It was
recognized that the wastewaters from sep-
tic systems are presently contributing to
groundwater recharge within this area, and
that sewers would transport the water to
other locations, resulting in water table
changes. Some respondents were especially
interested in the possible effects of
raising the salt water - fresh water
interface, causing potential future prob-
lems of salt water intrusion at the public
water supply wells.
3.2.7.1.1 Comment: (W-l, W-9)
An evaluation of the transportation and
relocation of wastewaters must be made to
define effects on water table levels in
the Yarmouth service areas.
Response;
Such an evaluation has been made, and the
results indicate minimal effects on water
table elevations within the service area.
As wastewaters are removed by the process
of sewering, the water table will gradually
respond by dropping in elevation to re-
flect the reduction in local recharge
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by septic systems. However, the maximum
long-term decline in elevation would not
exceed six inches.
3.2.7.1,2 Comment: (W-l, W-17, H-4)
A lowering of the water table by even six
inches would result in a rise in the salt
water - fresh water interface by 20 feet.
This may pose possible salt water intrusion
problems for the Town wells.
Response:
If this aquifer behaved purely according
to theory, it is true that a reduction
in water table elevations would be accom-
panied by approximately a forty-fold
raising of the fresh water - salt water
interface. With an average existing water
table elevation in the service area of
approximately five feet, the present inter-
face would be theoretically located nearly
200 feet below sea level. A six inch
reduction in the water table level would
therefore result in a new interface at
about 180 feet below sea level.
With no deep wells of any type within the
service area, this "intrusion" would have
no direct impact on water quality or on
the operation of water supply wells.
Actually, the intrusion would be insigni-
ficant compared to the raising of the fresh
water - salt water interface as a result
of water table drawdown in the vicinity
of typical pumped wells.
More importantly, it should be recognized
that within the service area there is pre-
sently an artificial "mound" of fresh water
and corresponding downward bulge of the
salt water interface. The removal of
this mound by sewering will actually re-
sult in a return to more natural ground-
water and interface elevations and flow
gradients.
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3.2.7.1.3 Comment; (H-4)
A reduction in the water table level in
the service area would cause a higher
flow rate of fresh water towards the
ocean, depleting the aquifer more rapidly.
Response:
There is presently a gradient, or slope,
in the water table from the public well
sites towards the service area, and a
reduction in water table levels in the
service area will increase this gradient
and associated flow rates. However, with
an elevation change of six inches or less,
the impact would be negligibly small,
amounting to flow rate increases of, at
most, several percent. These increases
would be partially, if not entirely,
offset by the decrease in gradient be-
tween the water supply wells and Site D.
Consequently, the net effect will not be
any increase in the depletion rate of
the aquifer.
3.2.7.2 Loss of Water to Barnstable
Several comments pertained to the trans-
port of wastewater to the Barnstable
treatment plant, and the potential im-
pacts on the water supply of Yarmouth.
3.2.7.2.1 Comment: (W-9, W-14, H-15)
Reintroduction of the wastewater into
Yarmouth's groundwater aquifer is critical
to the preservation of this natural
resource. The transport of wastewater
to Barnstable will result in a loss of
water for Yarmouth, and this loss has not
been quantified.
Response;
The replenishment of Yarmouth's ground-
water aquifer is a result of two separate
processes: the natural recharge by the
infiltration of precipitation, and the
general eastward movement of groundwater
across the Barnstable-Yarmouth boundary.
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Considering only the precipitation
recharge component, the transportation
of a maximum daily volume of 150,000
gallons of wastewater to Barnstable
represents far less than one percent of
the average daily recharge. This negli-
gible loss is partially offset by the
positive effects of the Barnstable appli-
cation site on the regional movement of
water towards Yarmouth.
3.2.7.3 Concerns about Site D
Various comments pertained to the hydro-
logy of Site D and the possible hydrologic
impacts of wastewater application.
3.2.7.3.1 Comments; (W-14)
The hydrologic impacts on Site D cannot
be reliably determined since the exact
hydrology of the site is not known. This
is seen by the different conclusions reached
regarding this site at different times in
the EIS process.
Response;
Although modifications of the conclusions
regarding hydrologic impacts of Site D
occurred throughout the DEIS process,
these modifications resulted from the
continual acquisition and analyses of new
data and information. The conclusions
stated in the DEIS represent the final
results of analyses based on the consider-
ation of all available information.
Because there is still a measure of un-
certainty regarding Site D, one of the
conclusions of this report is that addi-
tional hydrologic data should be collected
and evaluated as part of future facilities
planning.
3.2.7.3.2 Comment; (W-14)
A "steady-state" application rate at Site
D equal to design flow overestimates the
hydrologic impacts, since the design
high flow rate is of short duration and
seasonal in nature.
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Response:
Since the EIS has concluded that there
are no adverse hydrologic impacts asso-
ciated with any of the three alternatives,
this comment is moot. Actually, the
hydrologic behavior of Site D was evaluated
using a range of application rates, which
represent both average and peak conditions.
3.2.7.3.3 Comment: (H-8)
The use of Site D would result in a mound
of groundwater which would increase the
fresh water movement towards the Town's
wells. This would provide a greater
reserve of fresh water for water supply
needs.
Response:
The groundwater mound resulting from the
application rates considered in any of
the EIS generated alternatives (Alternatives
3, 4 and 5) would not cause a direct move-
ment of groundwater towards the water
supply wells. It would, however, decrease
the gradient between the wells and Site D,
and retard the natural flow of water away
from the wells. This would have a positive
effect on the management of the groundwater
resources for water supply.
3.2.8 Costs
The comments on costs ranged from cost sharing under
any tie-in to Barnstable to questions about specific
computations and the costs to residential property
owners and businesses.
3.2.8.1 Barnstable Charges
Comment: (W-12)
Town of Barnstable suggests equitable
charges for initial installation and
annual service rate for any tie-in to
their wastewater system.
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Response:
Barnstable's concerns have been reflected
in the revised cost estimates for the new
alternatives included in Chapter 1 of
this Final EIS.
3.2.8.2 Cost of Rehabilitation
Comment: (H-3)
Who is going to pay for cost of rehabili-
tating on-site residential systems? Where
is cost effectiveness?
Response:
The cost effectiveness is borne out by
the computations included in Table 3-2 of
the Draft EIS. The analysis indicates
that over a period of years, sewers would
be eleven times more expensive than a
program of maintenance and repair of
on-site systems.
There may be areas on the north side of
Yarmouth where clustered septic systems
may be more cost effective than individual
rehabilitation. The need for such systems
would be determined as part of any addi-
tional facilities planning.
Federal funds are now available for assis-
tance in the rehabilitation of on-site
residential systems and the construction
of a clustered septic system for several
homes. The Town's eligibility for these
funds would be determined as part of the
facilities planning process.
3.2.8.3 Cost to Businesses on Route 28
Comment: (H-13, H-15, H-17)
What will be financial impact of businesses
along Route 28?
Response;
Several of the specific questions were
answered at the hearing.
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As noted 6.734 of the Draft EIS, business-
men along Route 28 would be impacted by
the proposed sewering under Alternatives
3, 4 and 5. The average cost of sewering
Route 28 businesses, however, would be
less under sewering than under the strict
program of septic system maintenance and
repair proposed in Chapters 1 and 2 of
this Final EIS.
An additional cost would be the tax rate
increases associated with an enlarged
Board of Health inspection and maintenance
staff.
3.2.8.4 Accuracy of Table 3-2
Comment: (W-14)
A number of questions are raised on the
accuracy of the figures included in
Table 3-2 (Cost Analysis of On-Site Dis-
posal Systems Versus Town-Wide Sewers)
and a revised Table 3-2 was presented.
The table showed that sewers are only 3
times more expensive than on-site disposal
rather than the 11 times more expensive
when the cost figures presented to the
Facility Plan are used. Further, the
writer demonstrates that when an 80%
initial repair rate and future annual
repair rate of 10% are used (when con-
sidering residences south of Route 28)
then sewers are 25% cheaper.
Response:
The writer neglected to bring the salvage
values back to present worth and thus the
apparent discrepancies. Using the costs
from the Facilities Plan without increasing
them to account for construction cost in-
creases over the last few years is erroneous
3.2.9 Miscellaneous/Corrections
In addition to those comments which fall into well-
defined categories there were a number of wide-
ranging questions which defy categorization. These
miscellaneous comments are responded to in this
section.
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3.2.9.1 Comment: (H-12)
How many people can be safely put on the
Cape as far as water and sewerage?
Response;
This is a difficult question which was
answered in part at the hearing by a
representative of the Cape Cod Planning
and Economic Development Commission.
To a certain extent the answer depends
on the actions of the individual towns.
If/through poor controls,a town allows its
water supplies to be degraded, there could
be a reduction in the population safely
supportable by local water supplies.
The recommendations of this Final EIS are
directed at the protection of Yarmouth's
water resources through structural and
non-structural measures. These recommend-
ations would be consistent with the stated
growth objectives of the Town of Yarmouth.
3.2.9.2 Comment: (H-16, W-10)
More data on the slow rate land application
method of wastewater at Site D is requested,
Specific areas of concern are airborne
infection, odors and examples of practical
use.
Response;
The form of land application proposed for
Site D is known as the surface flooding
technique. This technique, when operated
in accordance with EPA's design criteria,
minimizes any potential health hazards
or odors.
In 1972, EPA estimated that from 570-950
municipalities with a population of about
7,000,000 were served by land application
systems. One nearby facility is located
at Otis.
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3.2.9.3 Comment: (H-18)
The Draft EIS gives no attention to
the marketability of the crops which
take up the nutrients.
Response:
The financial analysis assumed no market
for the crops. Potential markets include
fodder for livestock or use as an erosion
control material subject to approval of
local and state health authorities.
3.2.9.4 Comment; (H-20)
What will happen to Route 28 as a result
of sewering?
Response;
As noted in the Draft EIS, the sewering
of Route 28 will act as an inducement
for more rapid development.
3.2.9.5 Comment: (H-21, W-15)
A request for additional study time was
requested.
Response:
This request was granted pursuant to a
letter request from the Town of Yarmouth.
(See section 3.9.1.13 below.)
3.2.9.6 Comment: (W-2)
Sewers can solve different problems than
septic systems.
Response:
Properly designed, maintained and spaced
septic systems function in the same way
as a wastewater collection and treatment
facility. Where there are constraints of
high density and/or water usage, poor soils
and high water tables, sewers provide a
solution not generally achieved by on-site
systems.
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3.2.9.7 Comment: (W-2)
A better discussion of the water bodies
potentially affected by the use of Site
D is required.
Response;
The information available on the ground-
water hydrology at Site D, the rates and
concentration of wastewater application
and the characteristics of surrounding water
bodies indicates that under Alternative 4
there will be insignificant long term ad-
verse impacts on water quality. Further
detailed evaluations of impacts will be
dependent upon the Site D studies called
for in Chapter 2.
3.2.9.8 Comment: (W-2)
A NO., - N concentration of 10 mg/1 (the
drinking water standard) will adversely
affect a small tidal stream.
Response:
See response to 3.2.9.7 above.
3.2.9.9 Comment; (W-2)
Mistakes in Tables D-l and D-2 are noted.
Response:
The Kjeldahl level of 696 mg/1 for Site
G-4 in Table D-l should have been aster-
isked as not reportable.
The Kjeldahl level of 133 mg/1, for Site
SA-3-B in Table D-2 is correct as reported.
3.2.9.10 Comment; (W-4)
Federal Energy Regulatory Commission does
not find any significant impacts in their
area of concern,
Response:
None of the evaluated alternatives have
significant energy impacts.
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3.2.9.11 Comment: (W-6), (W-18)
Additional information on archaeological
and historic impacts is requested. Im-
pact on the Kings Highway Local Historic
District is requested too.
Response:
Further archaeological investigations of
Site D pursuant to the specifications of
the Massachusetts Historical Commission
will be conducted as part of additional
facilities planning for the project.
The alternatives recommended in this Final
EIS will have no impacts on the Kings
Highway Local Historic District.
3.2.9.12 Comment: (W-7)
Recommendation that EPA provide additional
guidance in preparing final Step 1 facility
plan is made.
Response:
See Chapters 1 and 2 of this Final EIS.
3.2.9.13 Comment: (W-8)
Extension of time for written comments
made by Town of Yarmouth.
Response:
EPA granted the extension.
3.2.9.14 Comment: (W-12)
Town of Barnstable is concerned about
impact on businesses and residents of
constructing a sewer force main in Route
28.
Response:
Any sewer construction along Route 28
will have a temporary adverse impact to
residents and businesses in both Yarmouth
and Barnstable. Construction scheduling
should coincide with periods of low
traffic flow and reduced business activity
along Route 28.
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3.2.9.15 Comment: (W-14)
The significant adverse rating of
Alternative 2 on "natural systems" and
sensitive areas is disputed.
Response:
The major reason for the significant im-
pact is the anticipated flow of incom-
pletely purified wastewater to adjacent
surface waters.
3.2.9.16 Comment: (W-14)
Ratings of impacts are subjective and
arbitrary as they relate to water quality.
Water table downstream of application
sites under Alternatives 3 and 4 would
require reclassification.
Response:
Under Alternatives 3 and 4, reclassification
of groundwater to below drinking water
standards would not be required. Such a
reclassification would be required under
Alternative 2. This and other factors
cited in the Draft EIS account for the
significant impacts assigned to Alternative
2.
3.2.9.17 Comment: (W-17)
What agency will be responsible for deter-
mining conditions under which seasonal
homes can be converted to year-round use?
Response;
The designation of an agency would be the
responsibility of the Town of Yarmouth.
In the instance of on-site wastewater
systems it would be appropriate for the
Yarmouth Board of Health to determine the
adequacy of the existing system to serve
greater usage over a longer period of time,
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APPENDIX A
LETTER FROM EPA TO YARMOUTH
BOARD OF SELECTMEN REGARDING NEW ALTERNATIVES
A-l
-------
% «w^
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F- KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203
1 0 OCT 1379
Board of Selectmen
Town Hall
Yarmouth, MA
Dear Sirs:
RE: Town of Yarmouth
E.I.S.
I am writing as a follow-up to our neeting of September 20, 1979 with
Mr. Bob Law ton, Mr. Ralph Cipoila and Mr. John Sears. During the past
two weeks this office has received several calls frora your 201 consul-
tant, Whitman & Howard, relative to the discussion which took place during
the meeting. The majority of the conversations centered upon the three
wastewater disposal alternatives which were presented and which we indicated
would be included in the final Environmental Impact Statement (EIS). In
order to insure that no confusion exists with respect to these alter-
natives, I will outline ichem here.
Alternative No. 1 - As recoronended in the Draft EIS, the commercial strip
on Rt. 28 will be sewered and the wastewater collected will be treated
with septaga frcm the remainder of the Town and the Town of Dennis at
site D. This alternative is workable with or without 150,000 gpd being
transported to Barnstable. However, the Barnstable option is the desired
one. An additional major element, within this alternative is the institution
of a strong on- lot system management program for the remainder of the
community.
Alternative No. 2 - The design and construction of a septage treatment
facility at site D in 'conjunction with a strong on- lot system management
program including some very positive controls within the previously
proposed sewered area on Rt. 28
Alternative No. 3 - The immediate design and construction of a septage
treatment facility at site D which would be compatible with a future
wastewater facility should non-sewering measures in the Rt. 28 area not
be satisfactory. This alternative is completely contingent upon the type
of septage treatment facilty recommended and more specifically whether or
not it could be converted into a combination septaye/wastewater treatment
facility. As with previous alternatives a major element of this alternative
is a strong on-lot system management program. An evaluation of septage
treatment is being conducted by the EIS consultant now and will be presented
in the final EIS.
It should be noted that additional step 1 work centered around on-lot system
rehabilitation could be done in conjunction with all three of the above
alternatives. However this work would be limited to specifically identified
problem areas.
-------
Finally, an additional option is available to the Town should you be convinced
that specific areas of Town not identified in the EIS, will need scwars in the
near future and that sufficient capacity is not available within the 500,000
gpri capacity at site D. Under this scenario this office would fund additonal
step 1 work in those areas to demonstrate as conclusively as possible, the need
or lack thereof of sewers. This Step 1 work would take place prior to the
initiation of action on any of the other alternatives and would still allow the
Town to receive reimbursement of previous step 1 work.
With regard to the reimbursement of previous step 1 work costs we remind you
again that the regulations only allow same if a grant is awarded prior to April
1, 198C. We recognize this places the Town in a position of having to move very
rapidly once the EIS is completed to avoid the loss of these monies. We have dis-
cussed this matter with our Headquarters people in Washington and they indicate
thac. they would give consideration to the granting of a deviation from this
particular regulation (40 CFR 35.925-18 (a}(3)). Therefore, I recommend that
the Board of Selectmen request a deviation in writing from this office as soon
as possible. The request should include a brief history of the project; a dis-
cussion of the current status including the fact that an SIS is ongoing and a
discussion of the constraits which may preclude the Town from meeting the April
1, 1980 date. We will forward your request with a memo of support to Washington.
At the previously referancsd meeting we promised to provide you with a breakdown
of the various wastewater flows as set forth in the EIS. The following is that
information.
Projected
Wastewater Flow Initial Design
(Rt. 28 Coirm. Strip) (mgd) (mgd)
Average Annual 0.21 0.24
Summer Average 0.32 0.36
Winter Storage at Site "D" 14.4mg 16.2mg
Design application rate
with all flow to Site "D" 0.37 0.42
(Reserve Treatment Capacity)* (0.13) 0.08
Design Application Rate
with 150,000 gpd to Barnstable 0.23 0.29
(Reserve Treatment Capacity)* 0.27 0.21
*500,000 gpd site D capacity minus the design application rate
I hope the above will be useful in your task of determining what steps the Town
of Yarmouth should take next. If you require any additional information and/or
assistance do not hesitate to call Daniel Coughlin at (617) 223-7214.
Sincerely yours,
Anthony 7. DePalraa, Chief
MA Engineering Section
Municipal Facilities Branch
cc: MA WRC - EIS Office - Robert Lawton
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APPENDIX B
LETTER FROM USGS TO EPA
REGARDING HYDROLOGIC STUDIES AT SITE D
B-l
-------
United States Department of the Interior
GEOLOGICAL SURVEY
Water Resources Division
150 Causeway Street, Suite 1001
Boston, Massachusetts 02114
August 17, 1979
Mr. Robert Mendoza
Environmental £ Economic Impact Office
U. S. Environmental Protection Agency
John F. Kennedy Federal Bldg.
Boston, MA 02203
Dear Mr. Mendoza:
This letter is in response to your request for a description of the scope
of work required to determine the hydrologic impacts of applying as much
as 1.5 million gallons per day of sewage effluent on a proposed site in
Yarmouth, Massachusetts. The site known as "site D" is located south of
Buck Island Road and west of Parker's Mill Stream.
A digital modeling approach would seem most appropriate. The prediction
of ground-water level changes is dependent on complexly interrelated
hydrologic properties and physical parameters specific to the site. Any
one of several computerized mathematical solutions to the ground-water
flow equation could be used to simulate hydrologic conditions at the site.
Adapting these computerized solutions to the site, modeling, consists of
identifying and assigning boundaries, hydrologic conditions of inflow and
outflow, and aquifer properties to tne site. Boundaries can be categorized
as impermeable or no flow, constant head (recharge or discharge) and "leaky"
or partial flow. Physically these are clay or till layers, ponds, streams,
or bogs. Inflow and outflow quantities such as natural recharge, discharge,
pumping and effluent application rate, aquifer hydraulic conductivity,
thickness and storativity must also be input in the modeling process.
After calibration, fine tuning or adjusting the numerical representations
of these physical parameters, the equations can be solved by a computer to
predict the new water-table elevations that would result from different
effluent application rates.
The descriptions of the boundaries and properties of the aquifer to form
the model must depend on measurements made at the site. Hydrologic
interpretation of the physical features of the site requires study by
qualified hydrologists. Examples are the identification of a pond as a
constant head boundary or a clay layer as a no-flow or leaky boundary.
ONE HUNDRED YEARS OF EARTH SCIENCE IN THE PUBLIC SERVICE
-------
Mr. Robert Mendoza - 2 - August 17, 1979
Lateral distances can be obtained with sufficient accuracy from maps;
vertical distances (altitude) must be measured by precise leveling to
0.1 foot accuracy. Test holes and wells are required to obtain
subsurface information, including lithologic samples and altitude of
the water table. Lithologic samples can be used to estimate aquifer
hydraulic conductivity and storativity. An aquifer test can be made
by mathematical analysis of water-level response in several observation
wells to pumping to compute hydraulic conductivity, storativity, and
anisotropy of hydraulic conductivity of the aquifer at the site.
Incidentally, recharge rates have been estimated for the area of concern
by the U. S. Geological Survey.
Field data collection for such an analysis (without the aquifer test)
would probably require: installation of about 6 shallow welIs; drilling
and lithologic sampling of one hole at the center of the site to about
200 feet deep; measuring surface-water levels at about 25 locations and
ground-water levels in about 6 wells to within 0.1 foot; and probably
some 10-foot deep backhoe holes for determination of soil permeability.
Laboratory sieve analyses of the lithologic samples would provide size
and sorting data to estimate hydraulic conductivity and storativity.
A study of this type is site and design specific and seems to be in the
field of the private hydrologic consultant. If a suitable consultant
is not available, the Survey could possibly do the modeling analysis
under our interagency agreement with EPA. However, we do not have the
manpower available to collect the required field data. We could provide
guidance for EPA's consultants for both data collection and modeling
analysis. In the long run, it will be advantageous to encourage the
development of demonstrated and acknowledged competence for this type
of hydrologic work in the private sector in this region.
For the District Chief, John A. Baker:
Sincerely yours,
Michael H. Frimpter
Chief, Hydrologic Studies
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APPENDIX C
WRITTEN COMMENTS ON DRAFT
ENVIRONMENTAL IMPACT STATEMENT
C-l
-------
LIST OF WRITTEN COMMENTS ON
DRAFT ENVIRONMENTAL IMPACT STATEMENT
Comment No.
W-l
W-2
W-3
W-4
W-18
W-5
W-6
gource Date
FEDERAL AGENCIES
EPA - Water Supply Branch 6/14/79
EPA - Water Quality Branch 4/23/79
EPA - State Coordinator 5/25/79
Federal Energy Regulatory Commission 4/18/79
Department of the Interior 6/1/79
STATE AGENCIES
Massachusetts Department of 5/18/79
Environmental Quality Engineering
Massachusetts Historical Commission 4/10/79
W-7
REGIONAL AGENCIES
Cape Cod Planning and Economic
Development Commission
6/8/79
W-8
W-9
W-10
W-ll
W-12
LOCAL AGENCIES
Yarmouth Board of Selectmen
Yarmouth Water Quality Advisory
Committee
Yarmouth Health Officer
Yarmouth Water Department
Barnstable Board of Selectmen
{5/11/79
-(6/12/79
(1/28/79
C/12/79
5/21/79
5/30/79
6/20/79
C-3
-------
List of Written Comments on Draft Environmental Impact Statement
(continued)
Comment No,
W-13
W-14
W-15
W-16
Source
ORGANIZATIONS
Association for the Preservation
of Cape Cod
Whitman & Howard
Yarmouth Taxpayers Association
BIF
Date
5/21/79
6/11/79
5/18/79
6/12/79
W-17
INDIVIDUALS
T.T. Chiang
6/11/79
C-4
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W-l
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATEJune 14, 1979
SUBJEClPraft EIS Review, Yarmouth Wastewater Collection and Treatment Facilities
FROM.Steven J. Koorse, Sanitary Engineer _
Water Supply Branch
TO-Kenneth Wood
Environmental and Economic Impact Office
The Yarmouth, Massachusetts wastewater collection and treatment facilities
draft EIS (DEIS) has been reviewed and a discussion of acceptability in
relation to water supply considerations follows.
The various wastewater treatment techniques under consideration for each
wastewater management alternative are presented in a limited detail by
the DEIS. As such, the specific sites rather than the actual wastewater
management technique associated with each site were evaluated with respect
to potential impacts to water supply quality.
Site "D"
Site "D" appears to have a positive potential for use in a land application
scheme. The hydrologic analysis conducted by Anderson-Nichols and Co., Inc.
indicates that the direction of groundwater flow at this site, under natural
background conditions, is southerly. A scenario depicting resultant ground-
water table levels as a result of a 1-1.5 MGD slow rate wastewater land
application system indicates an increasing trend in groundwater movement
towards the East. Another scenario depicting the effect of a five (5) MGD
flow rate yielded an indication of a significant mounding effect which could
significantly alter natural groundwater flow patterns. As such, with respect
to water supply quality, site "D" is suitable for wastewater and/or septage
land application under the following conditions:
1. All hydrologic effects attributable to wastewater flows projected to
exceed one (1) MGD should be identified and assessed to create no
adverse impacts to water supply prior to expansion of the system
above that level.
2. The proposed wastewater and/or septage management technique, once
developed, will need to be reviewed from a water supply perspective.
The DEIS only evaluates the effects of a slow rate land application
system on groundwater flow at site "D"; the hydrologic profiles
presented are consequently only valid for this method. Thus, any
modification in the treatment process should be accompanied by an
applicable predictive analysis which indicates no adverse impacts
on water supply.
EPA Form 1320-6 (Rev. 3-76)
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-2-
3. The aquifer area underlying site "D" has no development potential
as a drinking water supply. As such, assuming that acceptable
constraints are placed upon both ultimate flow rate and treatment
techniques, as discussed in the comments above, no adverse impacts
on any existing or potential water supply wells are expected.
However, two important considerations should be addressed:
a. Monitoring Requirements.
Monitoring wells should be sited in a manner such that
the trend of attenuated wastewater flow can be tracked.
Site selection should be conducted in order to collect
information which would serve to verify predicted trends
of groundwater flow, detect any developing threat to
existing or potential water supply wells, and provide a
data base which could be useful in assessing the impacts
of an increased flow rate to the land application system
should the need develop.
b. Alternative Waste Management Techniques for Best Practicable
Waste Treatment (BPWTT) Classification.
Investigation of the land use characteristics of the area
underlying the groundwater aquifer which would convey the
attenuated wastewater and/or septage from site "D" toward
Nantucket Sound, indicates that there is no land available
with the potential for well field development. In addition,
there are no existing water supply wells in this area. As
such, a Case III determination is appropriate. However,
the boundaries of the Case III area should be specifically
delineated. Furthermore, in accordance with the BPWTT
regulations, monitoring requirements reflecting these
boundaries should be developed. Coordination of consider-
ations from both a surface water quality standards and National
Interim Primary Drinking Water Regulations viewpoint will be
necessary in order to delineate the Case III boundaries.
Site "C"
Hydrogeologic conditions at site "C" are not described in sufficient detail
to evaluate its acceptability as a land application alternative. Since AWT
and rapid infiltration are proposed as the treatment technique to be employed,
rather than primary or secondary followed by a slow rate system, it must be
presumed that the additional land requirement attributable to a slow rate
system diminishes its cost effectiveness. In any case, the discussion in
the DEIS appendix concerning mass transport of nitrate-nitrogen in the
aquifer following AWT is not presented in sufficient detail to evaluate its
validity.
For all wastewater management alternatives under consideration where waste-
water is collected and transported rather than discharged on-site, an
evaluation of the effects this relocation might have on water table levels
and the associated decrease in depth to the saltwater diffusion zone should
be presented. This includes relocation to a centralized land disposal area
as well as relocation to the wastewater treatment facility in Barnstable.
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-3-
Any wastewater management alternative selected which incorporates a
wastewater collection system should take the necessary precautions to
establish a route which avoids existing or potential well fields. If
this is not possible, the risks of locating an interceptor through an
aquifer area which could influence a water supply well should be mini-
mized (e.g., ductile iron pipe with sealed joints).
If there are any questions with regard to the comments above, feel free
to contact me at x6486.
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DATE:
SUBJECT:
W-2
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
April 23, 1979
Yarmouth, MA Draft EIS
TO: Wallace E. Stickney
EIS Office
FROM: Donald R. Smith, Acting Chief
Water Quality Branch
We have reviewed the "Draft Environmental Impact Statement for Wastewater
Collection and Treatment Facilities, Yarmouth, Massachusetts." Our comments
are as follows:
Chapter 0
0.32
0.33
0.44
Why are there pumpings and repairs and what were the repairs? What
is the basis on which the conclusion was drawn that the link between
water quality problems and septic systems is not evident? What
evidence would prove it? Are the soils data sufficient to indicate
high groundwater?
