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.
                                 —  i  —

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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.
                                 - 3 -

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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.
                                - 4 -

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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.
                                 -  5  -

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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
                               - 6 -

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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
                                - 7 -

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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.
                                 - 8 -

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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,
                                 -  9  -

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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.
                           - 10 -

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                            CHAPTER 1


                      PREFERRED ALTERNATIVES
This chapter describes the additional alternatives developed in
response to comments on the Draft EIS.
                                - 11 -

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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
                                -  13 -

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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
                                -  14  -

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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.
                                - 15 -

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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
                          -  16  -

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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
                                - 17 -

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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.)
                  - 18 -

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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
                          - 19 -

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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.
                                    -  20  -

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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
F -
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              *Does not include up to $9,000,000 in rehabilitation of on-site  systems along Route 28.

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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.
                           - 35 -

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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
YARMOUTH

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Federal Agencies
State Agencies
Regional Agencies
Local Agencies
Organizations
Individuals
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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.
                                 -  41  -

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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
                          - 42 -

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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.
                                - 43 -

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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.
                  - 44 -

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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.
                   -  46  -

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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.
                          -  47  -

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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.
                   -  48  -

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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.
                          - 49 -

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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.
                          - 50 -

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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).
                  - 51 -

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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?
                  - 52 -

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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
                  - 53 -

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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


                          - 54 -

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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.
                  - 55 -

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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.
                   - 56 -

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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.
                  - 57 -

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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.
                          - 58  -

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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.
                  - 59 -

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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.
                          - 60 -

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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.
                  - 61 -

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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.
                  - 62 -

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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.
                  -  63  -

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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.
                  - 64  -

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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,
                  - 65 -

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                   APPENDIX A







         LETTER  FROM EPA TO YARMOUTH




BOARD OF SELECTMEN REGARDING NEW ALTERNATIVES
                      A-l

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% «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.

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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

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          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

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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

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                   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

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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
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•A Fom 1320.1 (12-70)
                                                                OFFICIAL FILE COf t

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                                    -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?

-------
                                   -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.

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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

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                                              W-5
     Commissioner

   PAUL T.ANDERSON
Regional Environmental Engineer
                                               May 18,  1979
                                                                           22*979
                                                     YARMOUTH—Wastewater 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

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            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.

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                             -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 dete™ined 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.

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                                   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

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                                 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

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                                     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

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                             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

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                                   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

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                                   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

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                                        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?
                         -6-

-------
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
                         -7-

-------
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:
                         -8-

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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-

-------
     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.
                         -10-

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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.

-------
                         -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

-------
           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 
-------
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

                                       -5-
                     Commtiice. ^ourt 
-------
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


                                       -6-
                     Comme.'i&e. Cowd. 
-------
  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

                                       -7-

                              Couit 
-------
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.

                                      -8-
                              Coait ^efioitintj Co.
                          BOSTON, MASSACHUSETTS

-------
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



                                        -9-

                     Commtice.  Couit 
-------
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

                                        -10-

                    Commeice. Court 
-------
  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



                                        -11-



                     Commc.ice. Couit 
-------
 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


                                       -12-

                     Comrmioe. Cou.it <^s,jpoitin^  Co.

                          BOSTON, MASSACHUSETTS

-------
 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

                                       -13-

                     Cornrntice Couit 
-------
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?




                                       -14-



                                               Co.
                          BOSTON, MASSACHUSETTS

-------
  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

                                       -15-
                     Commciae. Cowit 
-------
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



                                       -16-



                     Commtice.  Coait  
-------
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-



                                      -17-


                     Clonune.'uie. douit tzffe.ho
                                        •

                          BOSTON,  MASSACHUSETTS

-------
 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

                                       -18-
                     dom.me.ice. douit 
-------
           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

                                       -19-
                     Comm&iae. Cowit  
-------
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

                                       -20-

                     (2om.me.iae. Couit 
-------
 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?

                                       -21-

                     dommtice, dowit <^e,boitinct do.
                          BOSTON, MASSACHUSETTS

-------
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'

                                      -22-
                    dommtice. douit d^e-fzoitlncj  Co.
                          BOSTON. MASSACHUSETTS

-------
           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.

                                       -23-
                     Comrntiae.  Cowit  
-------
  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.

                                       -24-

                    L-omtnc.ics. Cou.it ^ffe.Loitlnq  Co.
                          BOSTON. MASSACHUSETTS

-------
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

                                       -25-
                     Commvics, Cou.it 
-------
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

                                       -26-
                    Comrmiae.  Couit  etfetioiting Co.
                         BOSTON, MASSACHUSETTS

-------
 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




                                       -27-



                     Commmcc. Cowt
                          BOSTON,  MASSACHUSETTS

-------
 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.

                                       -28-

                    Commtiae.  dowit e^zboitinq  Co.
                          BOSTON,  MASSACHUSETTS

-------
  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

                                       -29-
                     Commtiae.  Cowit  ezff&bo'itinq do.
                          BOSTON, MASSACHUSETTS

-------
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
                                        -30-
                     Commtice.  Couit  
-------
           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

                                        -31-
                    Commticf.  Couit ^zpoitlng Co.
                          BOSTON,  MASSACHUSETTS

-------
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
                                        -32-
                               Cowd. 
-------
           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

                                       -33-
                     Commtice, Couit 
-------
 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




                                       -34-




                     Com.mt.ics. Cowit ezffe.bo'itin   do.
                          BOSTON,  MASSACHUSETTS

-------
 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-

                                       -35-
                     Comimics, Cou.it 
-------
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
                                       -