How will more frequent well sampling indicate a source of pollutant
increase?
How many samples were taken and at what depth to support the contention
that there is no groundwater contamination attributable to failing sys-
tems along Route 28?
Could the Barnstable septage handling units be expanded to allow Yar-
mouth to be served? The final 208 recommendation for Yarmouth's septage
is for combined wastewater and septage treatment if feasible. If not,
composting is recommended.
The discussion, as presented, does not follow logically. If spray
irrigation at Site D reduces nitrates to USPHS drinking water standards
why would AWT be needed at Site C?
This section implies that the standards have been established down
gradient of Site D. This is not the case.
This section presents an inappropriate comparison. Sewers can solve
different problems (i.e.nutrients reaching ground and surface waters) than
septic system maintenance which is more geared towards precluding
"failures."
Chapter 1 - No comments
Chapter 2 - No comments
0.46
0.522
0.523
CONCUWEMCtf _
'MBOL h
ffiNAME)
,T. >
W&
&!/«#??:...
if^7f
nte. ........
&Abr....
1-/2+/7?
A Fom 1320.1 (12-70)
OFFICIAL FILE COf t
-------
-2-
Chpater 3
3.13 On page 89, it is incorrectly stated that 33 wells were sampled. Also
indicated on that page, is that most of the wells "are no longer in use."
Here it states that the wells are "active." Since 99% of the residents
are on town water, the former seems correct. Incidentally, the element
sampled for is "phosphorus" not "phosphorous." Where are the town wells?
3.24 What were the nature of the repairs? Why were they needed?
3.26 How many people were surveyed face-to-face?
3.27 How deep were the samples taken? The converse to the statement made
is that there is no evidence not to link these problems to the failure
of on-site disposal systems. The Draft Water Quality Management Plan/
EIS for Cape Cod used 0.0-0.4 rag/1 nitrate - nitrogen as "background."
Based on that, 35 samples of the 61 reported, exceeded background.
"3.31 Continued testing at the same wells won't identify the source. Can
the septic systems be enlarged south of Route 28? If enlarged, how
will groundwater quality problems be avoided?
Table 3-2 Can the .needed on-site repairs be made given the small lots
south of Route 28? What type of repair is needed whose cost is $2000-
$2500? How was this type of repair determined?
3.4 Why is the South Shore Drive area considered a potential service area
while area //4 seems to have a higher pumping, repair and problem per-
ception rate? Other areas are also higher and adjacent to the "needs
area".
Chapter 4
4.51 The future service area seems to ignore areas just as needy.
4.61 Could the Barnstable units be expanded to accept Yarmouth's septage?
What is the difference between septage pits and the settling/infiltration
portion of this proposal in terms of nutrients leaching into the ground-
water? Will the lagoon be aerated? What is meant by "clean water"?
4.71 The nitrate-nitrogen standard applies only to groundwater which has
received a Case I or Case II determination. Since there has been no
classification of the groundwater potentially affected by wastewater
applied at Site D, EPA is not reclassifying it!
4.72 Region I has no need to amend its criteria since the criteria applies
to the "ground water resulting from the land application of wastewater,
including the affected native ground water." What is the objective of
the proposed amendment?
4.731 The 400 Ibs. - N/acre/yr would result in a 14.5 mg/1 concentration in
the effluent applied, The assumption given in Section 4.72 is 20-30
mg/1. However, reed canary grass has removed (by harvesting) up to
approximately 350 Ibs - N/acre/yr. In this case then, two wrongs may
-------
-3-
make a right! How will the crop be disposed of after harvesting? Is
there a feasible market?
4.76 Again, 'reclassif ied" is incorrect terminology.
4.813 Why is there no consideration given to the effluent characteristics
and resultant groundwater affects of the application of the lagoon
effluent?
Chapter 5
5.17 Are the public water supply wells #4 and #5 indicated as G-4 and G-5?
The groundwater data are presented in Appendix I), not B. What criteria
was used to insure that the sampling program "was specifically designed
to locate on-lot waste water disposal system failures"? A high rate
of system repairs are indicated on Figure 6 south of Route 28 between
Berry Avenue and South Street. Yet only one groundwater sampling point
was used.
5.171 Please see the comment on Section 3.27. The first conclusion drawn
from the data should not be that the groundwater is of very high
quality.
What evidence indicates a correlation between rising nitrate levels and
the storm drainage system?
There needs to be a better discussion of the water bodies potentially
more directly affected by use of Site D, i.e. Plashes Brook, Seine Pond,
and Parkers River. Included in the discussion should be an estimate
of streamflow in Plashes Brook, tidal influences on Parkers River and
Seine/Swan Pond and a general discussion of the uses now made of those
waters (recreation, shellfish, fish, etc.). This is important in light
of the fact that Section 6.742 indicates flow towards these waters but
does not mention any surface impacts. Since Seine Pond shows "signs of
eutrophication" the impact of any additional nutrients which may result
from use of Site D (by whatever rate of application) should be assessed
and the rationale behind that assessment presented.
5.172 This is an inadequate discussion of the potential effects of septic systems
on surface waters.
Figure 13 It appears that town wells #4 and #5 are not G-4 and G-5, thus no
sampling data on them are presented in this report.
Chapter 6
6.172 What are the risks to groundwater by continued use of on-site systems?
6.721,2, & 9 These sections present the type of discussion which should be
included in the evaluation of Alternatives 3 and especially 4 and 5.
Specifically, why were not statements included in the evaluation of
those alternatives that the resultant groundwater would or would not
affect down-gradient surface water quality?
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-4-
6.742 Using this section as an example of the previous comment, the level of
detail and rationale is poor. The last paragraph indicates no plans
for use as a water supply but the process is judged against' drinking
water standards. In addition, this discussion implies that if drinking
wate standards are met, no problems are anticipated. However, a N03~N
concentration of 10 mg/1 (the drinking water standards) will adversely
affect a small, tidal stream. This potential impact has been ignored.
Appendix C
C.62112 Why wasn't the rehabilitiation technique presented upon which the
figures must be based?
C.623 Given the rationale that the septage "site is not in the area of influence
of any of the municipal wells and thus will not pose a significant risk
to drinking warter quality", why is the effluent quality of other alter-
natives at Site D a concern? Since there would be little mixing of the
effluent with the groundwater, volume should not be the only criteria
used to determine site viability or treatment requirements.
Appendix D
Table D-l Site G-4 has a Kjeldahl level of 696 mg/1 presented which must be
a typo.
Table D-2 Similarly, the 133 mg/1 Kjeldahl level at Site SA-3-B is probably
a typo.
Given the high nitrate levels at Sites SA-8 through SA-13, inadequate
investigation of the potential sources is made.
Appendix E
The use made of this "literature" in the development of the EIS is not at
all clear. What is the applicability of these systems to Yarmouth? Were
any of them used to determine rehabilitiation costs?
In general, the two weakest portions of the EIS are the assessment of sewer
needs and the impacts of intown alternatives on surface waters. The existence
of elevated nitrate levels in both surface and groundwaters has been minimized.
Since the service area and resultant flows are the key to the disposal site
and technique, it seems to be on quite an unsure basis that the alternatives
have been determined.
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W-3
DATE:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2 5 MAlf 1979
SUBJECT-. Yarmouth, MA - Environmental Impact Statement
FROM: Daniel J. Coughlin
MA State Coordinator - MA Engineering Sectio
T0: Robert Mendoza
Environmental and Economic Impact Office
6/61 9
EPA For,,, 13?n / (Rr» 3 741
Based upon the comments received at the official EIS hearing held on
May 21, 1979, it is apparent that some additional work must be done
before the subject E.I.S. can be finalized. In my opinion, the
following areas must be evaluated in further detail:
1. Septage Treatment - It is unfortunate that this matter
received so little evaluation, on the part of the consultant.
Practically everyone who has offered any comment on the draft
EIS has objected to the Lagoon process. I recommend that the
consultant be directed to evaluate other septage treatment
processing such as composting, lime stabilization, and con-
ventional aerobic treatment. If the Lagoon process is to be
recommended above any of these, the reasoning for its selection
must be detailed particularly with respect to the environmental
and aesthetic issues. One major inconsistency which to date
has not been noted pertains to the effluent quality of the
posposed septage treatment facility. If we must concern our-
selves with meeting drinking water standards with the proposed
land application system (unless a case 3 determination is made
under the BPWT regs.), then we should be equally concerned with
the septage treatment facility. Finally, if we do recommend
that a septage treatment facility be built at site D, we should
document why this site is superior to the dump site recommended
in the Town's Facilities Plan.
Needs Survey and Proposed System's Capacity - (a) The needs
survey completed as part of the E.I.S. has been the subject of
widespread criticism to include the Board of Selectmen and the
208 Agency. It is their contention that areas exist, primarily
south of RT 28, where the groundwater is within 2-3 feet of the
ground surface. This of course causes problems with on-site
wastewater disposal systems. I recommend that, with the assist-
ance of recent 208 work, a further needs investigation be con-
ducted in these areas.
(b) Mr. Paul Wilson of the Town's Water Department has claimed
that the projected flows from the RT-28 area are low. His
analysis results in flows of about 750,000 gpd. Since the
basis of our flows is the Town water department's records, it
is important that this matter be resolved. I suggest a meeting
be held between Mr. Wilson, A&N staff, and ourselves as soon as
possible.
-------
Yarmouth, MA
Page 2
The Town's Health Agency and the 208 Agency has questioned,
on several occasions, the validity of the conclusions drawn
from the Water Quality survey program. The EIS should provide
additional discussion as to how the conclusions were drawn.
Of particular concern to the Town were elevated colifonn
counts in Swan Pond and Long Pond. Additionally, the means
of determining that nitrate levels in the ground water would
not exceed 10 mg/1 as a result of continued use of septic
tanks should be included in the Appendicies.
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W-4
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, D.C. 20426
2 4 1979
April 18, 1979
William R. Adams, Jr.
U.S. Environmental Protection Agency
Region 1
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. Adams:
I am replying to your request to the Federal Energy
Regulatory Commission for comments on the Draft Environmental
Impact Statement for the Yarmouth, Massachusetts Wastewater
Facilities. This Draft EIS has been reviewed by appropriate
FERC staff components upon whose evaluation this response is
based.
The staff concentrates its review of other agencies'
environmental impact statements basically on those areas of
the electric power, natural gas, and oil pipeline industries
for which the Commission has jurisdiction by law, or where
staff has special expertise in evaluating environmental impacts
involved with the proposed action. It does not appear that
there would be any significant impacts in these areas of concern
nor serious conflicts with this agency's responsibilities
should this action be undertaken.
Thank you for the opportunity to review this statement.
Sincerely,
-^ Jack M. Helinemann
Advisor on Environmental Quality
-------
W-5
Commissioner
PAUL T.ANDERSON
Regional Environmental Engineer
May 18, 1979
22*979
YARMOUTHWastewater Collection and
Treatment Facilities, Environmental
Impact Statement
Mr. William R. Adams, Jr. RE:
Regional Administrator
U.S. Environmental Protection Agency
Region I, J.F.K. Federal Building
Boston, Massachusetts 02203
Dear Mr. Adams:
Please be advised that the Department of Environmental Quality Engineering
has had an engineer review the subject impact statement to determine whether the
proposed alternative? (5) are in compliance with present Massachusetts Regulations
and Department Policy.
The Department is of the opinion that "Alternative 3 - Barns table", which is
the preferred alternative of the EIS, is not the proper choice for a long term
solution to the wastewater problems of Yarmouth. First, it is questionable
whether the Barnstable STP can handle the additional sewerage from W. Yarmouth.
Secondly, and of most importance is the proposal for septage disposal by means
of anerobic lagoons. The Mass. Department of Environmental Quality Engineering is
the state agency responsible for approving such a facility and has done so in the
past_only as a short term solution to an immediate problem. Anerobic lagoons
require constant maintenance, they need extensive buffer zones between residential
areas and must be so located as not to endanger public or private water supplies.
The Department of Environmental Quality Engineering would like to go on record
as being opposed to anerobic lagoons as a long term solution to the septage problem
and is of the opinion that it has no place in a facilities plan.
Very truly yours,
For the Commissione
A/lp/RPF
Paul T. Anderson, P.E.
Regional Environmental Engineer
cc: Division of Water Pollution Control
110 Tremont Street
Boston, Mass.
ATTN: Brian Jeans
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W-6
COMMONWEALTH OF MASSACHUSETTS
Office of the Secretary of State
1ASSACHUSETTS
HISTORICAL
COMMISSION
MICHAEL JOSEPH CONNOLLY
Secretary of State
"
294 Washington Street
Boston, Massachusetts
02108
617-727-8470
10,
Mr. Robert C. Thompson
Regional Administrator
United States Environmental Protection Agency
Region 1
J.F. Kennedy Federal Building
Boston, Massachusetts 02203
Re: Wastewater Collection and Treatment Facilities, Yarmouth, MA.
Dear Mr. Thompson:
The Massachusetts Historical Commission and the State Archaeologist
have reviewed the Draft Environmental Impact Statement prepared for
the Wastewater Collection and Treatment Facilities in Yarmouth. The
draft does not contain sufficient background information for MHC to
evaluate the potential impacts to historic and archaeological resources.
We do not have a copy of any archaeological/historic survey in our files.
Specifically, the MHC will need information on how the proposed System
will effect the Kings Highway Local Historic District, which may be
eligible for listing in the National Register of Historic Places. In
addition, the MHC and the State Archaeologist will need more informa-
tion regarding the potential for historic and prehistoric archaeolog-
ical sites in the impact area. Walkover surveys are generally not
sufficient to determine the presence or absence of sites.
If you have any questions, please contact Val Talmage, State Archaeologist.
Sincerely,
Patricia L.
State Historic Preservation Officer
Executive Director
Massachusetts Historical Commission
PLW/ej
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W-7
CAPE COD PLANNING AND ECONOMIC DEVELOPMENT COMMISSION
1 >JT DISTRICT COURT HOU^E, BARNSTAULf:, MASSACHUSETTS 02630
TtLEPHONt: 617-30^-2511
Mr. Robert Mendoza
Environmental Impact Office
U.S. EPA
JFK Building
Boston, Mass 02203
Dear Mr. Mendoza:
I
June 8, 1979
Enclosed are two sets of comments on the Yarmouth Environmental Impact
Statement.
The official comments of the Commission were adopted at the May 24th
meeting of the Cape Cod Planning and Economic Development Commission.
These comments are to be inserted in the transcript in place of-my oral
statement made at the May 21st public hearing, (if possible)
The staff comments are for the benefit of the your office and the town
in revising the EIS. We would prefer that these comments not be published.
They are, of course available for review at our office in Barnstable.
We would be happy to answer any questions you or our staff may have about
these comments.
Very sincerely yours,
Paula L. Magnuson
cc: Sally Silver
-------
COMMENTS ON
YARMOUTH DRAFT EIS
BY
CCPEDC
(Official Comments for the Record)
-------
COMMENTS ON
Fnvi ronmental Impact Statcmentj_ Wastcwater Collection and
TFcatnient Facilities, Yarmouth, "Mass., (EPA, undated, 1979J
^ BY
Cape Cod Planning 5 Economic Development Commission, May 24, 1979
The Environmental Impact Statement has been reviewed by CCPEDC for
consistency with the regional goals and policies set forth in the
Final Water Quality Management Plan for Cape Cod (CCPEDC, 1979)
The following proposed comments are presented in two parts:
-- Comments on the major issues which triggered the E1S
-- Comments on alternatives recommended by the EIS
I. Comments on Major Issues Which Triggered the EIS
A. SEPTAGE TREATMENT
The recommendation against super-chlorination is consistent with
the 208 plan, which recommends against high-technology treatment
methods and against methods which do not protect groundwater
quality. (see Final Plan p. 2-37) The recommendation' to co-treat
septage with sewage wherever possible is also consistent with 208
recommendations, however, the recommendation for a lagoon system
is not.
It is felt that the discussion of septage alternatives is generally
inadequate, considering that under such a limited sewering program
septage treatment is the major facility need. More discussion is
presented below.
B. NEED FOR EXTENSIVE SEWERS
In general, the reduction of sewer service areas to areas presently
experiencing problems which cannot be cost-effectively corrected by
rehabilitation of on-site systems is consistent with the 208 plan
recommendations. The Cape Cod plan indicated that sewers would be
needed in large areas from Route 28 south to Nantucket Sound, the
inclusion of Route 28 in the EIS recommended sewer service area is,
therefore, consistent with the Cape Cod 208 plan.
The exclusion of high density residential areas south of Route 28
from the sewer service area is of concern to the CCPEDC. The 208
service areas were based largely on the very small lots in this
area which would inhibit the upgrading of on-site systems to meet
Title 5 except under ideal soils and water table conditions. Long-
term, high-density use of on-site systems is also believed to create
groundwater and surface water contamination.
-------
- L-
The EIS concludes, however, that neither soils nor water table
conditions present widespread problems in the area south of Route
28. Because soils are very permeable, leaching pits can be in-
stalled and still meet Title 5 setbacks in many cases. The EfS
does not present adequate water quality data to assess the extent
of water quality problems which could necessitate future sewering.
The CCPEDC staff is aware, however, that soil and high water
table elevations do present isolated severe problems south of
Route 28 as well as in other areas of the town. While a limited
amount of data is presently available to substantiate this problem
it is felt that the final EIS should not preclude sewering of
limited neighborhoods if problems should arise in the future.
Neither the EIS, nor the CCPEDC have adequate water table data
to determine precisely where such severing might be required.
This information should be obtained 'in the final Step I planning
work so that flows can be projected and reserve capacity developed
in the collection and treatment systems. Water quality monitoring
is also critical, both in ponds and coastal waters, since high
water table elevations can inhibit the proper operation of on-site
systems and result in contamination of ground and surface waters.
The EIS states that a possible ten percent of residential problems
may not be able to be solved through conventional on-site alterna-
tives. More information as to the nature and location of these
problems and the criteria by which their solutions may become
eligible for EPA funding should be contained within the final EIS
or Step I facility plan.
In summary, it is agreed that,, on the basis of information presently
available, the majority of residential problems south of Route 28
can be solved through stringent on-site system management and
control of seasonal conversions. , The final 208 plan encourages the
town to take these actions and CCPEDC staff is available to assist
in drafting model regulations and bylaws for this purpose. Isolated
problems may necessitate limited sewering or EIA funded alternative
solutions.
-------
-3-
II. _ C omments on Alternatives Recominended by the EIS
All of these alternatives appear to have limited capacities in
terms of the extensiveness of sewering proposed by the town units
original plan. Since site capacity and water supply are both'
critical to the town a town-wide water conservation program should
be an integral part of the final wastewater management plan.
Alternative 3
The development of the regional alternative would be consistent
with the 208 plan in that it would eliminate the creation of a
new possibly major non-point source of groundwater contamination
in Yarmouth. The CCPEDC is providing encouragement arid assistance
to Yarmouth in approaching Barnstable.
The recommendation of lagoon septage treatment at Site D is not,
however, consistent with the Cape Co'd 208 plan. The final 208
plan strongly recommends that towns seek long-term solutions that
will protect groundwater quality, recover resources and be com-
patible with abutting land use in rapidly developing resort and
second home communities. The lagoon system violates all of these
goals and we feel that such systems may become illegal within
five years under the Safe Drinking Water Act and/or Resources
Conservation and Recovery Act. A method incorporating the com-
posting process is preferred by the 208 plan. The benefits of such
a process were not adequately discussed in the cost-effectiveness
analysis provided in Appendix C of the EIS.
Alternative 4
In the use of Site D to handle' whatever sewage or septage does
not go to Barnstable, the major issues which must be addressed
are the degree of treatment required, the hydraulic capacity of
Site D and the technical feasibility of co-treating the relative
volumes of septage and sewage involved.
The EIS cites EPA Best Practicable Wastewater Treatment regulations
which requires that any land treatment system which permanently
recharges a potential groundwater resource must ensure that drinking
water quality be maintained. With limited flows, a slow-rate
application system with crop removal can be constructed at Site D
and maintain groundwater quality within the drinking water stan-
dards. This method is consistent with the 208 plan recommendations
on sewerage treatment methods.
SeSiSh!: Possibility that the groundwater down-
C°UJd be deteined by EPA no? to be a water
on hpr iu d°"e' water quality would not be a limitation.
to be han§?^ 1'°^ *** *?* and some 8«ater flows may be able
to be handled with secondary treatment alone.
-------
The CCPEDC position is that such an action is not advisable at
this time for a number of reasons. No need has yet been demon-
strated, for greater 'capacity at Site D, particularly if Barnstable
can be persuaded to take at least a portion of Yarmouth flows!
It must also be considered that Site D is a potential water supply.
A number of water supply problems occurring on Cape Cod over the
last few years has illustrated the vulnerability of our groundwater
supplies. For example, a gasoline spill in the vicinity of a
Provincetown Well and pesticide and road salt contamination of two
Yarmouth wellfields have necessitated temporary and long-term
shutdowns of major public supply wells. The recent discovery of
hazardous wastes buried in the Yarmouth landfill should serve as
an added warning of possible large-scale groundwater degradation
resulting in emergency closings of important supply wells.
Under a water supply emergency, public supply wells could be
developed in sections of town which are not presently considered
as potential water supplies. Under these conditions, the DEQE
policy requiring a 400* radius of protected watershed around a
well could be waived, and sites in the vicinity of Site D could
be developed. It is this DEQE policy which is cited by the EIS
in determining that the area around Site D is "not a water supply."
Although water quality samples at Site D have not been presented
by the EIS or other studies, there is no evidence that the area
does not presently meet drinking water standards. To make a
decision to degrade such a site below drinking water standards
should only be made in the case of established critical need and
with full public participation. Because of obvious regional
implications such a decision should also be reviewed by the
Cape Cod Water Resources Council, a CCPEDC advisory committee
recently established pursuant to 208 final plan recommendations.
Finally, Site D has a questionable hydraulic capacity. It is
evident that any flows applied to the site will ultimately reach
Seine (Swan) Pond and Parker's River. The greater the rate of
application to the site, the more direct the flow to these
surface waters is likely to be. For this reason further hydro-
logic and water quality studies would be required to evaluate
the impact of secondary treatment with moderate rate infiltration
at this site.
Alternative 5
The alternative at Site C, using tertiary treatment does not
appear to be cost-effective. We concur that tertiary treatment
would be required if the site were to be developed.
-------
Conclusions:
The CCPEDC feels that the Town of Yarmouth will need more informa-
tion to select a final wastewater management solution. Further
information is necessary on the cost and political feasibility
of the Barnstable alternative. A detailed investigation of site-
specific soils and high water table problems south of Route 28
would be required to identify isolated need for sewers or EPA
funded alternatives and further hydrologic assessment of Site D
May be required. The question has arisen whether the town must
select one of the three EIS alternatives or whether it is adequate
to accept the general findings on the needs issue and super-
chlorination process. In view of the need for additional
information it is recommended that the final EIS provide guidance
to the town on the work needed to develop a final Step I facility
plan and make recommendations on the1 availability of EPA funds
for this purpose.
The final EIS should be worded in such a way that either of the
two viable alternatives would be grant eligible. This should
include some flexibility regarding reserve capacity to service
limited areas south of Route 28 or EPA funding.for alternative
community solutions.
-------
W-8
TOWN OF YARMOUTH
SOUTH YARMOUTH
BOARDS OF
SELECTMEN
ASSESSORS
H E A I T H
EXECUTIVF
SECRETARY
MASSACHUSETTS 02664
May 11, 1979
MAY 141971
Mr. Kenneth T-feod
Environmental Protection Agency
J. F. Kennedy Building
Boston, Mass. 02203
Dear Mr. Wood,
The Board of Selectmen would like to request an extension of
the public comment period for two weeks. This would extend the date
from May 29, 1979 to June 12, 1979.
During the past two weeks the people primarally responsible for the
review of the Environmental Impact Statement have been involved in clearing
possibly hazardous material from the Town Disposal Area. As a result of this
unforseen occurance we have not had sufficient time to adequately prepare our
final comments on this important issue.
Thank you for your consideration of our request.
Sincerely,
Robert C. tawton, Jr.
Executive Secretary
-------
W-8
TOWN OF YARMOUTH
SOUTH YARMOUTH
MASSACHUSETTS 02664
June 12, 1979
BOARDS OF
SELECTMEN
ASSESSORS
-HEALTH-
EXECUTIVE
SECRETARY
Mr Kenneth Wood
Environmental Protection Agency
Environmental Impact Section
JF Kennedy Bldg.
Boston, Mass. 02203
Dear Mr. Wood,
As per our recent discussion, the Board of Selectmen would like to re-
quest a delay in submitting our final comments on the EIS for the Town
of Yarmouth Wastewater Treatment Plant and collection facilities.
We have been in touch with the Town of Barnstable and they have stated
that they will be responding to the Town of Yarmouth's request to tap
in to their sewerage system by June 21st. The Board would therefore
like to be able to submit their cottments on or before June 29, 1979.
The request for this extension, we feel, is valid in that without in-
put from Barnstable, we, in Yarmouth cannot make a rational determin-
ation as to what course of action to take to solve our septic waste
situation.
Thank you for your consideration of our request.
Sincerely
Robert C. Lawton, Jr.,
Executive Secretary
PCL/cr
-------
W-8
BOARDS OF
TOWN OF YARMOUTH SELECTMEN
ASSESSORS
SOUTH YARMOUTH MASSACHUSETTS 02664 -HEALTH-
EXECUTIVE
June 28, 1979 SECRETARY
Environmental Protective Agency
Enivronmental Impact Section
JF Kennedy Bldg.
Boston, Mass. 02203
Attention: Ken Wood
Dear Mr. Wood,
We have recently completed a review of the Environmental Impact Statement for
the Town of Yarmouth and would like to offer the following comments:
The Town of Yarmouth has received a letter frcm the Board of Selectmen in Barn-
stable stating that they could accomodate a flow of 150,000 gpd but not the
240,000 gpd proposed in Option one of the EIS. This places the town in the po-
sition of accepting one of the other alternatives cited, or presenting a dif-
ferent approach. The Town generally wants to have a true 20 year plan that
does not limit the Town for future reimbursements and protects our environ-
ment. We would, therefore, propose that consideration be given to the construct-
ion of a Sewerage treatment plant in Yarmouth at Site "D" which would have the
expansion capability to serve not only Route 28, but South of Route 28 and in
certain sections North of this highway. We would also suggest that Barnstable
be contracted with to accept the so-called Hyannis Park section of West Yarmouth
as originally proposed, and tentatively agreed to.
On another issue, the Selectmen are very concerned about septage treatment. At
the present time we are treating septage in a lagoon at the Disposal Area. This
method is not acceptable to the town and we are somewhat disappointed that this
issue is not spoken to in detail in the E.I.S. We would request that a positive
statement and offer of a solution be included in a second draft E.I.S., as this
issue could an important, if not more so, in the short term for Yarmouth.
The Selectmen will not attempt to dispute the technical points in the draft E.I.S.
We are, however, concerned that there is still disagreement concerning the types
of system to be used, i.e., Purofax, lagoon, etc., and that there is no clear de-
termination of the acceptance of Site "D". We would expect that these issues
would be clarified in the near future.
In conclusion, we feel that there needs to be a redraft completed of the E.I.S. to
clarify the problems and answer the questions raised at the various public hearings.
Upon completion of this new draft E.I.S., another public hearing should be held to
allow a complete review of the answers to questions raised and the alternatives
presented to allow Yarmouth to safely and effectively dispose of its septic wastes.
ft*
-------
W-8
Thank you for your consideration of our Garments and requests. We will be
looking forward to your response.
Sincerely,
Robert C. Lawton, Jr.f
Executive Secretary
CC: Senator Tsongas
Representative Studds
RCL/cr
-------
W-9
TOWN OF YARMOUTH
SOU'lH YARMOUTH
MASSACHUSJ: ITS 026M
June 12, 1979
BOARDS OF
SELECTMEN
ASSESSORS
HEALTH
EXECUTlVt
SECRETARY
Mr. Robert Mendoza
Environmental Protection Agency
Environmental and Economic Impact Office
J.F. Kennedy Federal Building
Boston, Ma., 02203
Re: EIS Final Draft
Dear Mr. Mendoza;
The foremost concern of the Yarmouth Water Quality Advisory Com-
mittee with the Yarmouth Draft EIS is its lack of attention to
what we feel is the Town's most glaring need - septage treatment.
The lagooning system is totally unacceptable.
The statements that there is little present degradation of surface
water quality has not been proven by the limited groundwater samp-
ling; and more testing will nave to be done in this area before any
conclusion can be made about limiting the sewage needs area. Recent
local records, not available during the EIS draft study_indicate
some areas where high groundwater and/or impermeable soils would re-
quire sewering within the next twenty years; and most recent flow
figures compiled by the Yarmouth Water Department mitigate in our
minds the future adequacy of the recommended alternative (Barnstable).
Some members of the Committee questioned the effects on the level of
the water table in the Town of Yarmouth if the Barnstable alterna-
tive is accepted.
We also question the possibility of reclassification of the ground-
water down-gradient of Site D to not being a water supply; both be-
cause we do not know if it is of that quality at the present time,
nor what future need the town may have to include it in its water
supply.
We feel that a split alternative (Side D for sewage and septage treat-
ment for the Route 28 area and residential needs east of Higgins Cro-
well.Road; and going to Barnstable for the area west of Colonial Acres
- Route 28 and Hyannis Park needs) should be considered by EPA, al-
though no interest has been shown by the Town of Barnstable in any
alternatives involving it, nor have any cost figures been presented
by that town. When received, the Town of Yarmouth would have to eval-
uate these costs insofar as the cost effectiveness of its total ex-
penditure is concerned.
-------
Page 2.
We would hope that the Town's eligibility for funding not be dis-
counted because we feel we need more information and assistance in
selecting a final wastewater management solution.
Sally Silver, Chairman
Board of Health
SS/av
-------
W-10
BOARDS OF
TOWN OF YARMOUTH SELECTMEN
« ~-^ ^ . ^ j, p n C(~)T5 <;
SOUTH YARiMOUTH MASSACHUSETTS 02664 A.ai-aau*.
-HEALTH
May 21, 1979
Mr. Robert Mendoza
Environmental Protection Agency
Env-uonmen-£a£ £ Economic. Impact
J.F. Ke.nne.dy Pe.dej.al Eldg.
Boston, Ma., 02203
Re: Public He.at.ing - Vra^t ojj Environmental
Impact State.me.nt far Yarmouth Wastewater
Colle.cti.on 8 Tre.atme.nt facilities
Dear Ur. Mendoza;
The. Town o& Vat-mouth Health Ve.pantme.Yit ha* re.viewe.d the. Vra^t E.l.S. and
would like. the. fallowing que.Ation* and comment* included in the &inal E.l.S.
? . ) Wat&A Qucsiity Data: to correct the statement that, 1}the water quality
analysis an3 sampling program produced no evidence to link turiace or
groundwat&i problem* to on-tite disposal AyAtem*." The iew te*tt> that
were performed were not tuUicient to make thi* conclusion. A complete
water quality sampling program i* needed.
2.) Spray: Slow rate land application. Please provide data a* to where
thi* type o& Ayttem ha* been in practical u4e? How are airborne
biological and odor problem* prevented?
3.) Septage Management: The lagoon method i* recommended. In a iew year*
thi* may not be an acceptable mean* otf di*po*ing o& *eptage wa*te.
What alternative* does the town have lor *eptage di*po*al?
4.} Residential M.ea*: Several area* in the Town ok Yarmouth have problem*
with poor soil conditions. How can these area* be included far possible
federal fands far on-site corrections?
Very truly your*,
Vale V. Karnes, Health
Town Oj$ Yarmouth
WK/av
-------
W-ll
TOWN OF YARMOUTH
WATER COMMISSIONERS
FREDERICK J. THACHER
ROGER G. EDWARDS, JR.
THOMAS E. KELLEY
SUPERINTENDENT
PAUL WILSON
MAY 311979
May 30, 1979
102 UNION STREET
YARMOUTH PORT, MASS. O2675
THE BOARD OF WATER COMMISSIONERS MEETS EVERY MONDAY
AT 7:30 P.M. AT UNION STREET OFFICE
EPA - Environmental Impact Board
Region 1
JFK Federal Building
Boston, Massachusetts
Attention: Mr. Ken Wood
Subject: EIS Public Comments
Gentlemen:
The Yarmouth Water Department wishes to submit the enclosed report,
prepared by our Department, to be included as part of the "Public"
comment procedures as agreed to at the Public Meeting held at the
Yarmouth Town Hall on May 21, 1979 and moderated by Mr. Wallace
Stickney-
It was my understanding from Mr. Dan Coughlin that the E.P.A. or
their consultants, Anderson & Nichol would be contacting me in the
very near future to review my estimated figures pretaining to sewage
flows along Route 28 Yarmouth, Massachusetts.
Very truly yours,
Yarmouth Water Department
Paul A. Wilson
Superintendent
PAW/me
Certified mail requested
-------
A SUMMARY OF ESTIMATED SEWAGE FLOWS
AIX>NG ROUTE 28 IN THE TOWN OF YARMOUTH
FROM THE BARNSTABLE TOWN LINE TO THE
DENNIS TOWN LINE BASED ON METER READINGS,
PEAK DAY FACTOR AND TITLE V MINIMUM
REQUIREMENTS OF THE STATE SANITARY CODE
-------
PART I
ESTIMATED SEWAGE FLOWS OF ALL ABUTTING
ESTABLISHMENTS ON ROUTE 28 FROM DENNIS
TO BARNSTABLE TOWN LINES
-------
(1)
MOTEL SEWAGE FLOW ESTIMATES AND SAMPLE ESTABLISHMENTS (6) SEASONAL ACCOUNTS
Actual seasonal water consumption
in gallons from recorded water
meter readings
Units'
1.) Americana Holiday Motel
2.) American Host Motel
3.) Hunter's Green Motel
4.) Cape Sojourn Motel
5.) Cavalier Motor Lodge
6.) Brentwood Motel
4,629,630 Gallons
1,959,300
1,380,400
1,731,900 "
1,012,435 "
649,210 "
130
79
74
55
54
40
ASSUMPTIONS: #1 THAT A PORTION OF METER READING CONSUMPTION WAS USED FOR NON
SEWAGE FLOWS I.E., LAWN SPRINKLING, GENERAL OUTSIDE USE.
WE ALLOWED 50,000 TO 750,000 GALLONS, BASED ON GENERAL
APPEARANCE AND SIZE OF GREEN AREAS. (LAWN FACTOR)
ASSUMPTIONS: #2 THAT APPROXIMATELY 75% OF TOTAL SEASONAL CONSUMPTIONS
MINUS "LAWN FACTOR" IS USED BETWEEN JUNE 15 AND SEPTEMBER 15.
FOR PURPOSE OF MATHEMATICAL REASONS A 90 DAY PERIOD WAS USED.
ASSUMPTIONS: #3 THAT ON ONE PEAK BUSINESS DAY DURING THE SUMMER SEASON THE
PEAK DAY USE WOULD EXCEED THE AVERAGE DAILY CONSUMPTION BY
30%.
FORMULA: TOTAL CONSUMPTION IN GALLONS X 75% MINUS "LAWN FACTOR"
DIVIDED BY 90 DAYS X PEAK DAY FACTOR 1.3 » DAILY AVERAGE
DIVIDED BY TOTAL UNITS IN EACH MOTEL.
THIS METHOD OF A PEAK DAY SEWAGE FLOW WAS COMPUTED FOR
ALL OF THE SIX (6) ESTABLISHMENTS LISTED ABOVE, THEN A
MEAN OF THE SIX (6) ESTABLISHMENTS WAS COMPUTED. THIS
GENERATED A FACTOR OF 227 GALLONS PER UNIT* OF POTENTIAL
SEWAGE FLOW DURING A PEAK DAY.
Unit: individual rental accomodations within a motel, cottage colony, etc.
-------
(2)
MOTELS (227 gal. per unit per day formula)
Motel Names
Units
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
Jolly Capt. Motor Lodge
Taffy Road Cottages
Pine Knot Motel
Southwind Villa
Blackwells
Quaint Steps
Parker River Motel
Mayflower Motel
Beachway Motel
Cape Traveler
Holiday Hearth
Town & Country
Holly Tree
Cape Motel
Thunder Bird Motel
Cape Holiday Motel
Snug Harbor Motel
American Host Motel
Uncle Sam's Inn
Blasko's Guest House
Squire John Motor Lodge
Americana Holiday
Windrift Motel
Tidewater Motel
Cape Sojourn
Yankee Village
1750 House
Yarmouth Gardens
Bay berry Village
Dolphin Motel
Hunter's Green
Pumpkin Patch
31
6
16
18
o
7
12
23
14
29
32
80
20
40
97
40
24
79
34
15
62
130
36
42
55
48
8
43
10
20
74
10
Gallons per peak day
7,037
1,362
3,632
4,086
500
500
2,724
5,221
3,178
5,583
7,264
18,160
4,540
9,080
22,019
9,080
5,448
17,933
7,718
3,405
14,074
29,510
8,172
9,534
12,485
10,896
1,816
9,761
2,270
4,540
16,798
2,270
Number of units unknown
-------
(3)
MOTELS (Continued)
Motel Names
Units
Gallons per peak day
33. Sea Cove Motel
34. Gateway Motor Inn
35. Yarmouth Motel
36. Sea View Motel
37. American Motel
38. Capt. Gladcliff
39. Cavalier Motel
40. Bass River Motel
41, Brentwood Motel
42. Capt. Jonathan
43. Beach & Towne
14
78
25
52
13
29
54
20
40
13
21
1,507
3,178
17,706
5,675
11,804
2,951
6,585
12,258
4,540
9,080
2,951
4.767
343,091 Total esti-
mated gallons
per peak day
-------
(4)
RESTAURANTS
Name
1. Cricket on the Hearth
2. Casa Mia
3. Dorsies Steak House
4. Forge & Sea
5. Fish Tales
6. Fred; Turkey House
7. Hearth & Kettle
8. Johnny Yees
9. Lobster in the Rough
10. Lobster Boat
11. Mama Angles
12. Olympia Fish House
13. Pancake Man
14. Petrillos
15. Parker River Chowder House
16. Pancake King
17. Peppinos
18. Pirates Cave
19. Riverway Lobster House
20. Signer Pizza
21. 200 Mile Limit
22. The Camelot Room
23. The Old Wharf
24. Tastee Tower
25. Treasure Isle Seafood House
26. Yarmouth House
Seating
Capacity
30
221
148
382
86
200
183
284
350
330
65
96
185
125
57
200
197
70
391
117
240
301
180
170
60
264
Title V1
35 Gals
1,050
7,735
5,180
13,370
3,010
7,000
6,405
9,940
12,250
11,550
2,275
3,360
6,475
4,375
1,995
7,000
6,895
2,450
13,685
4,095
8,400
10,535
6,300
5,950
2,100
9,240
4,932
172,620 Total estimated gallons
per peak day
Seating capacity figures were obtained from the Yarmouth Building Inspector's file.
Title V: minimum requirements of the State Environmental Code
-------
(5)
LOUNGES
Name
Compass Lounge
Eddies Fireplace
Le1 Spank
Mill Hill Club
Rascals
Sportsmens Pub
Sub & Pub
2,043
Title V
Capacity*
Total Seats
471
42
490
470
276
138
156
35 gals
per peak day
16,485
1,470
17,150
16,450
9,660
4,330
5,460
71,505 Total estimated
gallons per peak day
Seating capacity figures were obtained from the Yarmouth Building Inspector's file.
-------
(6)
MUNICIPAL & STATE AGENCIES
Average Daily
Meter Reading
X 1.3
= Peak Day Flew
Yarmouth Police Station
State Police Barracks
South Yarmouth Elementary
Yarmouth Town Hall
Yarmouth Library
West Yarmouth Post Office
South Yarmouth Post Office
553
682
746
739
188
124
3,032
718
886
0 not open during
peak season
960
200
244
161
3,169 Total estimated
gallons per peak day
-------
(7)
MISCELLANEOUS
(Large and small business, office buildings, banks, service stations, residence,
car wash, supermarkets, fast food (large and small), churches, hairdressers,
laundries) ,
Assumptions, water
meter readings and
1.
2.
3.
4.
5.
6.
7.
Name
Acme Laundry & Coin-
a-matic, W Yar
Acme Coin-a-matic
3 Yar
Banks
Car Wash
Church
Past Food Small
Fast Food Large
Units
1 ea
1 ea
7 ea
3 ea
3 ea
19 ea
6 ea
Title V requirements
Estimated
peak day
sewage flow
8. Hairdressers 12 ea
9. Office Buildings 9 ea
10. Large Business 11 ea
11. Small Business 152 ea
12. Residence 36 ea
13. Service Stations 15 ea
14. Supermarkets 3 ea
15. Cinema 28 1 ea
16. Massasoit Condo's 40 ea
17. Racquet Ball -
Bowling Alley 1 ea
18. Yarmouth Drive-In 1 ea
19. Aqua Circus 1 ea
20. Trailer Park
Ser.No. 2268-22A
Average Daily Meter Reading
A.D.M.R. 15,197 x 1.3 19,756
A.D.M.R. 9,768 x 1.3 12,698
Title V Res. x 2 = 660 4,620
A.D.M.R. i 3 » 500 1,500
Ave.Seat.Cap.110 x Title V
3 gals= 330 990
A.D.M.R. x 1.3 = 500 9,500
A.D.M.R. x 75% i 90 days
x 1.3 = 3,656 21,936
Ave. of 3 chairs per x
Title V 100 = 300 3,600
Title V Res. x 2 = 660 5,940
Title V Res. x 2 = 660 7,260
Title V Res. = 330 50,160
Ave.Home 3> 3 bdrms x
Title V 110 = 330 11,880
x Title V 300 4,500
A.D.M.R. i 3 x 1.3 = 1007 3,021
Seating Capacity x 3 gals
702 cap. 2,106
3 2 bdrms x Resid.Title V
allow 110 = 220 8,800
A.D.M.R. 794 gal x 1.3 = 1,032
A.D.M.R. 430 gal x 1.3 = 559
A.D.M.R. 2,473 x 1.3 = 3,214
A.D.M.R. 3,140 x 1.3 = 4f082
Misc. Total Estimated 177,154
Sewage Flow
-------
SUMMARY OP PART I
MOTELS, COTTAGE COLONIES, ETC.
MUNICIPAL & STATE AGENCIES
RESTAURANTS
LOUNGES
MISC.
TOTAL UNITS
CATEGORY AND/OR TOTAL ESTIMATED
43
7
26
7
1,507
7
4,932*
2,043*
343,091
3,169
172,620
71,505
177,154
767,539 Total
estimated
gallons
per peak
day
*Total Seats
-------
PART II
ESTIMATED SEWACE FLOWS OP ABUTTING ESTABLISHMENTS
ON ROUTE 28 PROM STANDISH WAY TO BARNSTABLE TOWN
LINE.
-------
Pg 1 of Part 2
SECTION
PROM STANDISH WAY TO BARNSTABLE LINE
PEAK DAY TOTALS
Units
Estimated gallons of sewage
for peak day flow
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
1.
2.
3.
4.
5.
jtea.s
Cape Holiday Motel
Cape Motel
Cape Sojourn Motel
Blasko's Guest House
1750 House
Thunder bird Motel
Snug Harbor
American Host
Uncle Sam's Inn
Squire John Motor Inn
Americana Holiday
Windrift Motel
Tidewater
Yankee Village
Motel Peak Day Total
Restaurants
Casa Mia
Dorsies Steak House
Johnny Yees
Tastee Tower
Treasure Isle Seafood
Rest.Peak Day Total
40
40
55
15
8
97
24
79
34
62
130
36
42
48
710
Seating
Capacity
221
148
284
170
_£0
883
9,080
9,080
12,485
3,405
1,816
22,019
5,448
17,933
7,718
14,074
29,510
8,172
9,534
10,896
161,170 Total gallons
7,735
5,180
9,940
5,950
2,100
30,905 Total gallons
-------
Pg 2 of Part 2
Lounges
Seating
Capacity
Estimated gallons of sewage
for peak day flow
1. Mill Hill Club
2. Rascals
Lounges Establ.Peak
Day Total
470
276
746
16,450
9,560
26,110 Total gallons
Miscellaneous
Units
1.
2.
3.
4.
5.
6.
7.
8.
9.
Fast Food Large
Fast Food Small
Hairdressers
Office Buildings
Residence d> 3 bdrms ea
Service Stations
Small Business
Car Wash
Acme Laundry
Acme Coin-A-Matic W Yar
2
3
1
3
11
4
19
1
1
1
7,312
1,500
300
1,980
3,630
1,200
6,270
500
19,756
Misc.Peak Day Total 42,448 Total gallons
-------
SUMMARY OF PART II TOTALS
ESTIMATE OF SEWAGE FLOW PER PEAK DAY
MOTELS, COTTAGE COLONIES, ETC. 161,170
RESTAURANTS 30,905
LOUNGES 26,110
MISCELLANEOUS 42., 448
260,633 Gallons
-------
Edwin F. Taylor, Chairman
Mary K. Montagna
Alfred B. Buckler
June 20, 1979 JUN 25 1979
Board of Selectmen
Town of Yarmouth
Yarmouth Town Hall
1146 Route 28
South Yarmouth, MA. 02664
Re: Yarmouth Waste Water Environmental Impact Statement -
Recommended Alternatives
Dear Selectmen:
Among the alternatives considered in the
referenced statement were two proposals to connect a
section of the proposed Yarmouth sewer system to the
Barnstable Sewage Treatment Plant. These alternatives
were discussed at joint meetings between our two Boards,
and we agreed to study the feasibility of accepting sewage
from Yarmouth in the Barnstable Sewage Treatment Plant.
Specifically, you requested that we consider
two flow alternatives including a flow of 240,000 gpd
average flow with a high summer flow of 360,000 gpd from
a portion of Route 28 and a flow of 150,000 gpd maximum
from a small section of Route 28. Both of these flows are
to be handled in a new force main to be constructed on
Route 28 through Barnstable to the Sewage Treatment Plant
at Bearses Way.
You also requested that we examine the feasibility
of utilizing the present South Street Pump Station for this
sewer connection rather than require the construction of the
force main on Route 28.
We presented these alternatives to the Department
of Public Works who, in turn, called upon our consulting
engineers, Whitman & Howard, for assistance in evaluating
these alternatives.
A review of the original report on the proposed
sewer system for the Town of Barnstable, which report was
-------
used as a basis for determining the size of the Barnstable
Sewage Treatment Plant, reveals that 150,000 gpd of sewage
from Hyannis Park in the Town of Yarmouth was included in
the sewer and sewage treatment plan. The plan provides for
the construction of a separate force main installation to
be installed on Route 28 to handle the 150,000 gpd flow from
Hyannis Park.
The study by the DPW and our consulting engineers
of the alternatives offered for consideration and of the
proposed use of the South Street Pump Station reveals the
following:
1. The Sewage Treatment Facility is capable of
receiving and processing the 150,000 gpd proposed from the
Hyannis Park area.
2. An average summer flow of 360,000 gpd would
overload the plant when the planned Barnstable Sewer System
is completed.
3. The South Street Pump Station and its force
main is not capable of receiving the 150,000 gpd of sewage
flow from Yarmouth since it is designed to handle only the
flow currently planned in the long range Barnstable program.
The Yarmouth EIS questioned the speed with which
the Town of Barnstable expects to reach the full 4.2 million
gpd of capacity. We are unable to provide detailed information
as to the future construction schedule of the Town Sewer System;
however, it is important to note that the population growth
rate in the Town of Barnstable is faster than the rate used
in determining the sewage needs of the Town, and at the last
Barnstable Town Meeting, the Town Meeting Representatives
voted approval of the first step in a long range sewer con-
struction program. It would appear on the basis of these
events that the full sewer plant capacity conceivably could be
reached in less than twenty years.
Based upon this evaluation, this Board is willing
to consider a proposal to accept 150,000 gpd of sewage from
Yarmouth to be delivered through a new force main to be con-
structed on Route 28.
Before an agreement on this matter can be arrived
at, it will be necessary to determine an equitable charge for
the initial installation and an annual service fee rate commen-
surate with the value of the service performed. With regard
to the charge, the value of the Sewage Treatment Plant existing,
as well as the expansion currently under construction, is
-------
- 3 -
estimated to be $10,300,000. The land value of the sewer
site is approximately $1,400,000. Of this total value,
approximately '$7,400,000 represents grant funding from the
State and Federal Governments. The Yarmouth share of this
cost should be 3.6% or $155,000, which share should be paid
to the Town of Barnstable in accordance with a procedure to
be negotiated between our two Boards. The service charge for
the receipt and processing of sewage from Yarmouth will be
determined on the basis of plant operating and maintenance
costs for the actual sewage flow which flow will be metered.
We note one additional factor to be considered in
arriving at an agreement and that is the impact of the sewer
construction on Route 28 on the residents and commercial
establishments in and adjacent to the route of the sewer force
main. This is a sensitive area and before a final agreement
can be reached, all affected parties should have an opportunity
to be heard. To the extent that there may be an impact on
some business establishments, this factor should be considered
in arriving at an agreement.
This Board is firmly committed to working with
our neighboring communities towards the mutual benefit of
all of our residents. Insofar as this sewer tie-in represents
an action that is potentially advantageous to both of our
communities, we will work with you toward the development of
a reasonable agreement.
Very truly yours,
Board of Selectmen
Town of Barnstable
-------
W-13
BOARD OF DIRECTORS
PRKSIOLNT
Hrenda .1 Bolp\n
ViCr PRESIDENT
A.C. Jane-,
SECKKTAK1
Kathaiinc ^hittum
fRKASliUtK
Joseph C Lowell
Judith ll.HiK-1
Ga>le B. Clurks
Karen Dumom
Harharj r-c^an
I'aul H. Harmlion
William I-!. Hdla'.d
B.'.rb.ira Mayu
I,-IM-:S K. NiLVcrson
Dial It s L". I'jilcsin
U.'iiald A. S.inJcr
D. ..... lii Sihail
l.r» in H Siuf
..'o-.ic 1 huntnM'n
Hi-rocrl t. \\hilluvL
Donald ' 7iim
L U1RMTOR
tsthcr A .Sutler
BOARD OF SCIENTIFIC
ADVISORS
Dr IK-ibcrl F Whiilock
thcmis:. Chairman
Dr. ll.w i. jUUvcl!
CM ol v'ii H)dro!o(;ist
Or C,.,!- in: S Cucsi-
FhviKal Ott-anogiaptler
Dr. Willum B K,-rt,wt
Dr. N- it'.'ii 11. Mckcrson
Dr HCICI M Ktch
1 imnokjgist
Dr. Ka>rv.ma Sicvcr
Dr. Mtchac! 6oukup
Ltmnoijgisl
Di Arthur N Sirahler
Or John M. leal
Mar>nc Ft-ologist
Association for the Preservation of Cape Cod
P.O.Box 636
Orleans, Massachusetts 02653
617-255-4142
WASTEWATER COLLECTION
YARMOUTH, MASSACHU3:
APCC Statement Regarding
Our comments are to be \M^6^@tgon with our
position regarding the necessity of maintaining Cape Cod's
groundwater resource in as high a quantity and quality as
possible.
In view of the recent failures and projected failures
of various town wells, it would, in our opinion, be most
unwise to reclassify that portion of Yarmouth's aquifer
downgradient from Site D to Case III. This is particularly
pertinent since at their last town meeting Yarmouth citi-
zens failed to pass zoning changes recommended to protect
present and future wellfields.
We believe that all recharge to groundwater supply
should be of drinking water quality, as described in the
Federal Standards, though even here it would be wise to
maintain a maximum of 5 parts per million nitrate as
nitrogen instead of the lesser federal figure of 10 parts
per million. At the very least a figure of 10 parts per
million of total nitrogen should not be exceeded. In
addition, any super chlorination process of septage is
unacceptable because of the hazardous by-products.
There appears to be considerable doubt whether Barn-
stable can or will accept all of the sewage developed
along Route 28, as suggested in the approved alternative
#3. Even if it could be processed by the Hyannis plant,
it may not be the most cost effective if Barnstable's
charges are excessive.
The treatment by the Draft EIS of how septage is to
be handled is most inadequate. Any long term cost-
effectiveness must consider that lagooning is not a
viable option on a permanent basis. From the point of
view of public health (even if presently acceptable to
the Commonwealth), from the point of view of esthetics,
and from the environmental point of view this method is
unacceptable.
Three viable cost-effective methods must be considered:
-------
APCC Statement re
Draft EIS
Yarmouth
1. All Route 28 sewage plus all the rest of
Yarmouth septage purnpings.
2. Part of Route 28 sewage plus all of the
septage pumpings.
3. None of Route 28 sewage and only septage
pumpings.
Which of these three is picked must depend upon Barn-
stable's response to the request that they handle at
least some of the sewage collected along Route 28.
In closing, we request that any proposed plan for treat-
ment of sewage, septage and the disposal of effluent must.,
meet drinking water quality standards through pre-treatment
and crop harvesting for discharge into the groundwater
system. Sludge treatment must be such that leachate will
meet these same standards.
May 21, 1979
-------
W-14
EST. - 1869 INC. 1924
Robert T. ton*.
Pwl C. tvcknara, |r..
Howard*. 1+tUn,
EMasA-Cooney
rewnerw. FuRer
Robert E. Hfckman
WHITMAN & HOWARD, INC.
Engineers and Architects
45 WILLIAM STREET. WELLESLEY. MASS. O2191 TEL: 617.237-5000
Frederick O. A. Unf. |r.
lames T. McDonoufh
Arthur T. Uicchini, ConooOfr
lames A. S. WWker, AXh. Officer
June 11,
Environmental Protection Agency
Environmental Impact Branch
J.F. Kennedy Federal Building
Boston, Massachusetts 02203
Attn: Mr. Wallace E. Stickney
ASSOCIATES
Gerald T.Carey
T. T. Chiang Ph.D.
Edward *. demons
Robert E. Crawford
John I. Daniels
Donald F. Dargie
Charles C. Ellis
Emeit H. Fafenlrom
Curtis H. Flight
George D. CutuHon
Arthur Liatsos
lames A. Little
Edward R Mayer
lames F. Murphy
loteph A. Murphy
Robert L. Wynun
ANDERSON-NICHOLS
RE: Written Statement
on Yarmouth, Massachusetts
Environmental Impact Statement
Gentlemen:
Enclosed are the written comments we have prepared
concerning the Yarmouth Environmental Impact Statement
(E.I.S.) prepared by your office. We anticipate that
these comments will be addressed in the finalization of
the E.I.S.
We would recommend that the present draft E.I.S.
be revised and an additional public hearing be held to
disclose the result of the many significant comments on this
E.I.S. that should be presented to the public before the
final report is published.
Very truly yours,
Charles L. Hattaway, P.E.
CLH/dgg
Enclosures
cc: Board of Selectmen
f /.
llf)
rvice
-------
COMMENTS ON YARMOUTH, MA E.I.S.
The proposed alternative selected by E.P.A. and their
consultant in the Yarmouth E.I.S., proposes that all the
wastewater collected in Yarmouth's area of need be transported
to the Barnstable, Massachusetts WWTF for treatment. This
recommendation is not supported or substantiated by the
facts of the Yarmouth situation.
Needs Area
The initial misconceptions concern the "needs area" as
determined in the E.I.S. The E.I.S. "needs area" is defined
as the commercial strip along Route 28 and eventually
includes the Hotel strip on the south shore line. The
supporting reasoning for this limited delineation was based
upon a needs survey and a cost analysis between sewer
construction and rehabilitation of on-site disposal in
residential areas. First, the needs survey should be
scrutinized concerning its accuracy to represent the desire
and needs of Yarmouth residents, particularly for the area
south of Route 28. As the E.I.S. points out, fifty (50)
percent of the area south of Route 28 is comprised of
seasonal dwellings located on very small lots. As expected
concerning seasonal property, most owners are non-residents
and live outside of Yarmouth. It is questionable that a
survey of this area can adequately represent the needs
unless the survey questionaire forms are broken down into
seasonal owners and permanent owners and appropriate conclusions
inferred therefrom. This type of information should be
available and presented in the E.I.S., to prevent any mis-
understanding and doubts about the survey's accuracy.
The E.I.S. concluded that in the residential areas
sewers would be more expensive than the rehabilitation of
existing septic systems. In order to support this recommenda-
tion, the E.I.S. further recommended that measures be taken
to reduce water usage for sanitary needs and that ordinances
be instituted to limit the conversion of seasonal homes to
yearly homes. These measures may be feasible in a few
limited cases, but it is extremely doubtful that such
restrictions on conversion would be acceptable in Yarmouth.
As was brought out at the hearings, many owners have been
investing for years in these seasonal homes and have inten-
tions of retiring on the Cape. It would be extremely difficult
to restrict these conversions and may actually defeat the
concept of slower growth on a town-wide basis by inducing
the purchases of new homes elsewhere in Yarmouth.
-1-
-------
As is documented in the Facility Plan, the 208 Plan,
and the E.I.S., a large majority of lots south of Route 28
are very small, ranging between 8,000 and 10,000 square
feet. In accordance with the local zoning codes and Massa-
chusetts sanitary code, a 10,000 square foot lot has up to
a maximum of 1,200 square feet of area available for waste-
water disposal fields. Thus, while a new on-site system may
be accommodated on such a lot, there is not sufficient area
available for rehabilitates in the future. Therefore, the
recommendation to rehabilitate existing on-site systems is
not feasible to satisfy the existing code requirements.
Even if land for rehabilitation were available, rehabili-
tation south of Route 28 would violate the "depth to water
table" requirement mandated under Title V. At many public
meetings and in the Facility Flan it has been documented
that the water table is very high south of Route 28. A
close scrutney of the land and sea elevations would further
emphasize this point. There is not a sufficient amount of
depth to water table for leaching fields without alteration
and filling of the lots. Filling these lots to satisfy the
sanitary code most likely would create more problems and
adverse impacts such as poor drainage of lots, drainage onto
neighbor's lots, expensive pumping to elevated leaching
fields, loss of existing vegetation and filling of wetlands.
Another recommendation by the E.I.S. is to install
neighborhood leaching fields in congested, small areas. This
also is not practical. The Town would be in effect, building
small sewer systems in numerous neighborhoods. Each system
would require maintenance and power to function satisfactorily.
The total operating and maintenance costs for many individual
systems would be more costly than one combined system, such
as proposed by the Facility Plan. Neighborhood leaching
fields necessarily require large vacant parcels of land
within the problem areas. It is evident and has been
demonstrated to E.P.A. that vacant land south of Route 28 is
not abundant as the area south of Route 28 is 80% or more
developed. Yarmouth has submitted an application to E.P.A.
for expanded funding of laterals under PRM 77-8, thus
satisfying E.P.A.'s own criteria for sewering these densely
populated areas.
In conclusion, we feel that the areas south of Route 28
should be more adequately analyzed and evaluated as the need
for sewers in this area is very evident for the present as
well as the future.
Recommended Alternative
Another major misconception and misleading portion of
the E.I.S. is the presentation of the alternative recommended
-------
in the Facility Plan and its associated costs. In complete
disregard of the many statements by Whitman & Howard, Inc.
and the Town Selectmen at various public meetings, E.P.A.
still refuses to acknowledge their misinterpretation of the
Facility Plan's recommendation. It is completely arbitrary
and inequitable to present an alternative that was never
proposed in the Facility Plan and then use it for cost-
effective and environmental evaluations that do not reflect
the actual Facility Plan.
The severity of this misrepresentation can be seen by
looking at Figure 0 and 14 which raise the following questions:
1. There is no doubt that an overall project
cost of $77,000,000 would have a financially significant
impact. However, at the public meetings and hearings E.P.A.
had been informed by Whitman & Howard, Inc. and the Town's
representatives that Alternative 2 is not and never was the
recommendation of the Facility Plan. Both the Facility Plan
and subsequent Step 2 Grant Application clearly proposed a
much less costly ($16,000,000) and environmentally acceptable
alternative; yet, E.P.A. sees fit to ignore these facts and
presents an unrecommended and unrealistic alternative. Such
a misrepresentation defeats the credibility of the E.I.S.
process and the best interest of the Town and E.P.A.
2. How can the E.I.S. make a judgement on the
hydrological impacts of Site D when they admit to not being
able to determine the exact hydrology of the site? When the
E.I.S. was initiated, E.P.A.'s consultant emphatically
stated that Site D could not hydraulicly accept any wastewater
flow. Later, the consultants changed their opinions on the
hydrology of site D and were able to locate a WWTF alternative
there. During more recent hearings and meetings, E.P.A.'s
consultants have altered the.ir opinion further by saying
that Site D can hydraulicly handle even more wastewater
flows than required by alternative 4. This type of presenta-
tion does not resolve one of the major issues listed by
E.P.A. as the purpose for the E.I.S. and further negates the
credibility of the E.I.S.
3. The subjective and arbitrary nature of the environ-
mental impact of the various alternatives raises questions
of reliability. For example, the impact on water quality
for the third and fourth alternatives will require that the
water table be reclassified beneath and downstream of Site D.
Alternative 2 would require the same reclassification and to
no further degree than the other alternatives; yet, according
to Figure 0, alternatives 3 & 4's impacts under this category
are minor and beneficial, while alternative 2's impact is
listed as severe and significant. This type of evaluation
of alternatives requires more quantitative and objective
documentation than that presented.
-3-
-------
4. The next two categories of questionable reliability
on Figure 0 concern "natural systems" and "sensitive areas".
In our opinion and in the Environmental Assessment which is
a portion of the Facility Plan, we feel that no "natural
system" nor "sensitive areas" will be adversly effected by
the proposed alternative. It is disconcerting to note that
alternatives 3 through 5 receive minor and insignificant
impacts in these categories, yet the only major difference
between them and the proposed alternative is the total
length of sewers installed in existing roadways. This type
of misrepresentation is unprofessional and is highly prejudicial
to the public interest.
The cost tables contained in the E.I.S. are very
confusing to the public as this fact has been brought out by
the Town's people several times. All costs should be
supported by detailed breakdowns and sources as well as more
clearly reflect the alternatives in equal perspectives.
More specifically, the cost comparison presented on
Table 3-2 (Cost Analysis of On-site Disposed Systems Versus
Town-Wide Sewers) is incorrect and completely misleading.
Through this table E.P.A.'s consultant substantiates the
economic benefits of on-site rehabilitation by inaccurately
comparing it to the cost of Town wide sewers in residential
areas which as stated earlier was never proposed.
We take a strong opposing opinion to Table 3-2 as
presented and offer the following major comments and a
"revised Table 3-2" reflecting the proper costs.
-First, we cannot substantiate the E.I.S. cost
figures listed for the construction of sewers and
sewage treatment facility. However, we have
listed the E.I.S. cost figures for comparison
with the proposed alternative of the Facility Plan.
-Second, the salvage values listed in the E.I.S.
Table do not follow the federal guidelines set
forth in the Federal Register, Volume 43, No. 188,
September 27, 1978. If true salvage values were
listed and even if we assume that the E.I.S. cost
figures for Alternative 2 are correct (these costs
are not correct), the present worth cost per unit
would be half that represented in the E.I.S.
-Third, on the enclosed "revised Table 3-2" the
actual cost figures from the Facilities Plan are
reported in the second column along with the
correct salvage costs. The difference between the
two costs represents the cost of sewers per unit
($3,011), which is only 36% of what the E.I.S. has
calculated. Utilizing the correct figures the
-4-
-------
E.I.S.
TABLE 3-2 (Revised)
COST ANALYSIS OF ON-SITE DISPOSAL
SYSTEMS VERSUS TOWN-WIDE SEWERS
YARMOUTH, MASSACHUSETTS
OPTION 1 - SEWER CONSTRUCTION - RESIDENTIAL
Cost of Sewers per Unit
Cost of Sewage Treatment Facility per Unit
Cost of Project Implementation
(Legal fees, administration, engineering
interest during construction, etc.)
Cost of Land
Cost of Connection 2
Annual Cost of O&M
*
w
0)
4J M
flj *
C W
M
D 4-1
P O
rH
< CM
$6100
830
1620
p
750
35
IT)
cu
0) .
p t.
R)
C 6
M 0
0) M
4-> U-l
i-t
< eg
$4458
608
273
42
750
35
c
o
H
4J
m
o
c
0)
c
Ob
O
0)4-1
KO
$4904
739
345
106
750
35
Present Worth of O&M
20 years @ 6.625% ^ 385 385 385
Present Worth Salvage Value per Unit:
Sewers (1025) (2675) (2942)
Sewage Treatment Plant (115) (304) (370)
Land x ? (76) (190)
Connection (125) (450) (450)
TOTAL PRESENT WORTH COST PER UNIT $8420 $3011 $3277
OPTION 2 - ON-SITE DISPOSAL - RESIDENTIAL 4
3
Immediate Repairs - % needing repair 5%
@ $2,500 per repair - cost per Unit 125
Annual Repairs - % needing repair 2%
@ $2000 per repair - cost per Unit 40
Annual O&M per Unit 20
Present Worth of Annual Costs 660
TOTAL PRESENT WORTH COST PER UNIT $785 $785 $4475
5%
125
2%
40
20
660
80%
2000
10%
200
25
2475
1. Suppose to be considered by E.P.A. regulations
2. Do not agree with figures but shall be used at this
point-in-time
3. These percentages change in the area south of Route 28
4. These costs are subject to question as E.I.S. has presented
1 them
5. E.I.S. alternative 2 with correct cost & salvage figures
6. The Facilities Plan recommended alternative for sewering the
area south of Route 28
-------
sewering of the entire town (Alternative 2 of
E.I.S.) is more than three times as expensive as
the rehabilitation of on-site systems and more
accurately represents the true situation than the
reference to "11 times" reported in the E.I.S.
text.
We agree that sewering the entire south side
of Route 6 presently is not cost-effective and
the Facility Plan never recommended such extensive
implementation until the need for such a program
develops.
-Fourth, the cost comparison of the Facilities Plan
recommendation for sewers and the cost of on-site
rehabilitation is presented in the third column of
the revised Table 3-2. These cost figures represent
the actual cost-effective analysis for sewering or
not sewering the needs area south of Route 28.
The conclusion from these figures is that it is
more cost effective to sewer this area of need
than rehabilitate the on-site systems. The costs
for rehabilitation listed in the third column are
substantiated by the information presented at the
public meetings by local residents and officials
and the information available in the Facilities
Plan.
The enclosed "revised Table 3-2" demonstrates that the
actual Facilities Plan alternative must be considered in the
Final E.I.S. as it is the most feasible and cost-effective
alternative.
Land Application Comparison
Another disturbing misconception evidenced in the
E.I.S. is the overly conservative, if not prejudicial,
assumption by E.P.A. that the land requirements for rapid
infiltration are equal to the land requirements for spray
irrigation. Many treatment facilities with rapid infiltration
of effluent have been approved and constructed on smaller
sites than what the E.I.S. considers necessary. One of the
most obvious examples is the WWTF in neighboring Barnstable
which consists of a 4.2 m.g.d. facility constructed on a 80
acre site. The Manual of Practice for Water Pollution
Control (MOP/8) states the following. "Flood irrigation has
two economical advantages over spray irrigation. As in the
case for ridge-and-furrow irrigation, there is essentially
no wind drift involved; thus, little or no border or buffer
area is required, and land requirements can be reduced."
Why
are the land .requirements in the E.I.S. being misrepresented?
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This same type of misrepresentation was utilized in the
evaluation of land requirements for the effluent disposal
area. For spray irrigation the maximum application rate is
6 inches/week and for rapid infiltration an application rate
of 3 gallons/square ft./day is acceptable in good soils.
The 3 gallons/square ft./day can be converted to 2.8 ft./week,
for comparision with spray irrigation. This comparison
alone demonstrates that a facility with rapid infiltration
does not require the.same acreage as a facility with spray
irrigation. Yet the E.I.S. equates these two processes as
requiring the same amount of land area.
Groundwater Hydrology
Another major misleading area of the E.I.S. which lacks
supporting information and sound recommendations concerns
the hydrology of Site D. Being one of the concerns of
E.P.A. for requiring the E.I.S., hydrology should be investi-
gated more thoroughly and conclusively in the E.I.S.
With the use of an analog computer model, designed
specifically for Yarmouth, and later the use of a digital-
three-dimensional computer model, developed by the United
States Geological Survey, the hydrological flow conditions
at Site D were simulated by Whitman & Howard, Inc. for
numerous scenarios. The results are the same as was
reported in the Facilities Plan; that is, no adverse
environmental impacts as a result of constructing the
recommended 2.0 m.g.d. facility on Site D. The results of
construction of a 5.0 m.g.d. facility indicates that some of
the low areas of Site D may need earthwork to maintain the
required 4'foot aeration zone at all times. However, even
an average 5.0 m.g.d. facility will not create an environmentally
adverse impact since the production of this high flow rate
is of short duration and would occur only at times when the
watertable has been lowered by high water usage and low
natural replacement. Considering these parameters, the long
term, effect on the Yarmouth watertable should be evaluated
utilizing a "steady state" application rate that is lower
than the actual design flow for the facility. These cal-
culations are easily evaluated and the Facilities Plan
presents the hydrology information in much more detail, as
should the E.I.S.
The Facilities Plan also recognized that the reintro-
duction of the wastewater into the groundwater is critical
to the Yarmouth natural resource. During public meetings,
E.P.A. stated that the E.I.S. recommendation of discharging
to Barnstable would have no effect on Yarmouth's watertable.
Yet, as pointed out by a resident of Yarmouth at the public
hearing, a six-inch reduction in the watertable results in a
20 foot rise in the saltwater-freshwater interface. This
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change is extremely significant for a Town relying upon
groundwater as a sole source aquifer. This impact should be
recognized and investigated in the Final £.I.S.
To summarize the hydrological impacts, we reiterate
that the E.I.S. lacks the adequate information necessary to
draw valid conclusions. The use of the two-dimensional
model can not answer the question as evidenced by the
conflicting statements by E.P.A. leading up to the E.I.S.
public hearing.
Septage Treatment
The final major point of concern in the draft E.I.S.
concerns the treatment of the septic waste problem. Septic
waste has been a problem in Yarmouth for many years. Corrective
action became necessary in February, 1972, when the then
Department of Public Health (Department of Environmental
Health of D.E.Q.E.) informed the Town that they must comply
with the latest sanitary landfill regulations. From that
date on, Yarmouth has been striving diligently to resolve
their septic waste problem with the interest of protecting
their residents and environment. Their efforts began with
engineering evaluations of their problems and concluded with
the submission of a Step 3 application under P.L. 92-500 on
September 20, 1976.
Since Yarmouth has shown a willingness to abide
by the environmental protection needs, E.P.A. should give
the same courtesy to Yarmouth in the Environmental Impact
Statement (E.I.S.) by presenting all the facts and alterna-
tives in an impartial manner for consideration. This
E.I.S. does not present any facts or alternatives for
septic waste treatment in Yarmouth. E.P.A. has actually
treated the septic waste problems as an after thought
deserving no engineering or economic consideration.
To emphasize this point, we wish to point out the short
comings of this E.I.S. in relationship to the septic waste
suggestions.
E.P.A. and their consultant presented very little in
the E.I.S. on septic waste, its collection, treatment, and
disposal. E.P.A. neglected to present and evaluate
alternative treatment methods for septic waste, detailed
cost analyses of the various alternatives, advantages and
disadvantages of the alternatives, and the Facility Plan's
recommendations.
The facility plan discussed three basic categories for
septic waste treatment; a. land disposal, b. combined
treatment, and c. separate treatment. Under each category
several alternatives were discussed in detail such as:
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a. Land Disposal
1. irrigation
2. plowing-in
3. lagoons
b. Combined Treatment
1. mixed activated sludge batch-fed system
2. batch-fed aerated lagoons
3. activated sludge reactors
4. aerobic digestion
5. slow introduction into a secondary facility
c. Separate Treatment
1, Lime stablization
2. chlorination
3. Aerobic digestion
4. Lagoons
5. Anaerobic-aerobic digestion
A report entitled "A Study of Waste Septic Tank Sludge
Disposal in Massachusetts" prepared for the Division of
Water Pollution Control, Water Resources Commission was
referenced. In addition to a process evaluation, the
Facility Plan discussed the advantages and disadvantages of
the septic waste treatment site. After all of this analysis,
a recommendation was made to the Town of Yarmouth.
The E.P.A. recommended a process and location with
no evaluation. E.P.A. and their consultants admit that
there will be adverse problems with their recommendation.
The only cost comparison made was a general statement that
the Facility Plan recommendation was 66% more costly than
the E.I.S. recommendation. Even this statement is inaccurate.
The Facility Plan recommendation was for a septic waste
treatment facility for 100% more design capacity than needed
because of DEQE's requirement for such reserve capacity for
all treatment methods for septic waste. The E.I.S. did not
satisfy this requirement in both their design nor their cost
comparison. Therefore using basic algebra one can determine
that the Facility Plan recommendation is actually less
expensive than the E.I.S. recommendation by 20%.
*(1-66) = y = 0.83x
y = Cost of Facility Flan recommendation
x - Cost of E.I.S. recommendation
Note: Cost of E.I.S. must be divided by 2 to compare
processes at equal design capacity requirements.
-9-
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In addition to these discrepancies, the E.I.S. did
not present their documentation to substantiate the pre-
dicted septic waste flows. It is evident that E.P.A. is
over relying upon increased septic tank pumpages to resolve
the septic tank problems in the residential areas. Yet at
no point in their discussion did they point out the impacts
of these increased pumpings on the septic treatment facility.
This is a very significant impact for an underdesigned
facility and according to the figures and recommendations
of the E.I.S. both the environmental and economic impacts
could significantly effect E.P.A.'s entire report for
Yarmouth.
We feel that E.P.A. has not addressed this area at all
and that a proper E.I.S. would have. We recommend not
only that the Facility Plan alternative be equitably
evaluated and presented, but also that additional treatment
methods be discussed.
There are also many other areas of concern in the E.I.S.
which we anticiapte will be addressed since they have been
brought up during the public participation hearings.
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W-15
YARMOUTH TAXPAYERS' ASSOCIATION
19 SALT WORKS LANE
SOUTH YARMOUTH, MASS. 02664
Tel.: 394-1645
May 18, 1979
Board of Selectmen
Town of Yarmouth
South Yarmouth, MA. 02664
Gentlemen:
A meeting of the Yarmouth Taxpayers' Association was held on
Kay 16, 1979 at the Town of Yarmouth Hearing Room. One of the new
business items on the agenda was "Discussion and formulation of
resolve reference environmental Incact Study regarding; seweraee in
the Town of Yarmouth". "
Members of the Yarmouth Taxpayers' Association were privileged
to attend a joint meeting of the V/ater .Quality Advisory Committee
and Health Advisory Board prior to our scheduled meeting the same
evening .
The comments were informative as to the latest draft copy en-
abling the Yarmouth Taxpayers' Association to discuss the E.I.S.
Report .
A motion was proposed and passed that the draft proposal not
be accepted in its present form. It was recommended that further
study be made, requesting an extension of time be granted to pro-
vide further input for the citizens' participation on the final
draft.
Sincerely yours
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W-16
COPY OF TELEGRAM
EPA BSN
B I F WRWK
TO: U.S. Environmental Protection Agency
J. F. Kennedy Building
Boston, Massachusetts
Attention: Environmental Impact Branch
Mr. Wallace Stickney 6-12-79
Reference: Draft EIS Wastewater Collection and Treatment
Facilities, Yarmouth, Massachusetts
Draft EIS lacks documentation of any adverse environmental impacts
resulting from treatment of septic tank sludge by chemical oxida-
tion with chlorine.
Percolation of filtrate into ground from chlorine treated septic
tank sludge for Yarmouth project was impetus for extensive testing
and analyses by EPA/ORD Cinci resulting in EPA Report 600/2-78-020.
Partial characterizations of chlorinated organics in superchlorine
septages and mixed sludges.
Page 2 of this report states
"Robert Tardiff of the Health Effects Research Laboratory in
Cincinnati has indicated that the identified organics in the
liquid centrates entering the environment do not by themselves
constitute a basis for environmental unacceptability of the
purifax process."
All expressed fears in this report of unknowns are responded in
manual. BIF submission to the EPA in support of the purifax
process for sludge and septage treatment entered into the record
a public hearing in Yarmouth on May 21, 1979.
Dr. S. B. Farrell, Chief Ultimate Disposal Section EPA/Ord Cinci
reported as authoring memo on November 14, 1978 stating long term
storage of sludge in lagoons cannot substitute for stabilization
processes herefore draft EIS recommendation to lagoon septic tank
sludge does not conform with numerous EPA requirements that sludge
must be stabilized prior to ultimate disposal.
Respectfully,
D. L. Moffat
BIF, West Warwick, Rhode Island
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W-17
o
0 4 Glenfeld East
Weston, Massachusetts 02193
June 11, 1979
Environmental Protection Agency
Environmental Impact Branch
J.F. Kennedy Federal Building
Boston, Massachusetts 02203
Attn: Mr. Wallace E. Stickney
RE: Environmental Impact Statement
Yarmouth, Massachusetts
Gentlemen:
As a follow up of my comments made at the Environmental
Impact Statement (E.I.S.) hearing in Yarmouth, Massachusetts,
I offer you this written text for insertion into the final
E.I.S.
As is stated on page 6 of the E.I.S. "The E.I.S. is
intended as a decision-making tool. Its function goes
far beyond E.P.A.'s concerns about project funding. Most
significantly, it provides a higher level of environmental
analysis to help the Board of Selectmen, other Town Boards
and the public at large to determine the consequences of
various alternatives to protect the Town's "most valuable
resource" - water.", the intent of an E.I.S. is to resolve
all environmental questions raised during public hearings
for a facility plan. I entirely agree with this purpose;
but having read through Yarmouth's E.I.S., I find that
this principal was not adhered to at all.
The E.I.S. conclusion is to transport our Town's
wastewater to the Barnstable collection and treatment
system. Yet the costs associated with such a recommendation
were not presented accurately. At several public
meetings, I heard that Barnstable would not consider
accepting any of our wastewater for the compensation being
presented in the E.I.S. This alternative therefore is not
resolved, but leaves the public in a confused and unsure
position.
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-2-
At one of the public meetings, Mr. Kenneth Wood
stated that the groundwater level would be lowered by 6-
inches if the wastewater were transported to Barnstable for
treatment. He further stated that this reduction of recharge
would be insignificant when compared to the total groundwater
present in our Town. This statement bothers me. Being a
hydrologist and hydraulic engineer, I know that a 6-inch
reduction in the surface of the groundwater table creates a
20-foot rise in the salt water-fresh water interface. This
amount of rise will create possible salt water intrusion
into our wells in the future.
The discussion and evaluation of such a hydrological
impact is missing from the E.I.S. This is a serious oversight
if we are determined to protect our "most-valuable resource".
E.P.A.'s recommendation to my Town includes a statement
written on page 9 that "The residential sections of Town do
not require sewering. These areas do require: . . . con-
tinued vigilance, prohibiting conversions of seasonal to
year-round use, where on-site systems are inadequate. . ."
As a taxpayer and an owner of a seasonal dwelling south of
Route 28, I would appreciate knowing what agency would be
responsible for determining which homes can or can not be
converted to year-round dwellings? With the area south of
Route 28 being highly seasonal and having many waste dis-
posal problems, the owners are going to have a difficult
time converting their seasonal homes into retirement dreams
such as I intend to do.
My wife and I have taken a very serious step in protecting
our future by buying a home in Yarmouth and we feel that it
is extremely important that our Town protect us. If sewers
will allow us to convert an existing home for our retirement,
the Town should supply these sewers.
I question the legality of preventing owners from
converting. If there are no legal grounds for the Town to
take such action, this E.I.S. once again has not performed
its function of resolving or at least properly evaluating
all questions.
We respectfully request that E.P.A. review this E.I.S.
and abide by their own interpretation of what purpose an
E.I.S. is to serve. We do not feel that they have done this
yet.
Very truly yours,
T V&1&
T. T. Chiang
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W-18
United States Department of the Interior
OFFICE OF THE SECRETARY
Northeast Region
15 State Street
Boston, Massachusetts 02109
June 1, 1979
Regional Administrator
U.S. Environmental Protection Agency
Region I
JFK Federal Building
Boston, Massachusetts 02203
Dear Sir:
This is in response to your request for the Department of the Interior's
comments on the Draft Environmental Impact Statement for the Yarmouth,
Massachusetts Wastewater Collection and Treatment Facilities.
The statement is generally a well written document. Area natural
resources are adequately described along with potential project asso-
ciated impacts to these resources. However, additional information will
be needed in the final statement on ground-water conditions, archaeological
resources and minerals. A number of alternatives have been closely
examined with two receiving extra detail; the Town's proposed alter-
native (#2) and the alternative found to be the most environmentally
acceptable.
We would like to provide the following specific comments:
Recreation and Archaeological Resources
The final impact statement should include discussion of any direct or
indirect impacts that the project might have on recreational resources
within the study area and on the Old Kings Highway Historical District.
Treatment of historic and archaeological resources is inadequate. The
draft statement seems to contain conflicting statements with respect to
archaeological resources. The archaeological consultant has concluded
"that there are no archaeological sites at or in the vicinity^of Sites C
and D which are eligible for listing on the National Register" (p. 112).
However, although potential impacts on historic and archaeological
resources are listed as "Insignificant/ Adverse" for Site D, it is
stated that "Additional archaeological surveys, however, will be required
if this site is selected" (p. 135). ._
RECEIVED
JUN-41979
REGION I
OFFICE OF THE
REGIONAL -~"'M'0?:-
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W-18
-2-
Archaeological field survey work, including subsurface testing, should
be carried out at Site D before a decision is made on alternative site
locations. The fact that there is a known, recorded archaeological site
in the area stresses the need to fully identify that site and related
archaeological resources in order to assess the potential impacts of the
wastewater treatment facilities on these resources. Only after such an
investigation is complete can informed decisions be made on the potential
environmental consequences of the proposed action, as required by both
the National Environmental Policy Act and the National Historic Preservation
Act. The final statement should include the results of these investigations,
evidence of appropriate consultation and coordination with the Massachusetts
Historical Commission (SHPO), and a discussion of proposed plans to
mitigate any adverse effects on archaeological resources if the wastewater
proposal is adopted.
Geological Resources
The statement should indicate the significance of private water supplies
in comparison to public supplies in the project area.
A water-table contour map or at least a map showing general directions
of the hydraulic gradients in the aquifer is needed; the magnitudes of
such gradients should also be shown and discussed, if a water-table map
is not included. Typical aquifer characteristics, especially transmissivity
and storage coefficients, should be given. The location of the sanitary
landfill should be shown on appropriate maps; the description on page 110
is somewhat ambiguous, because it could refer to more than one location.
It is stated that there is no provision for handling hazardous wastes at
the landfill (p. 111). Does this mean that all hazardous wastes are
routinely included in the landfill operation?
It is stated that the most significant changes in ground-water quality
that are apparently attributable to the landfill occur within the triangle
including observation wells 24, 25 and 27/28 (p. D-4). Well 28 lies in
the northern part of the project area; well 27 is apparently not shown
on figure 16; and wells 24 and 25 lie in the southern part of the project
area. The location of the apparent aquifer degradation should be clarified.
The possibility of reclassifying the aquifer as a Case III aquifer in
order to apply less stringent nitrogen standards is suggested (p. 72).
Because the aquifer is apparently essentially a sole source aquifer,
according to information given in the statement (p. 4), the assessment
should address alternate sources, if any are available, and should
evaluate impacts of the proposed reclassification on future aquifer
development.
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W-18
-3-
The statement would benefit from more specific information on the
ground-water/surface-water interrelationship in the project area. Such
information would be useful in assessing any effects on surface-water
sources that may result from increased ground-water discharge from
wastewater disposal areas.
Fish and Wildlife Resources
Alternative 2, which was developed by the Town and its consultant,
appears from a natural resource standpoint to be environmentally unaccept-
able. The site proposed for construction of the wastewater treatment
facility (Site D), does not have the hydrologic capacity to accept the
projected flows. The resultant changes in ground and surface waters
would violate existing Federal and State water quality standards. The
natural functioning of adjacent wetlands and the adjoining conservation
area will be altered resulting in adverse aesthetic and wildlife impacts.
The large area to be sewered exceeds that found to be necessary by the
needs survey and will open presently undevelopable lands to development,
further impacting area natural resources.
The statement designates Alternative 3 as the "preferred alternative."
The Fish and Wildlife Service concurs with this designation. This
alternative would sewer the area delineated in the needs survey and
transport the waste to a treatment facility in Barnstable. The facility
in Barnstable is presently under construction and will have the capacity
to accept wastewater from Yarmouth. Septage from Yarmouth is proposed
to be treated in Yarmouth at a new facility at Site D. This facility
would be relatively small and should not adversely impact wetlands.
However, if this is found not to be true, it appears that the facility
could be located elsewhere. This alternative would eliminate potential
water quality degradation of Parker's River, Mill Creek, Mill Pond,
Lewis Bay and Nantucket Sound. The majority of adverse impacts to fish
and wildlife which could result from this alternative would involve
stream crossings. The statement defines a number of mitigative measures
which should minimize these impacts.
Mineral Resources
The final statement should mention any resources in the project area and
the amount of those resources which will be foregone (preempted) if the
project is implemented. Mention should also be made of the commitment
of mineral resources for project construction.
Sincerely yours,
William Patterson
Regional Environmental
Officer
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APPENDIX D
LIST OF PUBLIC HEARING SPEAKERS
D-l
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LIST OF PUBLIC HEARING SPEAKERS
DRAFT ENVIRONMENTAL IMPACT STATEMENT
Comment No. Source
H-l Paula Magnuson
H-2 O.K. Putnam
H-3 Arthur Luke
H-4 Dr. Edward Chiang
H-5 Dr. Herbert Whitlock
H-6 Sally Silver
H-7 John Mulcane
H-8 Robert Hickman
H-9 Charles Hattaway
H-10 Bradford Tallman
H-ll Don Moffit
H-l2 Roy Putnam
H-13 Franklin Greene
H-14 Paul Wilson
H-15 Joe Gannon
H-16 Dale Karnes
H-17 John Sears
H-18 Robert Hickman
H-19 Sally Silver
H-20 Wayne Embree
H-21 Yarmouth Taxpayers
Association
D-3
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APPENDIX E
PUBLIC HEARING TRANSCRIPT
E-l
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Volume I
pagw 106 plus i
Exhibits Per Index
UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
REGION I
In the Matter of:
AN ENVIRONMENTAL IMPACT STATEMENT ON WASTE WATER TREATMENT
AT YARMOUTH.
BEFORE: Wallace Stickney, Chairman
Director of the Environmental and
Economic Impact Office
Environmental Protection Agency
JFK Federal Building
Boston, Massachusetts
Ken Wood, Project Officer
Environmental Protection Agency
JFK Federal Building
Boston, Massachusetts
Dan Coughlin
Massachusetts State Co-Ordinator
For the Grants Program
Boston, Massachusetts
Burk Ketchum and Joe Zeneski, Consultants
Anderson-Nichols
Boston, Massachusetts
Monday, May 21, 1979
Yarmouth Town Hall
Yarmouth, Massachusetts
Com.tne.itie. Cowit iting Co., {Jne..
18 TREMONT STREET
BOSTON. MASSACHUSETTS O21O8
(617) 523-3O68
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
INDEX
ALSO PRESENT:
Mrs. Sally Silver, Chairperson of Board of Health,
Town of Yarmouth.
Mr. Arthur Luke, Chairman of Board of Selectmen of
Town of Yarmouth.
Mr. John Sears, III, Selectman of the Town of Yarmouth.
Mr. Bradford Tallman, Selectman of the Town of Yarmouth
Mr. Franklin Greene, Selectman of the Town of Yarmouth.
PERSONS PRESENTING DIFFERENT SPEECHES:
Paula Magnuson, Cape Cod Planning Commission
Mr. Putnam, Citizen
Mr. Burk Ketchum
Mr. Arthur Luke, as Citizen
Dr. Edward Chiang, Citizen
Letter from Dr. Herbert Whitlock read into record
Sally Silver, as Citizen
Mr. John Mulcane, Citizen
Mr. Robert Hickman, Whitman & Howard,
Mr. Charles Hattaway, Whitman & Howard,
Mr. Don Moffat, B.I. P., Unit of General Signal,
West Warwick, Rhode Island
Mrs. Putnam, Citizen
Mr. Franklin Greene, Selectman
Mr. Nilson, Citizen
Mr. Gannon, Citizen
Mr. Dale Karns, Health Officer of Yarmouth
Mr. John Sears, Selectman
Mr. Wayne Embree, Citizen
Letter read into record of Yarmouth Tazpayer's Assoc.
t-omme.ic£. Coutf
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1 MR. STICKNEY: Gentlemen, I'd like to
2 call the hearing to order. My name is Wallace Stickney.
3 I'm director of the Environmental and Economic Impact
4 Office in E.P.A., Region One, in Boston.
5 It's my pleasant duty to act as moderator
6 for the hearing tonight. With me at the table are Dan
7 Coughlin, who's the Massachusetts State Co-ordinator
8 for our Grants Program, Ken Wood who's the Project
9 Officer at E.P.A. for the E.I.S., and on my right, Burk
10 Ketchum and Joe Zeneski of the firm of Anderson-Nichols
11 in Boston, who are consultants to the E.P.A. for the
12 Environmental Impact Statement.
13 Our agenda for the evening will be as
14 follows: We'll open with a short presentation about
15 the project and after that turn to your questions and
16 comments right away.
17 This is the official hearing on the
18 draft Environmental Impact Statement for waste water
19 collection and treatment facilities, Yarmouth, Massa-
2o chusetts. It was initiated in August of 1977 when
21 E.P.A. issued a Notice of Intent to Prepare the Environ-
22 mental Impact Statement.
23 The record, for comments on the draft
24 E.I.S. will remain open until June 12th, which is two
25 weeks longer than normally allowed, but which complies
-2-
Conuneun, Cowit
-------
1 with a request by the Yarmouth Board of Selectmen that
2 the record remain open for two extra weeks, and we want
3 to keep it open until we have all of the comments and
4 give you time to consider your comments carefully.
5 As you know, the waste water treatment
6 studies were initiated by the community in 1974. This
7 Environmental Impact Statement is just another step in
8 the process for providing federal funding for the pro-
9 ject in whatever form it might eventually take.
10 As those of you who have participated
11 with us so far in the E.I.S. know, this Environmental
12 Impact Statement is required to be completed for all
13 major or significant federal actions. As such, it does
14 not represent an investigation of what has gone on
15 before and no such inferences should be drawn, but it
16 merely is an independent federal evaluation of the
17 alternatives, the environmental impacts and the cost
18 effectiveness of the various alternatives which are
19 available to the community and to the federal government
20 With that, I'd like to turn it over to
21 the Board of Selectmen. If you have an opening state-
22 ment or would like to say anything before we begin, we'd
23 be glad to hear it.
24 MRS. SILVER: Thank you very much. The
25 Board of Selectmen, through Mr. Franklin Greene, Brad
-3-
Cowd.
-------
1 Tallman, John Sears, Arthur Luke and I'm Sally Silver,
2 Chairman of the Board of Health, have been working very
3 much with the Yarmouth Water Quality Study Committee in
4 evaluating this draft report. We've had quite a bit of
5 discussions back and forth with our engineers, Whitman
6 and Howard, with you people and with the public.
7 We have many questions and many comments
8 which we hope will come out tonight. Thank you.
9 MR. STICKNEY: Thank you. It's a
10 pleasure to be joined by the local officials. Usually
11 at a hearing like this, they like to stay as far from
12 us as possible, and I want to thank you for your coopera
13 tion throughout the process, it's been very helpful.
14 With that, I'd like to turn the program
15 over to to Burk Ketchum for a short review of the
16 salient points of the Impact Statement just so that we
17 will have a common basis upon which to start. Burk?
18 MR. KETCHUM: Thank you, Wally. Most of
19 you have been through a presentation that we have made
20 on two previous occasions. I'll try and be very brief
21 and summarize the Environmental Impact Statement which
22 as you know is incorporated in this document and also
23 there is a summary in the back of the room which is the
24 summary which is included in the E.I.8.
25 Essentially, we're talking about protec-
-4-
<2omme.ice. Couit tzffe.fzoitlncj Co.
BOSTON, MASSACHUSETTS
-------
1 tion of water resources in the community. This shows
2 the surface water bodies of the community here. We're
3 also talking about protection of ground water resources
4 which, as you know, there's a huge ground water aquifer
5 underneath the Cape Cod area.
6 The plan that was initially prepared by
1 the Board of Selectmen and their consultants back in
8 '77 and is the basis for this E.I.S. is shown here and
9 this shows the general service area that was proposed
10 at that time and was the basis of a public hearing held
11 in 1976 and E.P.A.'s Order to Prepare an E.I.S. included
12 the following major issues which were to be evaluated:
13 One, there was potential for ground water contamination
14 from proposed septage treatment facility; two, there was
15 local controversy over the cost; and three, the need for
16 such a large sewer service area was questioned.
17 Now, Anderson-Nichols, in collaboration
18 with the E.P.A. starf and with the community, has been
19 developing this E.I.S. over the past several years.
20 Essentially, we have been an extension of E.P.A.'s
21 staff to undertake technical studies and to carry out
22 a public participation program.
23 One of the initial things that we under-
24 took was a study of the need for sewering in this
25 particular community and I'll just summarize some of the
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1 steps that we took in evaluating the needs.
2 One, we reviewed prior reports; two,
3 we looked at the soil surveys; three, we had a workshop
4 at which some of the citizens of the community attended;
5 four, we met with the Board of Health, reviewed their
data, the water quality data; five, we did extensive
7 water-quality testing, there were four marine and
o thirteen inland surface water sample studies undertaken
o
and in addition, we evaluated thirty-two well sites. In
addition, we undertook a questionnaire which was sent
to ten thousand people in the community. We received
replies from a very large number, forty-three hundred.
Other aspects of this program included
I o
a T.V. show which was held about a year ago and there
14
were a number of meetings with groups such as the Board
* D
of Selectmen, the Board of Health, Planning Board,
16
17 et cetera.
As a result of this evaluation, we found
18
essentially that there was no great need for sewering
in the residential areas of the community. We did find,
20
however, that there was a need because of potential
ground and surface water contamination in the Route 28
23 area for sewering in that particular section of the
24 community.
The E.I.S. evaluated five alternatives.
tO
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1 The alternatives were as follows: One was the no action
2 alternative, which was essentially doing nothing with
3 the conditions that exist in the community. Now, this
4 is required by the federal E.P.A. regulations and this
5 was one of the alternatives that was evaluated.
6 Two was the proposed action. The propose
7 action is alternative two which I showed you before, is
8 essentially the proposal prepared for the town and
9 reviewed back in 1977.
10 The proposed action included an ultimate
11 service area of five million gallons per day, which
12 would be treated at Site D and a purofax (phonetically)
13 septage treatment facility at the town waste water
14 disposal site with a capacity of sixty thousand gallons
15 Per day.
16 Alternatives three, four and five were
17 developed as part of the E.I.S. study. Essentially,
18 alternatives three, four and five include the sewering
19 of the Route 28 area as shown on this map.
20 Tne alternatives differ in the manner
21 in which the manner and the location in which the
22 sewage would be treated under this alternative.
23 Alternative two excuse me, alternative
24 three proposes that the waste water be treated at the
25 Barnstable facility. Our information is that the plant
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1 there has been designed for a capacity of 4.2 million
2 gallons per day, which included capacity of about a
3 hundred and fifty thousand gallons per day from the
4 West Yarmouth area of Yarmouth.
5 Initial flow to this particular facility
6 would be 2.1 million gallons per day and through dis-
7 cussions with the Barnstable Board of Selectmen and
8 others, it's been determined that that is a feasible
9 alternative and the Barnstable Board of Selectmen have
10 indicated an open mind with respect to considering this
11 possible alternative.
12 Under this alternative, the septage
13 would be treated in a lagooning system at Site D here.
14 Alternative number four proposes that the waste water
15 be treated at Site D.
16 Now, under alternatives three, four and
17 five, we are proposing that there be an initial flow of
18 of approximately three hundred and sixty thousand gallon
19 per day which might increase at some later date to about
20 five hundred thousand gallons per day.
21 Under the alternative four, the waste
22 water would be treated to secondary levels and applied
23 to the ground in what is known as slow-rate irrigation
24 and there would be a septage facility incorporated as
25 part of that particular alternative.
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1 Under alternative five, the waste water
2 would be treated here at Site C which is northeast of
3 the Dennis-Yarmouth High School site. Because of the
4 potential for contamination of well sites in the
5 vicinity of that site, this particular treatment facilit
6 would be for advanced waste water treatment followed by
7
rapid infiltration.
8 Now, under alternatives three, four and
9 five, there are several considerations beyond those
10 which I've indicated and those are called non-structural
11 measures. These include zoning to protect the water
12 resources, the well sites in the community, they include
13 very strong implementation of the Board of Health's
regulations, possible improvement of some of these
15 regulations to cover things like seasonal conversions,
16 more inspections and an extensive program to prevent any
17 problems from reaching a point where sewering would be
18
necessary.
19
The environmental consequences were
20 considered in terms of the technical information, they
21 were considered in terms of the comments which we
22 received from the community, they included evaluation
O^
of various planning studies and I just have one here
24 which is probably the most recent statement of the
2S
community's goals for growth in the community, to
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1 preserve the quality of living in Yarmouth, to improve
2 the efficiency and effectiveness of its government
3 operations so as to minimize taxes, to involve the
4 public as much as possible in policy and decision and
5 four, to facilitate and promote the sound expansion of
6 the area's public industry which is essentially tourism.
7 Now, these and other documents were
8 reviewed and we have prepared a slide here which
9 summarizes the environmental consequences of the five
10 alternatives.
11 Just a brief explanation. We've evalua-
12 ted a certain number of categories here and for each
13 one of the alternatives, we've determined whether the
14 impact in that particular category is none, insignifi-
15 cant, minor or significant.
16 Now, under E.P.A. and federal guide-
17 lines, the most important consideration is whether the
18 impact would be significant or not, and we have made
!9 the determination that there are potentials for
20 significant impacts on alternatives one and two,
21 alternative one being no action; alternative two being
22 the original proposal of the community.
23 These impacts, including hydrologic and
24 financial under alternatives one and under alternatives
25 two, hydrologic, water quality, financial, natural systei
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1 and sensitive areas are summarized in the E.I.S.
2 In addition, on this chart, we have an
3 identification of the present worth cost to carry out th
4 various alternatives and the costs range from seventy-
5 seven million for alternative two down to fifteen millio
6 fifty thousand dollars under alternative three.
7 We have broken these down in more detail
g and I'd like Mr. Zeneski to give you a brief summary of
g what these costs actually mean to a typical taxpayer in
10 the community.
H MR. ZENESKI: Many of you have seen the
12 tables we presented in the text in the summary of the
13 report and I've described before that there is an item
>
14 in each for example, in alternative two, for the
15 capital cost, that is, the local share of the project
16 cost, that portion which is left over after federal
17 and state funding and the annual cost for the operation
18 and maintenance of the facility and we presented that in
19 table zero one and zero two in the summary of the report
20 What I prepared for tonight's presenta-
21 tion is a table to give us an idea of what this means
22 to a user. We have one user here and examples of
23 building assessed at a hundred thousand dollars with a
24 daily sewage flow or water use, depending on the measure
25 of charging for sewage use, of eight hundred gallons pei
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1
2
3
4
5
12
day. Now, we have four categories here I'm sorry,
two categories and then two sub-sets of that.
The first column is where the user pays
all costs associated with the sewer, that is, the capit
cost of the system and the operation and maintenance
costs, and we've assumed made two assumptions. One
is that the particular building owner is a user of the
Q
sewer system, is within the sewered area and uses the
g
sewer; the other is that he is not in the sewered area
and does not use the sewer, and that is the same assump-
11 tion for the other alternative, which is the town-wide
sharing of all costs,
Now, what this points out to us here is
14 that under alternative two, a user in the sewer service
15 area with an assessed value, keeping in mind these
16 numbers, would pay approximately $650.00 a year. The
17 same building and same sewage flow and the owner did
18 not use the sewer, was not in the sewer service area,
19 would pay nothing for that sewer.
20 If the town were to assess the cost of
21 construction through the taxes, then this fellow
22 because his property happens to be worth a lot, would
23 pay slightly more, almost twice as much under this
24 alternative and the non-user, the guy who's not reaping
25 any benefit from the sewer, would also pay a significant
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1 amount more and under alternatives three and four, we
2 see a different type of effect.
3 What this model demonstrates is that
4 under alternative two, the costs are very large and
5 more people are sharing them. Under alternatives three,
6 four and five, there are fewer users and, of course, the
7 cost is less.
8 Again, this can be put together from
9 the information contained in our published tables by
10 manipulating the numbers and I'd be glad to respond to
11 any questions on that if they come up later.
12 MR. KETCHUM: Thank you, Joe. That
13 concludes our formal presentation, Mr. Stickney.
14 MR. STICKNEY: Thank you, gentlemen. I
15 should let you know before we turn to comments and
16 testimony on the E.I.S. that at these hearings, we try
17 to develop the record as completely as we can, so from
18 time to time, I may ask the panel.ots or consultants
19 questions, but this should not be interpreted to indi-
20 cate that I have a lack of confidence in what they've
21 done, but merely to develop the record and the issues
22 as completely as we can.
23 We may, from time to time, also ask
24 questions of those of you who may wish to offer comments
25 so that we're sure that we understand what you want to
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1 tell us completely and finally, I must ask that for
2 comments and questions, that you use the podium. The
3 hearing is being stenographically recorded and the
4 microphone for the recorder operates at short-range
5 only and the only extra recorder microphone is the one
6 on the podium, so I hope you'll bear with us for this
7 minor inconvenience.
8 And, with that, I'd like to ask if there
9 are any state officials who'd like to comment?
10 (No comment)
11 MR. STICKNEY: Hearing none, would the
12 town like to make further comments at this time or
13 would you like to reserve any further comment?
14 MRS. SILVER: I think the Board would
15 like to reserve their comments until the public is
16 through and I think we would also all be making personal
17 comments that we would like to have recorded as being
18 from people that were Selectmen, but not a report of
19 the Selectmen at this time.
20 MR. STICKNEY: Fine, any way you wish
21 to do it.
22 MRS. SILVER: Thank you.
23 MR. STICKNEY: Are there members of
24 town boards or committees who would like to make a
25 comment or regional agencies?
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1 MS. MAGNUSON: I'll go first.
2 MR. STICKNEY: I thought you wouldn't
3 have to go first.
4 MS. MAGNUSON: You did very well. I
5 didn't want to go first, but I'll go first.
6 Paula Magnuson, Cape Cod Planning
7 Commission. We will be submitting a written statement
8 from the Planning Commission after our meeting on
9 Thursday.
10 The statement has been drafted and
11 distributed to the members, but until the time the time
12 it is adopted, I will briefly summarize the areas of
13 concern tonight, but the official statement will be
14 what you receive in writing.
15 For the benefit of the people present,
16 I thought they might be interested in the concern the
17 regional agency is going to express.
18 We've reviewed the plan for this purpose,
19 for its consistency with the Cape Code 208 Plan and
20 we've limited these official policy-oriented comments
21 to the areas of consistency with the 208 plan. There
22 are some technical comments that will also be submitted
23 in writing by the staff, but they aren't dealt with
24 here.
25 Now, we divided our comments up into
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1 two sections. The sections that dealt with the major
2 issues that triggered the E.I.S. and then the alterna-
3 tives recommended by the E.I.S.
4 So, to start out with, the first cause
5 for the E.I.S. that was cited was the septage treatment
6 method and whether that presented a risk to the ground
7 water and basically we really question since, under
8 your alternatives, septage is really the major facilitie
9 need, whether all of the septage alternatives have been
10 discussed adequately.
n In other words, treatment alternatives
12 in general. The information that was given on the
13 system that was studied was also quite limited and we'd
14 like to see more information provided if septage is
15 going to be a major decision of the final E.I.S.
On the need for extensive sewers, was
16
17 the other major issue that triggered the E.I.S. and we
18 do have a lot of feelings on that subject. Our major
19 concern is that the exclusion of high-density areas,
2Q residential areas south of Route 28 is an area of
21 concern because we had indicated in our 208 Plan, based
22 on information that was available then, that there was
23 a probable sewer need in this area.
Those comments were in and that recommen
24
25 dation were based on the small lots. Information that
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1 publicly has been available on high water table, althoug
2 it's vague information, and the water quality impacts of
3 that kind of density is likely to have.
4 And at this point, we feel that the E.I.S
5 has demonstrated that there are that the present
6 problems may not be pressing in that area and according
7 to the Health Department, can be solved in many cases
8 on site, but we are still quite concerned that either
9 water quality or soils and water table could mean a
10 future sewer need in this area and that whatever final
11 alternative is recommended should reserve capacity and
12 plan for reserve capacity could deal with problems if
13 the non-structural controls are not successful in
14 heading off major problems in this area and we might
15 add that we'll be submitting technical information.
16 There are some other areas in town that
17 show isolated severe problems with soils and water
18 table which may not presently require sewers as the
19 E.I.S. has concluded, but may be a need for future
20 service areas, and if sewer service is not the solution
21 to some of these isolated problems, perhaps some other
22 E.P.A. funded solution under the new amendments would
23 be and we'd like to see more information on what kind
24 of solutions would be fundable and what these solutions
25 are for the problems that the E.I.S. itself has deter-
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1 mined.
2 Moving into the areas of recommendations
3 by the E.I.S., we feel that the concept of the regional
4 alternative is consistent with the concept of the 208
5 Program, largely because it would avoid perhaps the
6 development of a new, major non-point source of pollu-
7 tion in the town and that would be assuming that septage
8 were dealt with in a non-polluting way.
9 The Planning Commission is encouraging
10 Barnstable to work with Yarmouth. We have set up a
11 meeting to discuss this and will provide such assistance
12 as we can.
13 Under that alternative, lagoon septage
14 treatment is recommended and as it has been pointed out
15 in the past, the 208 Plan recommends against lagoon
16 systems as a long-term treatment, partly because we
17 feel that they may very well become illegal under either
18 one of the federal acts, the Safe Drinking Water Act,
19 or the Resource Conservation and Recovery Act, and also
20 because of the ground water impacts and the impacts on
21 the neighborhood that are associated with this relativel
22 primitive method.
23 We have been encouraging towns to seek
24 a long-term solution that can protect the ground water
25 and we feel that those solutions are available at this
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time.
2 Under alternative four, the use of Site
3 D, our major comment in that area is, there is a question
4 of water quality at Site D, whether the water quality
5 needs to be maintained at drinking-water quality, which
6 would limit the capacity of the site more severely than
7 any hydrologic problems, or whether the site should be
8 classified as not a drinking water supply.
9 We've given a great deal of thought to
10 the ramifications of designating any area not a drinking
11 water supply and the Commission, I believe, will support
12 ! the staff in our concerns that if an area is presently
13 of drinking water quality, and we have no reason to
14 believe that the area around Site D is not presently
15 of drinking water quality, that it's very difficult to
16 decide it's not a potential water supply.
17 We've seen wells shut down on the Cape
18 due to gasoline spills, road soil contamination, pesti-
19 cide contamination, and we've seen very recently
20 hazardous waste discovered in an area that don't belong
2i on the Cape.
22 We don't feel that any agency, state
23 or federal or regional, is in a position to say that
24 all the present well fields are secure from contamina-
25 tion and won't have to be shut down at some point in an
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1 emergency and what we've seen in Province-town particular
2 is under an emergency that state usual requirements for
3 a fairly large radius of protective water shed around a
4 well can be waived in that, in fact, emergency water
5 supplies can be developed in areas conceivably such
6 as the area around Site D.
7 So, until such time as it is determined
8 that all the well sites are secure and that the area is
9 absolutely not needed for a water supply and/or that the
10 area is not presently suitable for water supply, we feel;
that the decision should be made very cautiously to
12 classify that area as not a water supply, and also with
13 regard to water quality at that site, the site will
14 obviously drain into Parker's River via Sane (phoneti-
15 cally) Pond and I call to your attention that the surfac
16 waters on the Cape are classified as low-flow waters,
17 where there are to be no discharges and control of
18 utrification (phonetically) is a major goal under the
19 state water quality standards.
2Q Site C, the use of tertiary treatment
21
we agree does not look very cost effective at this
22 time.
The conclusion that we reached is a
24 difficult one and it's the one the E.I.S. had to deal
25 with, and that is, there may be sewer service areas
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1 that will need sewering in the future, but the sites
2 look very limited, and the town is facing some very
3 severe problems in having to pick any one of the
4 alternatives presented.
5 We do feel that the town needs more
6 information to come up with a final waste water facility
7 plan. It may involve either one of the two preferred
8 alternatives, Barnstable or Yarmouth at Site D or a
9 combination of the two, and the final E.I.S. should be
10 geared to recommendations to the town that will help
11 them get their final facility plan completed, stating
12 the information that would be necessary to complete it
13 and the source of funds that might be available to the
14 town to complete it and resolve the questions that we
15 are raising and I think will also come up tonight.
16 That's basically my comments. Thank you
17 for your time.
18 MR. STICKNEY: Thank you very much.
19 Does anyone here at the table have any questions that
2Q you'd like to ask at this time?
21 MR. COUGHLIN: Well, maybe I could
22 1>d like to address that case one, two, three identifi-
23 cation --
24 MR. STICKNEY: Excuse me, Dan, would
25 you identify yourself for the record?
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1 MR. COUGHLIN: Okay, I'm sorry. Dan
2 Coughlin, Massachusetts State Co-ordinator for the
3 Construction Grants Program, E.P.A.
4 The regulations allow the regional
5 administrator of E.P.A. in conjunction with town
6 officials and the appropriate state officials to
7 determine what quality the water the effluent should
8 be applied to a land application site.
9 Essentially, there are three criteria
10 that have to be looked at. A situation where the
11 water resulting from a land application may be used
12 for drinking water, in which case it would require that
13 the water resulting from the land, application meet
14 drinking water standards.
15 A situation where the ground water may
16 be used or is being presently used for drinking water,
17 in that case again, drinking water standards would have
18 to be met, the difference being one has bacteriological
19 standards and the other one doesn't.
20 The final one is the case three which
21 Paula brings up. We haven't made any determination as
22 yet at all. It would appear that case three may be
23 applicable in this particular area downstream of Site
24 D simply because of the density of development down
25 there and the lack of any wells there now. There doesn'
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appear to be any room for wells.
2 The major point I'd like to make is that
the regional administrator or E.P.A. will not be making
4 that decision. It will be made in conjunction with the
5 town and the local people and the regional planning
6 agencies.
7 The reason we are considering it or at
8 least putting it in the E.I.S. is that it does allow
9 for additional capacity on that Site D. Right now,
10 Site D without that right off, or without that case
11 three determination, is somewhat limited with respect
12 to the amount of effluent you can put on it.
13 Once we do make a case three determina-
14 tion, if it is done, then the site becomes more capable
15 of taking additional flow.
16 MR. STICKNEY: Thank you for that
17 clarification, Dan. Who would like to be the first
18 commenter?
19 MR. PUTNAM: Are you talking about the
20 public?
21 MR. STICKNEY: Yes, we are.
22 MR. PUTNAM: Do I have to get over
23 there?
24 MR. STICKNEY: I'm afraid so, so that
25 we can record you for posterity.
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1
MR. PUTNAM: I think the public in the
town here has very little knowledge about
MR. STICKNEY: Excuse me, would you
identify yourself, sir?
MR. PUTNAM: Oh, Putnam, of West
6 Yarmouth. I think we the people know very little about
7 what's going on. A handful of people know all the
8 answers and I would think that it would be publicized
9 more than it is on how the water is in this town.
What bothers me most is the salt on the
11 roadways, the chemicals, more than the pollution of the
12 sewerage. They're both important, but all I'm trying to
13 point out is, where do we get this information unless
14 we come to meetings and there's not very many here
15 tonight that's getting the information, so what I'm
16 trying to get at is, how good is our water, chemical-
17 wise and sewerage-wise? How long do we have to go
18 without sewerage control? Those are the questions.
Can we go five years or can we keep
20 putting it in the dump? I understand the salt level
21 is getting up every year. It's up around fifteen parts
22 Per million or whatever it is. I think we need more
23 publicity on it to get us involved.
24 MR. STICKNEY: Thank you. I missed your
25 name.
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1 MR. PUTNAM: Putnam.
2 MR. STICKNEY: Mr. Putnam, we I know
3 that those of our staff working on the project have
4 done everything they could think of to make sure every-
5 body knew as much as they could about the project from
6 the newspaper supplements to newsletter to the cable
7 T.V. talk show.
8 Do you have any suggestions for a good
9 way to reach someone like you who feels he's not been
10 reached?
11 MR. PUTNAM: Well, the simple thing is,
12 are we in good shape right now? Does the water the
13 chemicals in the water, are we safe drinking it?
14 MR. STICKNEY: Okay, I guess I could
15 turn to whoever I should at the table -- does the
16 analyses that you've done show any significant ground
17 water problem at the present time?
18 MR. PUTNAM: What's the salt content?
19 That seemed to be pretty high. It's getting up every
20 year. I haven't heard anything myself about it, but
21 I've called the water department. They say it's
22 increasing every year. Also, the stuff we put on the
23 lawns, that's getting down there some time. I think it
24 ought to be controlled.
25 So, these are simple questions and it's
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1 because I don't have the information I'm asking, that's
2 all.
3 MR. STICKNEY: I think that I can just --
4 MR. KETCHUM: Excuse me, this is Burk
5 Ketchum. We did do extensive, as I mentioned before,
6 we did extensive testing of the surface water in the
7 ground water community and this information is all
8 contained in the appendix to the E.I.S. and essentially,
9 based on this information, we found no extensive pollu-
10 tion of the ground water or surface water in the commun-
11 ity at the present time requiring sewers and I believe
12 you can verify this, that based on our findings, due
13 to the flows and potentials for growth along Route 28
14 and the type of water users there, that there will be
15 an ultimate need for sewering in that particular area,
16 and that was essentially our finding.
17 The data and I will certainly go
18 through it, but if you have a copy of the document, it
19 is here, it has been summarized in the body of the
20 report and also in the appendix.
21 MR. PUTNAM: So you're talking sewers.
22 MR. KETCHUM: No, I'm talking, I believe,
23 water quality in general.
24 MR. PUTNAM: Yeah, how do you get rid
25 of chemicals? You can't do it, you can't filter it out
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1 You've got to accept the continual
2 MR. KETCHUM: Well, one of the ways that
3 we have recommended here and that replies to salting of
4 the roads and other solutions, and these are not
5 original with us. They have been included in the
6 studies which Paula Magnuson of the regional agency
7 has done, that there are non-structural measures require
8 to protect the water resources in the community.
9 Right at the outset of the Environmental
10 Impact Statement, we said that the problems aren't
11 critical at this particular point, but unless the
12 community d,oes
13 MR. PUTNAM: That's it.
14 MR. STICKNEY: -- initiate a whole array
15 of measures which include those of the Board of Health,
16 zoning measures. Board of Health staff which could be
17 expanded to provide more than response to critical
18 situations as they arise, then these can they're very
19 cost effective measures to eliminate problems in the
20 future and we were criticized at one of the previous
21 meetings that we had here a month or so ago for not
22 stressing this enough.
23 I believe the Planning Board said we
24 didn't point this out. Well, we wish to reiterate that
25 and we have stated this, that the alternatives for not
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1 taking very strong non-structural measures will be
2 rather extensive sewering in the community and the cost
3 that Joe has shown there would indicate that sewering
4 of many of the residential areas is a very expensive
5 option.
6 Adding a few people to the Board of
7 Health staff, improved zoning regulations, Board of
8 Health coverage, adequate coverage of conversions of
9 seasonal units all will help to solve some of those
10 problems.
11 MR. PUTNAM: Has anything been done so
12 far such as holding up on salting roads for one thing
13 and how about people throwing their dioxins on the land
14 and in their own home, kill bugs and so forth, what's
15 being done about that? Nothing?
16 MR. STICKNEY: Well, I think the town
17 has taken some measures. There were some proposals for
18 zoning changes, there were some proposals for zoning
19 protection around the wells. There may have been other
20 measures in connection with Board of Health.
21 I don't speak for the town and I really
22 can't answer that question.
23 MR. PUTNAM: Well, that's why I'm up
24 here. I know very little about what's going on and I
25 think most of the people are that way.
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1 MR. STICKNEY: Mr. Putnam, I hope you'll
2 be an interested participant
3 MR. PUTNAM: Well, I am.
4 MR. STICKNEY: from here on out
5 because the rest of the process will include collecting
6 all of the comments that are made orally here tonight
7 and in writing, analyzing them carefully and responding
8 to them in developing a project which is based not only
9 upon the work that's been done so far, but the comments
10 that will come in, so I hope you will take the oppor-
11 tunity to go through this information and comment
12 specifically on it.
13 MR. PUTNAM: Where do you get one of
14 those?
15 MR. STICKNEY: Pardon?
16 MR. PUTNAM: Where do you get one of
17 those?
18 MR. STICKNEY: Ken, can you help us
19 with that?
20 I1R- WOOD: The executive secretary has
21 a supply of them.
22 MR- PUTNAM: Now, those are proposals,
23 there's nothing being done? They're just proposals,
24 aren't they, that's in that book?
25 MR- STICKNEY: Right. From this, we hope
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1 a project, a concrete project will be developed.
2 MR. PUTNAM: That may be a few years.
Well, thank you.
4 MR. STICKNEY: Thank you. Is there
5 anyone else who would like to make a statement?
6 MR. LUKE: Yes, I would, as an individual
7 member of the Board of Selectmen. My name is Arthur
8 Luke, West Yarmouth.
9 In studying this, and before I got
10 involved in it, I had a question asked of me one night,
11 what I knew about sewerage, and I told the person I
12 knew how the problem started and I was hoping that I'd
13 learn how the problem would be taken care of.
14 I still don't see with the E.I.S. report
15 that we've found a way to take care of our problem in
16 the town. I think the report at this point is short-
17 sighted and does not take care of the problems that
18 are going to exist in this town twenty years hence.
19 Some of those of those problems that I
20 see -- and these are statements rather than questions
21 the seweraging that is proposed by the E.I.S. does not
22
take care of septage problems in areas that are current
23 underwater. I'm talking about cesspools that are sitti
24 in a ground area, the septic system is probably eight
25 feet into the ground and sitting in four feet of fresh
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water when it's built and I'm talking about a few years
2 back, not presently.
3 We have an area in town, Swan Lake, it's
4 got a high fecal chloroform content which, as the report
5 says, comes from blooded mammals, and yet that area is
6 not going to be taken care of under this plan.
7 The septage systems that we're supposed
8 to maintain in the town, we're supposed to pump on a
9 yearly basis. The report says that we are going to
1° take that and put it in a lagoon situation which is
what we have presently at the town dump.
12 That present system that we have now
13 at the town dump is probably closer to our well field
that was so highly talked about because of the barrels
15 that were out there. I believe personally that this is
16 more of a problem than those barrels were and I'm not
17 trying to take away from the impact of those barrels
18 that we had for a problem at the dump, but we're going
19 to transport to our town disposal area and put into a
20 lagoon system something that's eventually going to fall
21 into our town water.
22 Now, maybe we'll have to shut that well
23 down anyways because that dump's been there for twenty
24 years.
25 I don't know the answers to that, the
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1 water department does, but I still think that that is
2 not a system that we should be talking about in this
3 day and age.
4 I think that's something that should be
5 in the past tense. This report speaks to cost effec-
tiveness. The cost effectiveness is only to the federal
o
7 government as far as I can see in this report in that
8 it doesn't speak to the many systems that they're talking
9 about that the individual taxpayers in this town would
10 have to put in.
They speak to a neighborhood area that
isn't going to be seweraged. They say, "Take a lot of
land and maybe pump to that area to cure that problem."
I *3
Who's going to pay for that. Exactly where is that
15
16
17
18 government was supposed to speak to it or not, but I
19 have a hard time in my mind coming down to whether this
20 town should sewerage one mile or ninety miles without
21 knowing the total cost to the whole town, not just the
part of the town that's going to be seweraged.
23
24 change our outlook on allowing seasonal homes and
25 seasonal businesses to change to year-round. I've
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thought about that for a long time.
2 I can't think of a way in which we can
3 tell a homeowner that bought a home down here two years
4 ago, ten years ago, twenty years ago, that they and
5 they're looking forward to their retirement, can no
6 longer use their home year-round, they can only use it
7 seasonal, they'll have to go to Florida or go back to
8 where they were and I'm sorry you planned wrong, but
9 we've got to stop you now. That's not a good plan.
10 I just can't see it as a solution.
11 The report speaks to a specific flow for
12 Route 28 and the total businesses that are there now.
13 It doesn't speak to the fact and I think everybody
14 can quite quickly realize this, that this town is in
15 dire need of laundromats, so let's say we sewerage Route
16 28. What do you think is going to be one of the first
17 businesses to pop up on 28? Laundromats. What is the
18 increase in flow going to be? I don't read that any-
19 place.
20 I think we should be looking to the
21 future, not just to the present flow. Can Barnstable
22 handle that type of flow that's going to increase? I
23 haven't found that anyplace, found the answers to it.
24 Where does our water come from and how
25 much are we going to lower our water level if we take
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1 our water or our sewerage and put it into Barnstable?
2 Does our flow of water come from Barnstable, and if it
3 does, then it will be returned to our town and the water
4 level will remain constant maybe, but if I read the
5 report correctly, the water level in this town would be
6 going down approximately six inches.
7 Now, is that six inches per year so
8 eventually we're down many feet? And I'm speaking
9 strictly as a layman, maybe I missed a lot of points in
10 there, but I would like those answers. Thank you.
11 MR. STICKNEY: Well, thank you very
12 much, Mr. Luke, and you've raised some interesting
13 points. One very important one relative to cost effec-
14 tiveness, deals with a subject close to us all.
15 Dan, would you take a minute and explain
16 how we develop a funded project and how the cost
17 effectiveness values are computed?
18 MR. COUGHLIN: The term "cost effective-
19 ness" was developed under a really maybe developed
20 before then, but it was developed essentially and
21 widespreadly used after Public Law 92500 came into
22 existence in 1972, that's the Clean Water Act.
23 Essentially, it's a method by which we
24 compare alternatives for handling waste water for
25 treatment, collection or whatever type of project we
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1 would want to compare.
2 It requires that we look at each and
3 every alternative, assign a capital cost to it, an
4 operation and maintenance cost and use an economic
5 formula to bring those back to a common point of view
6 so that we can compare the alternatives. It's called
7 a present worth analysis which gets a little complex
8 when you get into it.
9 Essentially, it brings everything back
10 such that you can look at apples and apples and not
11 apples to oranges.
12 In one situation, the capital cost may
13 be high, the operation and maintenance cost low. Anothe
14 situation could be just reversed, and we have to bring
15 that back to a point where all the dollars can be
16 compared to the dollars for another alternative. That's
17 called a present worth evaluation.
18 In the cost effective analysis, we're
19 looking at the total project cost. That's the total
20 project cost, I guess you could say, to the federal
21 government if we were to fund the project, or to anybody
22 who was going to fund the project.
23 It's not necessarily aimed at looking
24 towards the cheapest method for the town to handle
25 their problem because under our law and under our regu-
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1 lations, we can only fund a cost effective project on
2 the basis of the total project cost, so it isn't
3 inconceivable that you could have an alternative where
4 it might be cheaper for the town to do one thing simply
5 because of political constraints or arrangements for
6 cost sharing, that might not be funded because it would
7 be more expensive to the federal government if we were
8 sharing the project so that's an important element to
9 understand. It doesn't usually happen that way, but it
10 can happen that way.
11 MR. STICKNEY: Dan, as a follow-up
12 question, not all portions of every project are
13 eligible for federal funding, are they?
14 MR. COUGHLIN: No, that's right. As I
15 said, the total project cost, the eligibility makes no
16 difference in the cost effective analysis and that's
17 another possible element that could throw the desire-
18 ability of an alternative one way or the other.
19 At the present time in Massachusetts
20 lateral sewers are not funded under our grant program.
21 The major portion of alternative two is lateral sewers.
22 If in fact you constructed alternative
23 two, then a more major portion of the project would not
24 be eligible for federal grants. In that particular
25 scenario, it would cost the town quite a bit more to
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1 fund the project and if it were as cost effective to do
2 that alternative as a non-sewering alternative, the
3 town would end up well, let me say, if it was more
4 cost effective to do that alternative, the town would
5 end up actually spending more money, but Uncle Sam
6 would actually end up spending less I mean, the total
7 project cost would actually be less.
8 MR. STICKNEY: Thank you, Dan. I was
9 interested in the concern for the lowering of the ground
10 water table. Did you study that in the E.I.S., Ken?
11 MR. WOOD: Yes, we did, Wally. Let me
12 read from a report prepared by U.S. Geological Survey,
13 John Guzwood (phonetically) did a modeling exercise.
14 I'll try to be brief, but let me read you this
15 paragraph:
16 "A rectangular area of approximately
17 170 acres under natural conditions was assumed to have
18 been developed for residential use. Water was supplied
19 to the area from a remote location, meaning town water
20 supply off-site, and waste water was discharged through
2i an on-site disposal system. The continuous waste water
22 flow rate of 110,000 gallons per day was assumed to be
23 uniformly distributed over the area. This flow rate is
24 equal to the projected 1955 flow rate for waste water
25 management solution service area B in the Town of Bourne
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1 and is approximately fifty percent greater than the
2 Anderson-Nichol's projected 1995 average peak flow for
3 isolated category two areas. This is data provided
4 by the Cape Cod Planning and Economic Development
5 Commission.
6 The results were, analysis of the effect
7 of this additional recharge, this means on-site disposal
8 indicates that the maximum height of rise of the water
9 table would be less than .5 foot in the center of the
10 developed area and would be neglible, less than one-
11 tenth of a foot at the periphery of the developed area.
12 Future conversion to a centralized waste
13 water collection and disposal system away from the area
14 Of interest would cause the water table to decline to
15 its original average position if there were no other
16 changes made which would affect a local recharge-
17 discharge balance.
18 This means that bringing water supply
19 in from a remote source of town water supply, dis-
20 charging it on-site raises the ground water mound in
21 an average condition to less than half a foot or about
22 half a foot.
23 Moving that on-site disposal, the ground
24 water retains its normal position six inches lower in
25 the center of the mound."
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1 Does that respond to your question, Mr.
2 Luke?
3 MR. LUKE: I'm not sure that it does.
4 MR. WOOD: It's not six inches per year.
5 This is allowing the ground water to return to its
6 normal position.
7 MR. LUKE: Yes, but what I'm speaking to
8 is the fact that we're pumping water from a town well
9 area --
10 MR. WOOD: Right.
MR. LUKE: area A, okay?
12 MR. WOOD: Right.
MR. LUKE: Now, the water we're normally
I O
14 building six inches higher is on 28, okay, and the norma
flow of the water, if I've understood you correctly, is
15
towards the sea, towards the ocean?
ID
1? MR. WOOD: Right.
MR. LUKE: So that's being taken out
18
anyways, so now we're bringing it back towards our
i y
well field, okay, which is going to again, if I've
understood correctly, there's a flow of water that
comes I'm trying to think of a wave-sort of action,
22
all right
23
MR. WOOD: No. Let me correct that. I
24
think I know where you're going. The ground water from
fcD
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1 the high point in Yarmouth toward the sea is a gradient,
2 right?
3 MR. LUKE: Uh-huh.
4 MR. WOOD: Okay. We're pumping water
5 from a supply well over here on to, say, a developed
6 area, one hundred and ten thousand gallons per day in
7 this hundred and seventy-six acre area, which is resi-
8 dential developments, all right?
9 Each of these residences disposes on
10 site. Within this one hundred and seventy-six acre
11 tract, the ground water, as a result of the on-site
12 discharge, is mounded six inches, but the gradient of
13 the ground water still retains the same direction. It's
14 merely creating a mound in this one area, but removing
15 that discharge lowers this ground water back to its
16 normal elevation, back to its normal gradient, there is
17 no net loss or gain.
18 MR. LUKE: Okay, that's where we differ
19 and I still differ, okay, and maybe I'm a hundred per-
20 cent wrong, but if we take it and we pump it to Barn-
21 stable and we lower that water level by five inches or
22 whatever it is, then the water that's up by the mid-Cap
23 and I'm speaking strictly as watching it run down a
24 hill, okay, if you lower that water level, you're
25 lowering the resistence to that water that's being held
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1
now
2 MR. WOOD: No.
3
MR- LUKE: which is then going to
4 lower the water throughout the whole area.
5 MR. WOOD: There must be a hydrologist
6 in the group who will bear me out, that raising the
7 ground water mound in one area does not create a back
8 pressure. Is this correct, Dr. Chiang?
9 DR. CHIANG: No, you're wrong. I'd like
10 to make a comment on that.
11 MR. STICKNEY: All right. Would you
12 DR. CHIANG: Dr. Edward Chiang, and I'm
13 a taxpayer in Yarmouth. If you took out the water six
14 inches, the first problem is you increase your ground
15 water hydro pre«:.-ure , you push more fresh water
16 into the ocean.
17 Another thing is, the fresh water, for
18 every foot you're above mean sea level is to push the
19 sea water down about forty-one to forty-two times that
20 one foot. You take out six inches, it would raise the
21 sea water on the bottom of the ground forty-one or
22 forty-two times higher than what it's now, so if we
23 pump the water, the sewer, whatever, pump to Barnstable,
24 that means Yarmouth has lost something.
25 Another thing I'd like to point out as a
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1 taxpayer, I think we generally, Americans, already feel
2 our government is too powerful and now E.P.A. comes into
3 the town, limiting us to when to use our house, how we
4 are going to use our house. I don't think that's
5 applicable.
6 This is exactly under alternatives three,
7 four, five, you're going to limit us, change our seasona
8 home to a year-round. I don't think it is applicable.
9 You may apply to a house which has not
10 been built yet, but I don't think you can apply to any
11 house built already.
12 MR. STICKNEY: Excuse me, Dr. Chiang,
13 will you be making written comments on the Impact
14 Statement?
15 DR. CHIANG: Yeah, I would. I would.
16 MR. STICKNEY: Good. I have a statement
17 here which was sent over Ken, whose statement is
18 this? I'm not sure now.
19 MR. WOOD: Dr. Whit lock.
20 MR. STICKNEY: Okay.
21 MR. WOOD: Herbert Whitlock.
22 MR. STICKNEY: From Dr. Herbert Whitlock,
23 from the Association for the Preservation of Cape Cod.
24 He asks that it be read or entered into the record and
25 it is a short one and it is as follows: "Waste water
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1 COLLECTION AND TREATMENT FACILITIES, YARMOUTH, MASSA-
2 CHUSETTS, APCC Statement Regarding Draft EIS.
3 Our comments are to be taken in conjunc-
4 tion with our position regarding the necessity of main-
taining Cape Cod's groundwater resource in as high a
6 quantity and quality as possible.
7 In view of the recent failures and
8 projected failures of various town wells, it would, in
9 our opinion, be most unwise to reclassify that portion
10 of Yarmouth's aquifer downgradient from Site D to Case
11 III. This is particularly pertinent since at their last
12 town meeting Yarmouth citizens failed to pass zoning
13 changes recommended to protect present and future well-
1" fields.
15 We believe that all recharge to ground-
16 water supply should be of drinking water quality, as
17 described in the Federal Standards, though even here it
18 would be wise to maintain a maximum of 5 parts per
19 million nitrate as nitrogen instead of the lesser
20 federal figure of 10 parts per million. At the very
21 least a figure of 10 parts per million of total nitro-
22 gen should not be exceeded. In addition, any super
23 chlorination process of septage is unacceptable because
24 of the hazardous by-products.
25 There appears to be considerable doubt
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1 whether Barnstable can or will accept all of the sewage
2 developed along Route 28, as suggested in the approved
3 alternative #3. Even if it could be processed by the
4 Hyannis plant, it may not be the most cost effective
5 if Barnstable's charges are excessive.
6 The treatment by the Draft EIS of how
7 septage is to be handled is most inadequate. Any long
8 term cost-effectiveness must consider that lagooning is
9 not a viable option on a permanent basis. From the
10 point of view of public health (even if presently
n acceptable to the Commonwealth), from the point of view
12 of esthetics, and from the environmental point of view
13 this method is unacceptable.
14 Three viable cost-effective methods
15 must be considered:
1. All Route 28 sewage plus all the
16
17 rest of Yarmouth septage pumpings.
2. Part of Route 28 sewage plus all of
to
19 the septage pumpings.
3 None of Route 28 sewage and only
20
21 septage pumpings.
Which of these three is picked must
22
23 depend upon Barnstable's response to the request that
24 they handle at least some of the sewage collected along
25 Route 28.
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1
In closing, we request that any proposed
2
plan for treatment of sewage, septage and the disposal
of effluent must meet drinking water quality standards
4
through pre-treatment and crop harvesting for discharge
5
into the groundwater system. Sludge treatment must be
o
such that leachate will meet these same standards."
That's a statement by the Association
8
for the Preservation of Cape Cod. In reading it, Ken,
9
it seems to me that I would need some clarification of
its three viable cost-effective methods. I'm not sure
that that is specific enough to be of use to us, but
12
that will be entered into the record along with the
13
other statements that are made tonight.
14
Are there any other comments?
15 MRS. SILVER: Mr. Stickney?
16 MR. STICKNEY: Yes, ma'am.
17 MRS. SILVER: Sally Silver. At one of
18 our previous meetings, the value of the Route 28 area
19 was questioned by some members of the public that were
20 here , the value of that area to the town as a whole,
21 and we have had our assessors office working for the
22 last two weeks to compile some general figures for us.
23 The total real estate assessment along
24 Route 28 is $31,517,250.00. We add to that the total
25 personal property assessment of $1,036,740.00 for an
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1 to the town of $32,553,990.00. This represents 63%
2 of the assessment of all of the commercial property in
3 the entire town. Also, 7% of the entire town's assess-
4 ment.
5 Of that, a third of those assessed values
6 are in motels, a sixth are in restaurants, both of which
7 are extremely high water users.
8 The income per year from that Route 28
9 strip at our present $18.80 tax rate is over $600,000.00
10 Per year, so I think in discussing the needs of the
11 Route 28 area, the town as a whole must look to it as
12 being a very important part of our town even though area
13 wise, it makes up much less.
14 One other question that doesn't deal with
15 that as much is, I question so many times in the report
16 the fact that if we did not sewer as much of the area
17 as we had originally discussed, why more interest was
18 not paid to the septage treatment, especially since the
19 town has been told for years of the need for something
20 to be done about our septage, and to me the solution
21 of the lagooning really was something that was just
22 pulled out and put in there, I felt.
23 I think that needs a great deal more
24 looking at.
25 MR. STICKNEY: Thank you very much.
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1 Yes, sir? You're next.
2 MR. MULLCANE: My name is John Mullcane
3 and I live in West Yarmouth, and for the almost twenty
4 years that I've lived on the Cape, and as a taxpayer in
5 the Town of Yarmouth all that time, I followed any of
6 waste water problems and sewerage problems we've had
7 with great interest, realizing that Yarmouth would face
8 it some day.
9 I followed Falmouth's problems over the
10 years and I guess it was my learning ground and I
11 followed with interest the outfall discussions and what
12 would happen to water supply if you pump your sewerage
13 and all that fresh water out into the ocean, terrible
14 things that would take place in the ocean, what happens
15 to your drinking supply, and it made sense to me when
16 they said it was proved more or less conclusively, I
17 believe, that it's not the right solution, that you
18 need to return the water supply back through the land
19 in a method that we can use it over and over again.
20 Then I became even more interested when
21 they decided to put this sewerage treatment plant right
22 next door to me and, you know, you have that feeling,
23 "Oh, God, not me, you know. I don't want to be the one
24 to say no, but " I listened to the engineering firm
25 at town meeting and asked a few questions and I walked
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1 over the land and wondered how they could be saying it
2 could actually take sewerage when right now the ponds
3 are at a very, very high level. The water level in the
4 town is very high and if we were to pull a couple of
5 the sluiceways that the people that run the bogs main-
6 tain to hold the water back from the ponds and shut them
7 off over where you want the sewerage treatment plant or
8 where it was suggested it go, Site D, we could flood
9 Site D.
10 I've walked through there when you have
11 to have rubbers just to walk around the edge of the bog,
12 so I wondered how that could be, and then the Environ-
13 mental Impact Statement, if you read it, you know that's
14 an undesireable site.
15 What I'm trying to say in my statement
16 is that the more I listen and the more I attend these
17 meetings and the more I read, the more confused I get.
18 I'm wondering if there is an equitable solution to all
19 these things.
20 We seem to be caught between a rock and
21 a hard place, it seems. I only have a couple of
22 questions though. The first is, is it a viable alter-
23 native to think that the Town of Barnstable, although
24 the Selectmen, you've made a statement, Selectmen have
25 open minds, will they really and truly accept our
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1 sewerage? If we're going to consider this plan in any
2 seriousness, is it a realistic appraisal to consider tha
3 actually that they will let us they will accept it?
4 Is it cost effective? And in looking at the report that
5 I picked up tonight, there's some vague statements about
6 the plant has been built to accept a hundred and fifty
7 thousand gallons per day of West Yarmouth's sewerage and
8 that confused me, to think that Barnstable would build
9 in anything before, you know, they made any agreements
10 with us.
11 There were a few statements in the paper
12 to the effect that the Selectmen as they presently are
13 aligned in Barnstable, are not amenable to this. Now,
14 whether that's true or not, I don't know, just from the
15 newspaper report.
16 So, if you could address that or if
17 anybody can address it, I would at least like to know
18 that much, whether we're considering something of any
19 value here or are they just going to say, "No thanks,
20 Yarmouth, we don't want your sewerage."
21 Second is the saptage treatment area. I
22 thought that it was explained very well at a town
23 meeting several years ago that one of the biggest and
24 main solutions we would have is to treat septage treat-
25 ment on land that the town owned up off of Old Townhouse
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Road and the people that sat there in well-dressed
2 clothes and explained it so logically and there were no
3 really intelligent questions or answers to it to explain
4 exactly how this treatment would work, and why it would
5 be good. It was a super-chlorinated treatment, and that
6 the resulting people would come and gather it up because
7 it would be so good as a treatment for the soils in thei
8 gardens and we were all having visions of great big huge
9 tomato plants and everything growing green and solutions
10 being taken care of.
11 Now, all of a sudden, this is unacceptabl
12 Letters are being read by doctors and statements are
13 statements are being made that no way this can be, it's
14 one of the worst things that we can do, and now there's
15 a septage treatment plant being proposed for Site D and
16 a method called lagooning which would be likened to just
17 throwing it on the open ground and containing it somehow
18 or other like we already do at the dump.
19 If there's somebody here tonight that
20 could at least give us a scenario, a description of
21 what septage treatment on Site D would be like, what it
22 would actually be like, how much area it would cover and
23 whether it would be good for us or not, some sort of a
24 description so I could go away with some understanding
25 of what you have in mind.
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1 MR. STICKNEY: I think, John, that Mr.
2 Ketchum can explain the reasoning that went into the
3 E.I.S. I'm not sure the Selectmen wish to discuss any
4 delicate negotiations which may be going on with Barn-
5 stable, but certainly they may if they wish. Burk?
6 MR. KETCHUM: I think your question
7 and Wally probably put it correctly, there are nego-
8 tiations going on and Paula Magnuson of the Cape Code
9 Planning and Economic Development Commission mentioned
10 that a meeting is being scheduled between the Selectmen
11 of the two communities, I believe within the next couple
12 of weeks, so that the wheels are rolling in that respect
13 and that's about all I can say in terms of whether it's
14 a viable option.
15 Before we did complete the Environmental
16 Impact Statement, we did work to get a joint meeting
17 which I attended with the Selectmen of Branstable and
18 Yarmouth, which I understand was a historic meeting, but
19 the meeting was held and now I understand a second
20 meeting, so that I think it's still a viable option.
21 As far as the lagooning and septage
22 treatment, I'd like Joe just to tell you briefly what
23 that's all about.
24 MR. ZENESKI: Well, basically the septage
25 disposal facility we envision for Site D is very simply
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1 a lagoon, a hole in the ground, where the solids, the
2 septage can be settled as best it can, the liquid portioji
3 would then flow out of that lagoon, out of that hole,
4 onto another piece of soil where it would leech into the
5 ground.
6 The solids could then be scraped out
7 periodically and dealt with. It's not a high technology
8 process, it's probably I would guess if you have a
9 hole in the ground now where septage is dumped, it might
10 appear about the same.
11 The reason we selected Site D, however,
12 is because there would be less impact on the wells.
13 Obviously Site D has been described a number of times
14 here and in the past as downgradient from the wells
15 and that we felt that, one, it would have no impact on
16 existing wells and we suspect no future wells, and also
17 that in the future if more capacity were needed, that
18 that then could be received from Barnstable, the site
19 would be available.
20 MR. KETCHUM: I think there's one other
21 thing in terms of the state's attitude with respect to
22 this type of facility. I don't believe the rules are
23 clear are they, Dan?
24 MR. COUGHLIN: No, right at this point
25 in time, the state has determined or has stated, not
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officially but verbally, that sepage lagooning is an
2 interim measure or an interim solution to a septage
handling problem.
4
We have seen septage lagooning work quite
well country-wide in some situations. We have a couple
6 in Massachusetts where it works, where one of the pur-
7 poses of putting that alternative in the E.I.S. was to
Q
get an official statement from the Department of
9 Environmental Quality Engineering as to whether or not
10 it is a temporary solution in their mind and exactly why
11 they feel that way.
12 The issue of type of septage treatment
is not a closed one at this point in time. There were
14 other alternatives or at least one other alternative
15 presented in the E.I.S., that being composting.
16 Lagooning was cheaper. There are other alternatives
17 that could be utilized such as presented in the proposed
18 plan or lime stabilization type of techniques. There
19 are other techniques available.
20 I don't think we will end here on the
21 final E.I.S. I think the question will be addressed in
quite a bit more detail in the final E.I.S., so just
23 based on the amount of comments we've tonight and in
24 previous meetings.
25 MR. STICKNEY: Right, certainly it is an
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1 important issue. Where might someone go to see a lagoon
2 system in operation?
3 MR. COUGHLIN: I think there's one up in
* Acton, isn't there, that the state has seen fit, for
5 some reason or not, I believe, not to determine it as
6 temporary and I'm not sure. There's some difference of
7 opinion from one region to the other between the various
8 regional state agencies, and that one apparently does
9 work without too much problem.
10 MR. STICKNEY: Did the Selectmen wish
11 to respond to that question about Barnstable? You don't
12 have to, I'm just giving you an opportunity if you wish.
13 MRS. SILVER: You mean insofar as our
14 discussions with Barnstable?
15 MR. MULLCANE: Well, excuse me, Sally,
16 you know, if you have ongoing negotiations and naturally
17 if they're delicate, I wouldn't expect an answer. It's
18 just that nothing publicly has come out and I guess I
19 could make an assumption that if you're considering it
20 in this report, but there are so many people here, are
21 we actually, the Town of Yarmouth people, expected to
22 give it serious consideration? I guess not until such
23 time as you've nailed it down between the two of you.
24 MRS. SILVER: When they say the wheels
25 are moving, I have the feeling they're going around and
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around and around and
2 MR. MULLCANE: Yeah, well you could
you know, being an observer of almost twenty years, you
can read between the lines and I think it would be a
minor miracle if you pulled it off, really. That would
6 be my own personal opinion and I think it would be a
7 part of the solution. Obviously a little bit of every-
° thing may be the answer to Yarmouth is my comment now
9 and one other thing is a lagooning system in Site D
10 would be totally, completely, absolutely unacceptable
11 to me and to, I'm sure, to the neighborhood that I live
12 in.
13 We already have a lagoon and if that's
14 the way we're going to go, just keeping using the one
15 we've got. After all, it's right next to the town dump
16 and if somebody's going to have a shut a well down in a
17 few years because of whatever is leeching out of the
18 town dump and out of that lagoon, let's shut that one
19 well down and let us not spoil what is potentially a
20 very or is a beautiful area of the town right now.
21 MR. STICKNEY: Thank you, John. Are
22 there other questions or comments? Yes, sir?
23 MR. HICKMAN: My name is Robert Hickman
24 from Whitman and Howard. I happen to be the town
25 engineer for the Town of Barnstable. I am not speaking
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for the Town of Barnstable.
2 We have some very serious reservations
3 about the present status or condition of the draft E.I.S
4 I realize it's a draft E.I.S. However, it's supposed to
5 be, from what we have determined, in a form with some
6 slight minor modifications based on public input, can
7 provide the community with a real strong recommendation
8 on which way to go and unless I'm mistaken, the recommen-
9 dation of the report as it stands now is to go to Barn-
10 stable, yet there are no serious negotiations as far as
11 being resolved at this point in time.
12 From a company standpoint, having preparejd
13 the initial facilities plan, which recommended a much
14 smaller than a seventy-seven million dollar sewerage
15 system, we find it quite amazing that there are three
16 or four other alternatives, none of which included the
17 recommended plan in the facilities plan and we don't
18 think anybody can say, "Well, we didn't realize that's
19 what you proposed." In fact, a Step 2 Grant Applicatior
20 Was filed to E.P.A. for a much smaller scale system
21 which included use of Site D, about a 2 MGD treatment
22 plant, sewering portions of Route 28 and portions of
23 south of Route 28 that we felt when we did the facilities
24 plan, adequate need justified design for sewers.
25 Also, in preparing a facilities plan
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1 for a community, a consultant must look at the future,
2 not just do a need survey and say these are the needs
3 of the community.
4 It may be the needs of the community for
5 that particular day that the reports came in, but not
6 for the future, so we feel that in the final E.I.S., at
7 the very least, one other alternative should be inves-
8 tigated, which is, what was recommended and applied for
9 through E.P.A. by the Town of Yarmouth.
10 On the matter of lagooning, we feel that
11 the E.I.S. should at least address all viable alterna-
12 tives for treatment of septage.
13 We feel that the statement of lagooning
14 of septage would be the answer, I believe many comments
15 have been made here tonight which I think are well
16 founded, that lagooning is an interim solution to a
17 septage treatment problem.
18 We feel that the facilities plan did
19 present an alternative which should be addressed in
20 much more detail in the Impact Statement, that being
21 purofax (phonetically) treatment of septage.
22 We also think that there are other
23 means of septage treatment that should be addressed,
24 as Dan pointed out earlier, but they should be in the
25 written part of the E.I.S.
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We agree that there is a problem in
2 getting the Commonwealth of Massachusetts, D.E.Q.E.
to agree on what is an acceptable means of long-term
treatment of septage. There are many that are accepted
5 throughout the country and that are funded by E.P.A.,
6 some of which are being rejected as a viable alternative
7 for Yarmouth, namely purofax.
8 We think it should be more adequately
9 supported in the E.I.S. if there is documentation for
10 rejection.
11 In regard to the matter that Arthur
12 Luke brought up about pumping out of ground water and
13 bringing it to Barnstable, working in Barnstable, I am
14 aware of the area of discharge of the treatment plant
15 effluent. It does not flow towards Yarmouth where water
16 is taken for water supply.
17 A very beneficial advantage, if you will,
18 happens if Site D was to be used by Yarmouth for dis-
19 posal of waste treatment, whether it be a very small
20 plant or a larger scale plant, and that is to generate
21 a mound that in turn does change the hydrolic gradience
22 of the ground water and in fact many of Yarmouth's
23 water supply wells are between the Site D and the Mid-
24 Cape Highway.
25 Therefore, it would in fact build up a
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1 greater reserve of fresh water that could be used by
2 the Town of Yarmouth for its water needs. We think this
3 should be addressed in greater detail.
4 That's all I have to say at this time.
5 MR. STICKNEY: Dan, what was the dispo-
6 sition of that two million gallon a day grant request?
1 MR. COUGHLIN: The disposition was the
8 E.I.S., to be quite honest. As we saw the report, Bob,
9 the original 1975 report in its first page, I think,
10 indicated a 5 MGD system by the year 2000 and that's in
11 my report.
12 Now, we recognize the environmental
13 assessment, some one year later you recommended going
14 and that's 5 MGD's eventually, but at least by the year
15 2000.
16 , You backed off a little bit and said
17 the alternative would be a 2 MGD plant with sewering of
18 I'm not sure how many sub-areas, for the treatment plant
19 alternative D, but again, it indicated that you could
20 sewer the entire area up to 5 MGD within the thirteen
21 year period and that was still an open option, and in
22 fact you were to include capacity within the intercep-
23 tor system for that sewering.
24 There really was no alternative for us
25 to look at that system other than a twenty-year plan for
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sewering the entire service area and that's how we looked
2 at it.
3 Our proposed plan in the E.I.S. also
4 covers a twenty-year planning life.
5 MR. STICKNEY: Are there other questions
6 or comments? Yes, sir?
7 MR. HATTAWAY: I don't want to press the
8 point of Whitman-Howard trying to go against the E.I.S.
9 because
10 MR. STICKNEY: Would you identify your-
11 self, sir?
12 MR. HATTAWAY: Charles Hattaway from
13 Whitman-Howard. I was one of the project engineers on
14 this particular facilities plan. I'd like to refresh
15 Dan's memories, that in our recommendations of the
16 E.I.S. I mean, of the proposed sewage treatment
17 plant that were submitted to his office, we recommended
18 only that they construct a two million gallon plant and
19 only a collection system capable of handling that kind
20 of flow and only servicing the area south of 28, and
21 as Dan must recognize hydrologically, a sewer that is
22 designed for eight-tenths full, which is the normal
23 criteria used, plus the peaking factors which are
24 supposed to be used, and I don't want to get too
25 technical, but the point being is you can always sur-
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1 charge a sewer to take more, so as far as an eight-inch
2 sewer taking a little bit more, you can do so and
3 increase the capacities and a detailed evaluation of
4 the collection system proposed obviously represented the
5 fact that the system being requested by Yarmouth was not
6 a collection system in that area that he is proposing,
7 taking a five million gallon flow, so actually, in
8 essence, the request by Yarmouth was just a two million
9 gallon treatment plant and a collection system capable
10 of handling such a flow.
n MR. STICKNEY: I presume that in the
12 final E.I.S. as we develop it will respond specifically
13 to those
14 MR. COUGHLIN: There's no way I can
15 answer you, Chuck. I just read the thing before I came
16 down and I read it just the other way around. You can
17 read it either way you want and it's easy enough to get
18 up and say, "Well, we didn't mean that," but the way the
19 thing came to us was a 2 MGD plant or a 3 M3D plant
expandable to a 5 MGD and that's the way we had to
look at it under our rules and regulations, there was
no other way we could look at it.
23 MR. TALLMAN: Sir, may I speak? I
happen to have been a member of the Board at the time
that the sewer
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1 MR. STICKNEY: Excuse me, sir, would you
2 identify yourself?
3 MR. TALLMAN: I'm Mr. Tallman, Selectmen
4 of the Town of Yarmouth.
5 MR. STICKNEY: Thank you.
6 MR. TALLMAN: I was one of the members
7 of the Board when the original plan was initiated. It
8 was not initiated for a complete sewerage, it was
9 initiated as it has been stated here tonight, to take
10 care of a small area.
11 They wrote a plan, what would eventually
12 be the needs of the town. There was no intent, there
13 was no intent at the meetings held at the school buildin
14 in the auditoriums, it was explained to the public, what
15 the intent was and it was an intent for a very small
16 sewerage system, but we were planning ahead, which is
17 supposed to be good business, but apparently some people
18 don't think so today.
19 MR. STICKNEY: Sir yes, sir?
20 MR. MOFFAT: My name is Don Mo f fat and
21 I'm with B.I.F., Unit of General Signal from West Warwick
22 Rhode Island. We are the manufacturers of the equipment
23 to treat septic tank sludge by the process of rapid
24 chemical oxidation, the purofax process.
25 At Yarmouth when the process was pro-
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1 posed, there was some number of questions raised. There
2 were some inuendoes and there were some outright false-
3 hoods.
4 As a result of proposing that for the
5 Yarmouth project, the E.P.A., in Cincinnati, was
6 requested to obtain samples of septic tank sludge and
7 run some analyses before and after treatment. This
8 they did and published a report.
9 The report answers only a very small
10 portion of the questions that were raised. It was not
11 done in great depth and it in turn left some number of
12 questions unanswered.
13 B.I.F. retained a number of consultants
14 in the academic scientific world to study the problems
15 and study the questions and arrive at answers and on
16 April the 4th of this year, those people met with the
17 E.P.A. in Washington, D.C., essentially chaired on the
18 part of the E.P.A. by Harold P. K. Hill, Jr., Director
19 of the Municipal Construction Division of the Environ-
20 mental Protection Agency, and subsequently on April 27,
21 1979, the oral presentation was submitted to the E.P.A.
22 in a written form. To help clarify some of the questions
23 that were raised relative to this process for septic
24 tank sludge treatment at Yarmouth, we request that this
25 be entered as part of the record on the draft E.I.S.
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1 MR. STICKNEY: Would you read that title
2 completely, Mr. Moffat?
3 MR. MOFFAT: B.I.F. Submission to the
4 E.P.A. in Support of the Purofax Process for Sludge and
5 Septage Treatment. I'll read it all if you'd like.
6 MR. STICKNEY: Thank you, we'll do with-
7 out it. Could you also reference the E.P.A. report
8 more precisely, the one you referred to?
9 MR. MOFFAT: The E.P.A. report which
10 addressed and answered a part of a number of the
H questions but not all of them, and I think the title
12 will tell you this, it's E.P.A. Report 600/2-78-020,
13 Partial Characterization of Chlorinated Organics in
14 Super-Chlorinated Septages and Mixed Sludges.
MR. STICKNEY: And the date of the E.P.A
ID
16 report?
17 MR. MOFFAT: March, 1978.
18 MR. STICKNEY: Thank you. It will become
19 part of the record.
2Q MR. MOFFAT: Thank you.
MR. STICKNEY: Are there other comments
that need to be made? I know that we will not be able
to respond to every comment or develop every issue
completely tonight and that there will be extensive,
specific comments made by various levels of government
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23
24
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1 before the end of the comment period, so this is a step
2 in the process, but not a complete step. Are there
3 other comments here? Yes, ma'am?
4 MRS. PUTNAM: Not a comment, a question.
5 MR. STICKNEY: Could you use the micro-
6 phone and state your name?
7 MRS. PUTNAM: I'm Mrs. Roy Putnam and
8 i wanted to know if any survey had been made to find out
9 how many people can be, well, safely put on the Cape as
10 far as water, as far as sewerage, and all other facili-
11 ties.
12 Also, this gentleman on the end spoke
13 of lagoons in some towns acting well. Now, was that
14 because it was a smaller town, fewer people?
15 MR. STICKNEY: Okay, as far as the
16 studies that are available Cape-wide, Paula Magnuson,
17 Can I put you on the spot? I think you probably are
18 better able to respond to that than we are.
19 MS. MAGNUSON: We have worked on a Cape-
wide waste water management plan and water quality
management plan. We have -- we started out wondering
if it was possible to come up with that kind of a
figure and obviously it's not because it's a question
of what you're willing to pay and how much environmen-
25 tal degradation you're willing to accept. If you paid
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1 to sewer everybody and provide tertiary treatment of the
2 water, perhaps there's an unlimited number of people
3 that could live on the Cape.
4 Our approach has been to recommend that
5 water supplies be protected by zoning and regulatory
6 measures and when you start talking about protecting a
7 well, you're talking about maybe a square mile for a
8 million gallon a day well, within which you don't want
9 housing densities to exceed one house per sixty thousand
10 square feet overall density.
11 When you start doing that, you approach
12 a point where you can't add any more people outside the
13 well area because the well area gets so big, and we're
14 beginning to get a feel for where that point is.
15 We don't see it -- well, in analyzing
16 the Town of Yarmouth in which we are working on a
17 project with the Water Quality Advisory Committee,
18 we've looked at different sections of Yarmouth to see
19 how the areas around the wells stack up against these
20 density recommendations and in fact, in some areas,
21 shall I say it' s maybe south of the dump in a segment
22 towards the water, the density already exceeds what we
23 would have recommended.
24 Therefore, you might say that section
25 has exceeded the amount we're talking about. In other
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1 areas in the western part of the town, it's relatively
2 undeveloped and you could do a preventive zoning approach
3
and the zoning changes that were presented last fall
4 would be part of that kind of an approach to protect
5 the water supply, so it's not an easy answer and all we
6 can say is that we are certainly at a point of talking
7 about preventive programs everywhere on the Cape except
8 perhaps Provincetown where you haven't really reached
9 an end point where you can't do something about it and
10 we're hoping that through the preventive programs, you
11 can avoid that final question of how much is it going to
12 cost and how much are we going to have to degrade the
13 environment.
14 It's not a specific answer, but it's not
an easy question.
MR. STICKNEY: Thank you, Paula, and
17 Acton is a town northwest of Boston of about 20,000
18 people, a burgeoning suburban town, as I know it,
19 and they would, I guess, treat something in the order
20 of twelve or thirteen thousand gallons a day at their
21 system.
22 Are there other questions or comments?
23 MR. GREENE: I have a few questions.
24 Franklin Greene, I'm a Selectmen in Yarmouth. I asked
25 the same question before and the gentleman in the gray
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1 suit, I hope he answers it for me tonight.
2 I have a piece of property assessed at
3 $700,000.00 with a potential daily flow rate of 2800
4 to 3000 gallons. What is it going to cost me per year?
5 MR. ZENESKI: For what?
6 MR. GREENE: I asked that question when
7 you were here before and I presume you're going to give
8 me an answer, but
9 MR. ZENESKI: Yeah, I can answer that.
10 I touched on that early on. I didn't know what your
11 assessed value or sewage flow would be, but you're
12 telling me now that it's $70,000.00?
13 MR. GREENE: $700,000.00.
14 MR. ZENESKI: $700,000.00 is your
15 assessed value?
16 MR. GREENE: Assessed valuation.
17 MR. ZENESKI: All right, and your
18 potential flow?
19 MR. GREENE: 2800 to 3000 gallons per
20 day.
21 MR. ZENESKI: Well, let's use 3000
22 gallons per day.
23 MR. KETCHUM: Why don't we let him
24 figure this out we'll
25 MR. GREENE: Okay, I've got a couple of
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1 other questions. In lagooning systems, if I understand
2 it, what happens when the wind blows and the houses
3 down-wind of it?
4 MR. ZENESKI: Oh, the odor problem.
5 On the lagooning system, there is the potential obviousl
6 for some odor problems, yeah. If that's what the
7 question refers to, yes.
8 MR. GREENE: That's what I'm trying to
9 bring out. On a sixteen million dollar project, how muc
10 federal funding in dollars now, not in percentages or
11 anything else, I'm talking dollar bills, to the town
12 would come in?
13 MR. ZENESKI: On any sixteen million
14 dollar project or on a particular sixteen million dollar
15 project?
16 MR. GREENE: On three, four and five
17 MR. ZENESKI: Those numbers are in the
18 report, sir. I believe it's in an appendix that we
19 went through that cost calculation.
20 MR. GREENE: But a lot of people out
21 here don't have that report, so why don't you tell them
22 exactly what federal funding money would be
23 MR. STICKNEY: If I might, before we
24 begin to give the figures, the final figures on federal
25 funding will depend on whatever portions of the final
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1 system are declared to be eligible for federal funding
2 and the eligibility of the joint determination between
3 E.P.A. and the state.
4 I'm sure these are good estimates, but
5 the final numbers, the exact numbers would have to wait
6 until the development of a specific project.
7 MR. GREENE: Well, say we sewered Route
8 28 only, approximately what would be the amount of money
9 being reimbursed?
10 MR. COUGHLIN: Generally speaking, Route
11 28 would involve an interceptor. Under the present
12 program in Massachusetts, interceptors, treatment
13 plants, pump stations, force mains are eligible for
14 federal grants in the amount of seventy-five percent,
15 the state kicks in another fifteen percent. House
16 connections and that type of thing are not eligible,
17 so those are costs that would have to be borne entirely
1B by the town or the individual connecting in.
19 So, under that particular project, that
20 probably is the project in compared with alternative
21 two that would have the maximum amount of federal
22 funding.
23 Again, it's up to the state to put a
priority on what elements of a sewer system they want
to place federal funding on. I think it's a rather hare
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1 question to give you an exact dollar figure, but overall
2 that particular project would have a relatively high
3 amount of federal funding.
4 MR. STICKNEY: Does the information
5 presented so far give ball-park figures for those two
6 alternatives that you just mentioned, Dan?
7 MR. COUGHLIN: I don't know. Have you
8 found it, Joe? I think it was in Table C-l that the
9 calculations were made based upon a certain amount of
10 federal funding, but I don't think it broke it out in
11 dollars and cents exactly, exactly how much, Wally.
12 MR. STICKNEY: Okay.
13 MR. COUGHLIN: So, it's something we'd
14 have to look at.
15 MR. STICKNEY: Well, let's see.
16 MR- COUGHLIN: So, as it stands right
17 now, this is something we'd have to develop more
18 specifically.
19 MR. STICKNEY: Yes, it would appear
20 that way to me unless Anderon-Nichols can find some-
2i thing. Do you have another question, sir?
22 MR- GREENE: The treatment plant or
23 y°ur report, at least the part ~ I couldn't find it -
24 doesn't address what we're doing up at the lagoons up
25 at the disposal area right now, and that to me as far
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1 as -- going back to what Mr. Tallman said, I was not on
2 the Board of Selectmen, but I sat on the Finance Commit-
3 tee, and it seems to me that was a number one priority,
4 to try and put up some kind of a treatment plant up
5 there to take care of these honey wagons, so-called,
6 night soil or whatever you want to call it, but you don
7 seem to address that too much. Am I correct?
8 MR. KETCHUM: Well, I think the question
9 of the problem at the site is addressed. In our dis-
10 cussion, we addressed the need for septage disposal
11 under each of the alternatives and these the lagoonin
12 was one that was discussed and that essentially is what
13 we recommended.
14 There is a discussion of septage treat-
15 ment not on the present site.
16 MR. STICKNEY: Sir, would you anticipate
17 that the town might request funding for a septage
18 facility only without a sewerage collection system?
19 MR. GREENE: What I'm driving at is if
20 the town requested strictly funding for the system up
21 at the town disposal area to take care of this night
22 soil, which is septic tank pumping is in essence what
23 I'm talking about, if we just requested that amount and
24 no other sewerage at all. That's what I think should
25 be addressed on one area.
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1 MR. STICKNEY: Thank you.
2 MR. KETCHUM: We'll get back to you with
3 the answer
4 MR. GREENE: Oh, is he still calculating
5 over there?
6 MR. ZENESKI: In between questions, I'm
7 trying to --
8 MR. COUGHLIN: Wally, if I could address
9 that one thing on the septage treatment facility, one
10 of the major reasons it was located the two major
11 reasons it was located at Site D, number one, it was
12 downstream from the wells --I'm sorry.
13 The septage treatment plant in the
14 E.I.S. was located or supposed to be located at Site
15 D for two reasons. First, it was downstream of the
16 water supply wells. Secondly, that is assuming that
17 the alternative for going to Barnstable is the alter-
18 native that is selected.
19 Now, Barnstable may or may not give you
20 all the capacity you want. If in fact you go to Barn-
21 stable and they give you 300,000 gallons per day which
22 is present-day estimated flow is 340, and it turns out
23 sometime in the future, we may want to sewer some other
24 area without federal funds or if some area crops up
25 and has problems, you don't have any place to go and
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I
1
2
5
you may have sold Site D. .That's the only site we
could find in the E.I.S. that was really left for a
3
treatment plant.
4
This utilizes Barnstable alternative and
Site D as well and it leaves Site D open for future
6 options should additional flow have to be developed or
7 additional capacity has to be developed.
g
So, those are two reasons why that sep-
g
tage treatment plant was placed there. The other impor-
10 tant thing to understand is and I said it before, the
11 issue or the whole E.I.S. shouldn't be clouded just by
12 the septage issue.
The major issue was the extent of the
14 sewering system proposed as far as we could see. There
15 are any number of septage treatment options which would
16 be considered and will be considered and I can assure
17 you will be addressed in the final E.I.S. in a little
18 bit more detail.
We're in the throes of trying to evaluate
20 this lagooning system to see if in fact it is a good
21 option for Yarmouth. It has worked in other places, as
22 I've said before.
23 MR. STICKNEY: Are you still figuring?
24 MR. ZENESKI: No, I have some numbers.
25 i thought that we had published the distribution of
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1 federal and state grants and apparently have not and
2 we'll get that in the final report, but for your hypo-
3 thetical building assessed at $700,000.00 and discharging
4 3000 gallons per day into the sewer system, under the
5 alternative two as was pointed out here earlier, you
6 have to keep in mind the basis for our assumptions.
7 First of all, there's two methods to
8 collect the capital cost, that is, the cost that would
9 be left over to be borne by the town after state and
10 federal grants.
n Now, the one way to do it is to say that
12 everyone has an equal opportunity to use the sewer so
13 they'll pay an equal share for that cost. That's one
14 method, so we would just divide by the number of users,
15 and then your capital cost, your annual capital cost,
16 would then be $506.00 a year for your particular unit.
17 If, on the other hand, the town says,
18 "Well, we're going to sewer most of the town anyway as
19 we've interpreted the Whitman and Howard proposal," the
20 tax increase we estimate would be $11.61. That's about
21 seventy-five percent of what it currently is, so that
22 y°ur tax bill for sewers at an assessed value of
23 $700,000.00 would be $8,127.00 a year, okay?
24 MR. GREENE: Compared to the thirteen I
25 Pay right now.
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1 MR. LUKE: Yeah, but we're not talking
2 about system two anyway, so that's
3 MR. ZENESKI: All right, so you want to
4 use that as a basis of comparison, right? Now, under
5 alternative three that we're recommending, the same
6 numbers would apply or basically the same break-down
7 would apply, you would pay $550.00 a year for the capita
8 cost if only the users, the users on the commercial
9 strip shared the cost.
10 If it were collected through taxes, and
11 that is, that everyone in town were to share the cost
12 of building the sewers on the commercial strip, then
13 your cost would be $266.00, you'd pay slightly less
14 because everyone else would be sharing with you.
15 It's analagous to the situation in
16 schools where people without children subsidize the
17 people who have children, et cetera.
18 Your operation and maintenance cost now,
19 the annual cost for using the sewer would be about
20 $1100.00, so your total costs added together is $1600.00
21 in the one case, $1300.00 in the other case.
I hope that answers your question.
MR. WILSON: In the past few days, I've
tO
24 had an opportunity to calculate the possible sewerage
25 flows along Route 28. Based on actual meter readings
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1 and Title Five requirements, I came up with a figure of
2 780,000 gallons per day. I'd be glad to share how I
3 arrived at my figures if you will tell me how you got
4 yours of 360,000.
5 MR. STICKNEY: Would you be glad to
6 submit your figures for the record, sir?
7 MR. NILSON: Sure.
8 MR. STICKNEY: Okay. Would you repeat
9 those for my benefit again?
10 MR. NILSON: I came up with 780,000
11 versus your 360,000.
12 MR. STICKNEY: And that was based on
13 water meter, actual merer readings?
14 MR. NILSON: Correct.
15 MR. STICKNEY: And Title Five I'm not
16 sure I
17 MR. NILSON: Title Five requirements.
18 MR. STICKNEY: And what is that?
19 MR. NILSON: That's the state sanitary
20 code of the Commonwealth of Massachusetts.
21 MR. STICKNEY: If let me try again.
22 Y°u used Title Five where you didn't have water meters
23 to read?
24 MR. NILSON: Where I didn't have enough
25 data on water meters in a peak period of time and with-
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1 out trying to use some type of an adjustment factor for
2 peak-day flow.
3 MR. STICKNEY: So your meters are
4 averaged out over a quarterly period or something like
5 that?
6 MR. NILSON: For twelve months, to
7 anywhere from eleven months to fourteen months.
8 MR. STICKNEY: And then you had to
9 estimate what the peak daily might be from that?
10 MR. NILSON: No, I yes, I did in some
1T instances and in other instances, I just strictly took
12 the unit or seating capacity and used the Title Five
13 requirements that would be the design criteria for an
14 on-site system.
15 MR. ZENESKI: Could I ask for clarifi-
16 cation? On the numbers you just gave us, the 780,000
17 versus 360,000, you're referring to the summer flows,
18 the peak summer flows?
,_ MR. NILSON: That's exactly correct,
i y
20 the peak flown.
MR. ZENESKI: So these are peak in
22 gallons per day?
MR. NILSON: In gallons per day.
£.0
MR. ZENESKI: Very good.
24
MR. STICKNEY: Dan, in developing the
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1 prior numbers do you know what the sources were?
2 MR. COUGHLIN: It was my understanding
3 the sources were the Yarmouth water department and it's
4 unfortunate if the Yarmouth water department is going to
5 come up with different numbers now. We certainly could
6 have used them in the early phases of the Yarmouth
7 E.I.S.
8 We've been trying to come up with good
9 numbers for quite some time.
10 MR. STICKNEY: Is one of the issues
11 whether or not you're using average annual flows as
12 compared to average daily or peak daily?
13 MR. NILSON: I'd be glad to respond to
14 the question that this gentleman here just made as to
15 the figures used by Anderson-Nichols.
16 I used the same material that was avail-
17 able to you that's available to me, other than I did go
18 out and physically check all these structures, I did
19 take the time to use the data that's available to you
20 and to everybody.
21 MR. COUGHLIN: Okay, then we'll be
22 verY interested in seeing that. If we've made an error,
23 we certainly want to know.
24 MR. STICKNEY: Thank you. Are there
25 other questions or comments on the report?
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1
MR. GANNON: My name is Joseph Gannon,
I live in Brookhaven, South Yarmouth, with all the
3 unanswered questions, I don't know where to start, but
we should start calling this the sewering on Route 28,
not the sewering of Yarmouth. This is what we're talkin
6 about.
If we have a problem on 28, I can't
8 understand how we're continuing to build restaurants
9 up there. Now, I don't know if Barnstable's going to
10 accept this. I know they complain about the smell of
11 it now when they get to Yarmouth, so do we have a
12 contract, they're going to take it for ten years or
13 for life or
14 MR. STICKNEY: First of all, spell your
15 last name.
16 MR. GANNON: Gannon, G-a-n-n-o-n.
17 MR. STICKNEY: Oh, Joe Gannon, okay.
18 MR. GANNON: It seems that after each
19 speaker, we have a question without an answer. We just
20 had the water and your group and another unanswered
21 question. We haven't had the answer to how much water
22 we can send to Barnstable, we haven't had the answer yet
23 how much water we're going to lose when we do send it.
24 I'm confused. And then my group would like to know
25 what it would cost the taxpayers in Brookhaven.
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1 MR. STICKNEY: Now, I assume that
2 Brookhaven is a discernable area of the town that
3 we're familiar with?
4 MRS. SILVER: It's a subdivided area in
5 South and West Yarmouth, it's a subdivision area.
6 MR. ZENESKI: Apparently the question is
7 what's it going to cost me. Will you be on the sewer,
8 sir? All right, as I pointed out earlier, we tried to
9 present a lot of information in one table and apparent-
10 ly, we're having a lot of trouble with that. We're
11 trying to demonstrate that there are a couple of methods
12 of recovering the cost of the project.
13 One of the methods here in this column
14 is that the sewer-user pays all costs. That is, the
15 fellow who uses the sewer pays for the installation of
16 the sewer or that share that the federal government
17 doesn't pay for, and his annual use charge. He'd pay
13 that anyway.
jg In the other column, we're assuming
20 that there's a town-wide sharing of costs, that the
21 town says, "Oh, it would be nice to have sewers on
22 Route 28 and let's all chip in and buy them." Well,
23 some people do that.
24 In this case, we've simply divided the
25 total cost left over by the number of users, so a non-
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1 user, you notice, in this underneath the little slash
2 there, pays nothing.
3 So, when it comes time to decide on a
4 method, the town says, "We'll let the users pay their
5 own share and the non-users pay nothing," then you'll
6 pay nothing.
7 If, on the other hand, the town finds it
8 fit to pay for all that cost through taxes, then your
9 house, if it's assessed at $40,000.00 would be charged
10 an additional $15.00 a year in taxes under alternative
^ three. How long? Twenty years.
12 If your house is assessed for $20,000.00,
13 you'd pay $7.50 a year more, just for the sewers. That'
14 not to say that taxes won't go up for other reasons, but
15 for the sewer reason, this is what the money means.
,. Does that explain that?
1 O
MR. STICKNEY: Joe, I would like to make
18 one philosophical comment if I may without getting into
19 the discussion about who's going to pay for the sewers,
but one reason for banding together in a municipality
is mutual protection and development of services which
are of mutual benefit to all, although which may not
benefit all equally and I hope that in developing what-
ever is developed for a funding system or a community
24
decision, that the broad community interest will be kept
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1 in mind. That's the way we've got to function if any-
2 thing's going to work. You were next, I believe, sir,
3 and your first name is Bill?
4 MR. KARNES: Dale.
5 MR. STICKNEY: Almost got it.
6 MR. KARNES: Dale Karnes, the Health
7 Officer for the Town of Yarmouth. In reviewing the
8 E.I.S., I came up with four primary areas where I had
9 major questions.
10 The first had to deal with the water
11 quality data as listed in the study. It's my opinion
12 that the data is insufficient to make a statement that
13 the water quality analysis and sampling program produced
14 no evidence to link surface or ground water problems to
15 on-site disposal systems.
16 I feel that the sampling program wasn't
17 that wide-spread to make this type of statement and this
18 must be revised, that the town really does need a town-
19 wide, continuous and on-going water quality sampling
20 program to truly assess what the problems might be
21 from different on-site disposal systems throughout the
22 town.
23 We know of several major areas which have
24 been pointed out earlier, one area with a higher water
25 table in it. There is little doubt that the water table
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1 has to be affected by the on-site systems that are
2 leeching into this.
3 There are other areas of town which have
4 extremely poor soil conditions and again, this would
5 contribute to adverse water quality in this area.
6 Another area where I had questioned was
7 in the method of disposal at Site D, a slow rate land
8 application and I've asked that you supply more data
9 on where this type ot system is used in a practical
10 use, and how problems with airborne biological and
11 odor can be prevented.
12 A third area and one area I think that's
13 been touched on several times already is that of
14 septage management. The lagoon method as recommended
15 is again a method as pointed out that may not be accep-
16 table as a means of septic disposal in a .few years, and
17 i think the town needs, under the study, to touch on
18 what alternatives are available.
ig And the fourth and final area, in
2Q residential areas, there are several areas in the town
21 which have problems with soil conditions and I would
22 like to ensure that these areas can be included for
possible federal funds for on-site corrections at a
£O
later date and that this would be incorporated into
25 the E.I.S., the final E.I.S. plan.
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1 MR. STICKNEY: Thank you very much, Dale
r\
Does anyone here have questions?
3 MR. KETCHUM: No, I think these are the
4 same comments you made at previous meetings, so we're
familiar with them.
6 MR. STICKNEY: Okay. Yes, sir?
7 MR. SEARS: John Sears, Selectman. One
8 of the things that I don't feel has been addressed
9 significantly enough is the economic impact on and
10 if we're speaking of Route 28, Route 28 only, or as with
11 the citizenry as a whole.
12 We that have lived a long time in the
13 town of Yarmouth have been confronted with what Route 28
14 is and what it appears to be and the looks and whatever
15 as far as it affects our town because it is our major
16 roadway.
17 The amounts of money involved to service
18 or to send a pipe by the businesses on Route 28 are
19 going to very directly affect those businesses. There
20 are, I'm sure, some businesses there which are very
21 marginal businesses.
22 We can tell by looking at them, by the
23 amount of traffic that they take, the appearance and
24 what amount of maintenance that they're able to do. If
25 it becomes too expensive for them to pay their taxes
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1 and to pay for their upkeep and to pay for sewering,
2 what might we expect from the businesses on 28?
3 There are some people who still reside
4 on Route 28 and will they be forced to leave, will the
5 general outlook of 28 be better because it will be
6 the land will have to go to those who can afford it and
7 build something better, or will it downgrade our town
8 by not being able to provide the amount of funds in
9 order to stay in business?
10 Another subject which I feel that a great
11 deal of stress and too much stress at this point is
12 being put on Barnstable. At this time, I think that we
13 can speak to Barnstable and we can speak to God, and
14 neither one of them perhaps wants it.
I think that we have seen what our
ID
16 growth has been over the past twenty years and we don't
17 need an Impact Statement to tell us what has gone on in
18 our town for the last twenty years.
I think that we can envision somewhat
iy
2Q what will happen in our town in the next twenty years.
21 The figures that are put before us now I figure are now
22 prices and the price of gasoline daily shows us what is
23 happening with inflation and whichever alternative we
24 select, by the time we're ready to build it, I'm sure
25 that the cost will have escalated well beyond that, so
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1 hopefully, the figures as they're presented will contain
2 within them the basis for dealing with inflation.
3 I feel like we're in a little bit of a
4 panic situation, that if we don't buy something, we're
5 going to get nothing. This isn't a new problem. We've
6 lived with this problem and we've all had cesspools and
7 grown up with cesspools and added to our cesspools and
8 then found something was better and then we've grown in
9 that direction.
10 So, to simply say, "Come on, boys, you've
11 got to do something in the next thirty days and then
12 you're going to have to do something in the next six
13 months," I feel as the gentleman out there has stated,
14 that the public does not know and perhaps this is our
15 job and I feel it is our job to get them out and we
16 tried, Sally was on the radio today, to try to get
17 people out.
18 Just one observation that I make is that
19 I think we are expecting the public to be too well
20 versed. I think we've got to go right down to basics
21 and we've got to tell people the difference between
22 septics and septage and sewerage so that they under-
23 stand that, and people are very hesitant about asking
24 questions like that because they feel like that it may
2b make them feel a little bit foolish or that maybe some-
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1 body else knows something that they don't know and I
2 think that we're expecting too much of the public.
3
I think that we've got to go right back
4 to square one and start and educate people a little bit
5 at a time because this is going to affect them as much
6 as the amount of their tax bill is presently.
1 MR. STICKNEY: Thank you, Mr. Sears.
8 Your initial concern with the economics of sewerage is
9 that there would be marginal businesses now that couldn'
10 survive in a higher cost area?
11 MR. SEARS: Right now, they're surviving,
12 they've got a hole in the ground and they dump their
13 waste into that and they're surviving with that and
14 maybe they do or maybe they don't have to pump those.
15 If the pipe goes by, they will have to
16 use that facility and it's going to cost them and there
17 may be some motels right now that do very little and it
18 may cost them $500.00 a year to do what they're doing.
19 That same motel, it might cost them $8,000.00 a year
20 and somewhere along the line, they've got to raise their
2! rates or they've got to attract a bigger flow of people
22 and if gasoline becomes a big crunch, people aren't
23 going to be able to come to those motels and they're
24 going to go downhill and they're going to need painting
25 and this affects our town.
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1 MR. STICKNEY: One of the goals of this
2 process is for a project to be developed which is
3 acceptable to the community and to the Board of Select-
4 men and one which you're completely clear, as clear as
5 possible, about in terms of our funding, what the
6 funding will be, and whatever the result of this final
7 E.I.S. or whatever shape the final E.I.S. takes, we're
8 well aware that unless the decision makers in the town
g are satisfied and wish to develop a program to be
10 submitted for funding, then nothing is going to happen,
11 so
12 MR. SEARS: Well, if I may, just one
13 more time if we at this point said, "Well, okay,
14 we've got all this, we know the alternative that we
15 think is best " and this is a hypothetical question
16 because we haven't talked about this at all " and we
17 agreed that this is the time, that this is the alterna-
18 tive that we choose, but right now the people won't
19 vote for it and they won't buy it and we can't have
20 it," and then we come back in five years and say, "Okay,
2i we're ready," and then we're going to be told that,
22 "We're sorry, Yarmouth, but we spent a lot of money on
23 a booklet for you back in 1978 and '79, so you're not
24 in line anymore, so you go to the back of the line."
25 And this is why I feel like you're going
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1 to buy it today or you're going to wait ten years and I
2 feel, you know, that amount of pressure, that it's take
3 it or leave it.
4 MR. STICKNEY: Dan, if I might ask the
5 condition of a priority list in Massachusetts and what
6 the situation is in that regard.
7 MR. COUGHLIN: Well, it's not so much
8 the priority list as the continued funding by congress
9 in the water pollution control area.
10 At this point in time, congress has been
11 appropriating up to five billion dollars, four and a
12 half, five billion dollars annually for water pollution
13 control.
14 This last year, the Committee recommended
15 to the House that it appropriate zero. Now, their
16 finding was beaten down as far as I understand. Now
17 they've recommended 3.8 as opposed to 4.5, which we
18 anticipated they would recommend for funding.
19 The best I can say is that we aren't
20 trying to put anybody on the spot with the E.I.S. It
21 was initiated because Yarmouth asked for a grant to
22 build a certain or design a certain facility.
Eventually, I would assume, at least
fcO
24 the way things would appear, that Uncle Sam is going to
25 stop funding waste water treatment facilities or may
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1 devise a funding formula and cut it down, so the
2 communities that act now and get the grants now have
3 the money whereas, if you don't act now and don't get
4 their grants now, may not get the money, it's as simple
5 as that, and there's no way I can predict it. It depend
6 on the particular feeling in congress each and every
7 year when they appropriate money.
8 So, that's the only way we're putting
9 you on the spot, by saying there is money there now and
10 there is money there next year probably, but whether
11 there's going to be money there in the future, we don't
12 know and if there isn't, then you're on your own.
13 MS. MAGNUSON: If I could add to that,
14 if I understand it, if the town votes gets a grant
15 by next April, 1980, they can get seventy-five percent
16 of the money they've already spent back, which I think
17 would be about $75,000.00 and if they don't have a grant
18 by next April, they would lose that retroactive funding.
19 I was asked to pursue this for the
20 Selectmen. Is that correct?
21 MR. COUGHLIN: That's right.
22 MR. STICKNEY: That's the shortest and
23 most direct answer we've gotten tonight. Do you have a
24 response, Mr. Ketchum?
25 MR. KETCHUM: Yes, I'd just like to
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the last comment from the Selectman. I refer you to
o
Page 130 of the E.I.S. and we're very cogni2ant of the
3 cost situation and one of the things that we did
4 indicate here under this present worth analysis type
5 of evaluation, that the extensive sewering of the
6 community would be about eleven times more expensive
7 than the maintenance and the on-site system's strong
8 non-structural measures, so there's a very strong
9 concern from our part.
10 In fact, v/e even make the point here,
11 "The high cost for sewering could represent a burden-
12 some if not impossible cost to many families in moderate
13 income and the many elderly families living on fixed
14 income. It would represent a form of inflationary cost
15 not warranted by any need except along Route 28 to
16 protect water resources."
17 Now, that item has been brought into
18 contention this evening, but from our finding, we felt
19 that the only need was along Route 28 and that the cost
2o for extensive sewering elsewhere in the community is
21 not warranted and it's very expensive as indicated by
22 the chart.
23 To answer your Route 28 question, we
24 found that given the types of users along there, many
25 of which are major water users, that the most cost-
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1 effective solution for dealing with that particular
2 problem would be sewering, that the cost to handle a
3 number of the situations on an individual basis, and
4 we've reviewed these with Mr. Karnes, would be more
5 expensive than the sewering option which is recommended
6 under alternatives three, four and five.
7 We're very cognizant of this and I wanted
8 to make a point that this whole financial issue is
9 addressed in the E.I.S. and I cite the page where it is
10 covered.
n MR. SEARS: I was open to the very page
12 that you referred to.
13 MR. STICKNEY: I suspect you're asking
14 for a more detailed analysis of the Route 28 area?
15 MR. SEARS: I think, you know, it's
16 all right to stand back and assume these kinds of things
17 and I don't know how far you go into a person's books,
18 but somewhere along the line, those people have got to
19 be spoken to and, you know, how will this affect you,
20 are you going to go out of business or are you going to
21 stay?
MR. STICKNEY: We've been going for about
23 two and a half hours now and if we could -- we didn't
24 set a time limit, but if we could wrap this up by 10:15
25 or so, I think it would be useful and we'd be available
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for informal discussions afterwards as well.
2 MRS. SILVER: Mr. Stickney?
3 MR. STICKNEY: Yes?
4 MRS. SILVER: Oh, I'm sorry.
5 MR. STICKNEY: It makes no difference,
6 who would like to be first?
1 MRS. SILVER: Thank you. What type of
8 system do they have in Barnstable at the present time?
9 Is there some type of lagoon there?
10 MR. STICKNEY: For septage or for the
11 sewerage itself, the plant itself?
12 MRS. SILVER: When you drive down the
13 road behind the mall and you notice an odor, where would
14 that be coming from?
15 MR. ZENESKI: We have the representatives
16 of Whitman and Howard working for Barnstable here.
17 MR> HICKMAN: My name is Robert Hickman.
18 I'm here from Whitman and Howard. I was glad that
19 Anderson-Nichols introduced us. That is the Hyannis
20 Treatment Plant that you are detecting odors from and
21 it's because right now the Town of Barnstable has an
22 overloaded system. It's a primary treatment plant.
23 The primary treatment plant is providing
24 only partial treatment of the wastes that come into the
25 facility and right now they have several essentially
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1 lagoons on their filter beds. The treatment process
2 that they go through right now is simply settling, as
3 was suggested before, in the first lagoon with the
4 effluent going out to sand beds and percolating to the
5 ground.
6 They have seven effluent lagoons because
7 the plant is not capable of removing all of the waste
8 that comes into it and discharging it properly. That's
9 why they're spending eight million dollars to build a
10 secondary treatment plant that is capable of receiving
11 domestic wastes and septage from the Town of Barnstable
12 When the new plant is completed, you
13 will not detect the odor you detect now. If I can
14 follow up with a couple of comments while I'm here?
15 MRS. SILVER: We didn't have this
16 planned.
17 MR. STICKNEY: No, I was just looking to
18 see if your question had been answered.
19 MRS. SILVER: Yes.
20 MR. STICKNEY: The floor is yours.
21 MR. HICKMAN: Thank you. The costs in
22 tne report we take exception to and will follow up in
23 writing where we disagree.
24 I could just as easily take what is said
25 in tne report to be eleven times more expensive and have
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it come out equal to, as far as the town's costs, and
2 use this. What is not in the cost-effective analysis
3 in the report is what a homeowner will have to pay wno
4 is not connected to the sewer that the tables say he
5 pays no cost for annual operation and maintenance costs
6 of a septic system, having it pumped out and brought to
7 a municipally constructed and operated septage treatment
8 facility.
9 The cost of that septage facility, we
10 feel, are not adequately covered in the E.I.S. and we
11 feel it's a very real cost that the homeowners tneinselve
12 in Yarmouth will be faced with.
13 We also feel that the quantity of flow
14 of septage that would be generated within Yarmouth,
15 both present and in the future, are grossly underestimat
16 We noticed in the report on one page, a
17 statement that suggested that regional facility be
18 constructed with Dennis and Yarmouth and their flows
19 total fifty some-odd thousand gallons per day and yet
20 later on in the report, it's recommended a septage
21 facility of thirty thousand gallons per day be con-
22 structed.
23 There's obviously a discrepancy there,
24 and just to follow up on that, the septage facility |
25 that Whitman-Howard recommended and designed for the
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1 Town of Yarmouth was sixty thousand gallons per day
2 simply because the D.E.Q.E. at the state said, "You've
3 got to be double in everything," so whereas the initial
4 needs of Yarmouth were thirty thousand gallons per day,
5 it was doubled to sixty thousand gallons per day, so if
6 in fact we were going to compare apples and apples in
7 the report and a thirty thousand gallon per day lagoon
8 septage facility for Yarmouth, we should also be compari
9 a thirty thousand gallon per day purofax treatment
10 facility for the Town of Yarmouth.
11 There are many of these, what we feel
12 are discrepancies in the report. The amounts of land
13 required for the size and method of final treatment if
14 it was a domestic waste treatment facility, we feel are
15 misleading.
16 For one method of treatment and disposal,
17 conventional secondary treatment with rapid infiltration
18 disposal similar to what will eventually be completed in
19 Barnstable, which has a buffer zone around the facility
20 of one hundred feet and is pretty typical, I think, of
21 that type of facility, the E.I.S. recommends a four
22 hundred foot buffer zone which is the same buffer zone
23 theY saY should be put in for spray irrigation which has
24 obviously a high mist and a potential carry on to privat
25 property and also for slow-rate irrigation.
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Comme.ice. Cowit.
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1 There's no attention in the E.I.S. to the
2 marketability of the crops that are supposedly to take
3 up the nutrients if that particular method is to be
4 accepted by the Town of Yarmouth.
5 I think that the Town of Yarmouth should
6 not be asked to make a decision on the final E.I.S.
7 until E.P.A. does make a decision if it's in conjunction
8 with the town officials and the state officials on
9 whether the ground water would be classified as Case I,
10 II or III.
It has a very significant effect on the
12 costs of whatever alternative is finally selected.
13 MR. STICKNEY: Thank you, Mr. Hickman.
14 Dan, what about that? I presume no decision would be
15 made until that --
MR. COUGHLIN: No, that's why I said we
16
17 haven't made a determination on the Case I, Case II or
18 Case III situation. We certainly wouldn't make it
19 without consulting with the town and you're very right
in saying that it has quite an impact on what type of
21 facility we'd build and how much it costs,
Without a Case III determination, the
site is much more limited as far as handling capacity
than with the Case III determination.
MR. STICKNEY: Are there other comments?
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1 Yes, sir?
2 MR. GANNON: Can I ask it from here? Mr.
3 Sears, isn't the cost of doing business with these
4 motels, say it:s $8,000.00 for sewerage, isn't that
5 deductible from tneir income tax?
MR. SEARS: Yeah. They've got to have it
6
7 tnough to have it to spend.
MR. STICKNEY: Few of us make money on
8
9 our deductions. I know some people do it.
MR. SEARS: We couldn't do it as a house-
owner, but ousiness 1 would think could.
MR. TALLMAN: Business is no different
than a house. If you're in business, you've got to
I v5
make a profit or you've got no business.
MR. SEARS: That's true. That's true, so
15
if the sewerage is too much, naturally you'll go out of
ID
business.
MR. TALLMAN: That's right.
18
MR. SEARS: There must be some deduction.
19
MR. TALLMAN: Yeah, but deduction isn't
20
the answer.
21
MR. SEARS: Well, we don't know how much
22
MR. TALLMAN: We're all working for
23
deductions, but you've got to have the money to deduct
24
it from.
25
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1
MRS. SILVER: Mr. Stickney?
MR. STICKNEY: Ma'am, you have the floor
MRS. SILVER: Thank you. I had one more
4
comment, speaking this time as a member of the Water
Quality Committee, and this is one thing we have been
6 discussing at our last few meetings which was a combina-
7 tion alternative or.a split alternative.
8 We will be writing to you about this,
9 but I did want to bring it up tonight in that we think
10 we have another viable alternative which would be
11 portions of different ones that were in the draft before
12 sending a portion of the West Yarmouth, Route 28 sewage
13 to Barnstable up to the hundred and fifty thousand per
14 day and then treating the rest of Route 28 and also some
15 of the areas south of Route 28 that have shown needs and
16 are septage wastes at a treatment plant at Site D.
17 And we do think that this might be some-
18 thing that also is worth looking into. Thank you.
19 MR. STICKNEY: Thank you very much.
20 MR. COUGHLIN: Wally, could I answer
21 another question that Bob raised, Bob Hickman raised,
22 and that is, in the report, there is on Table 0-1 and
23 o-2, a discussion of on-site system cost to people that
24 are on septic tanks and correct me if I'm wrong, Burk,
25 but I'm quite sure that the cost for on-site septic
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1 maintenance and even the cost for reconstruction of
2 certain fail systems which may in fact fail during the
3 twenty-year planning life, is considered in the cost
4 tables.
5 MR. ZENESKI: If you check the report
6 and I believe Chapter 3, where we make reference to
7 the eleven times more expensive on Page 54 of that
8 report, and those of you who have it can make reference,
9 we've presented the cost to the homeowner I'm sorry,
10 the total cost based on a user basis. Now, keeping
11 in mind that we do our cost effective analysis on
12 total cost, not just E.P.A. cost or state cost or
13 local cost or user cost, but total cost, and this is
14 where we get the reference to the eleven times more
15 expensive.
16 The $785.00 you see is the total present
17 worth cost of repairing septic systems or maintaining
18 on-site disposal. We've broken out into an annual cost
19 of $72.00 and you see that shows up in all cases here.
20 In addition, there would be the cost for
21 the septage disposal facility. Under alternative two,
22 where the septage disposal facility would be the most
23 expensive because it's separate from the waste treatment
24 facility I'm sorry, alternative three in this case,
25 the Barnstable alternative, it represents slightly more
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1 cost to the homeowner through his use costs and there's
2 nothing else I can say about that, but that we have
3 indeed addressed those costs in the report.
4 MR. STICKNEY: I think it would be
5 helpful, I guess, if when you make your comments on
6 costs, you utilize that as a basis. That would help us
7 to extend the comments on out.
8 Now, we will have a transcript of this
9 hearing available. When, sir? When will that be
10 completed? Ten days, and upon completion will have one
11 copy on file down here for those who wish to use it.
12 If there are no other questions or
13 comments, I appreciate your indulgence and the informa-
14 tion you've presented. We have one more. Almost gone
15 three times, but go ahead.
16 MR. EMBREE: Wayne Embrey, West Yarmouth.
17 MR. STICKNEY: Would you spell your last
18 name?
19 MR. EMBREE: Embree, E-m-b-r-e-e. My
2Q question I don't know who to address it to, but
21 presuming 28 is sewers and I think that's about all
22 we're talking about now is, I assume, 28 is going to be
,, sewered, we've got some very good real estate operators
-------
1 With the sewerage in, what is going to
2 happen? Is it going to be a one-way street for this
3 28 to be you know how it is in the summer time now,
4 you've got sixteen million people, it seems. Our beache
5 are overloaded now. What's the impact of sev/ering of
6 28 going to have in that respect?
7 I don't think there's anybody here that
8 can answer that, but I think it's really going to zoom
9 up the town, as if we need it.
10 MR. STICKNEY: Mr. Embree, maybe I
11 could ask someone on the panel. Did we do a socio-
12 economic or a secondary effects assessment in this?
13 MR. KETCHUM: We've shown a map in the
14 Environmental Impact Statement of the vacant properties
15 along Route 28 and it's our presumption that over a
16 period of time, that land will be developed possibly as
17 a result of sewering because in some ways, it will make
18 it more attractive for development, so we don't discount
19 that
20 MR. EMBREE: You would presume it would
21 be developed?
22 MR. KETCHUM: Yes, we presume it would
23 be developed and the numbers that we've used for an
24 ultimate flow of, I think, five hundred thousand gallons
25 per day reflect that particular development that would
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1 occur.
2
It also assumes that there aren't going
to be any major zoning changes along that particular
4 area. The present zoning allows a certain type of very
5 low density apartment development which is not really
6 typical apartment type of uses, and we're assuming that
7 there would be no change there.
8 MR. EMBREE: So, you're saying
9 MR. KETCHUM: Yes, we assume there will
10 be development as a result.
11 MR. EMBREE: That there will be develop-
12 ment?
13 MR. KETCHUM: Yes.
14 MR. EMBREE: Thank you.
15 MR. STICKNEY: There is a letter dated
16 May 18, 1979 from the Yarmouth Taxpayers Association
17 and addressed to the Board of Selectmen, Town of
18 Yarmouth, which I will read into the record.
19 "Gentlemen: A meeting of the Yarmouth
Taxpayers' Association was held on May 16, 1979 at the
Town of Yarmouth Hearing Room. One of the new business
items on the agenda was 'Discussion and formulation of
resolve reference Environmental Impact Study regarding
sewerage in the Town of Yarmouth.'
Members of the Yarmouth Taxpayers'
25
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BOSTON, MASSACHUSETTS
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Association were privileged to attend a joint meeting
of the Water Quality Advisory Committee and Health
3
Advisory Board prior to our scheduled meeting the same
4
evening,
5
The comments were informative as to the
6 ,
latest draft copy enabling the Yarmouth Taxpayers'
7
Association to discuss the E.I.S. Report.
8
A motion was proposed and passed that the
9
draft proposal not be accepted in its present form. It
10
was recommended that further study be made, requesting
11
an extension of time be granted to provide further
input for the citizens' participation on the final
13
draft. Sincerely yours, Hugh E. Kilmartin, Secy."
14
Thank you very much ladies and gentlemen.
15
The formal part of the hearing is closed.
16
(Whereupon the hearing ended)
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BOSTON, MASSACHUSETTS
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C E R T I P I C A T E
2
3
UNITED STATES OF AMERICA
4 ENVIRONMENTAL PROTECTION AGENCY
This is to certify that the attached
6 proceedings before the United States Environmental
7 Protection Agency, in the matter of AN ENVIRONEMTAL
8 IMPACT STATEMENT ON WASTE WATER TREATMENT AT YARMOUTH,
9 MASSACHUSETTS, on Monday, May 21, 1979, at the Yarmouth
10 Town Hall, Yarmouth , Massachusetts, before Wallace
11 Stickney, Chairman, and Director of EIS, Boston, Mass.,
12 commencing at 7:30 p.m., was held as herein appears and
13 that this is the original transcript for the file of the
14 Department.
15
16
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18
19
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Couit eRzboitlnq Co.
.S. GOVERNMENT PRINT.NG OFFICE: ,979.602-676/341
BOSTON. MASSACHUSETTS
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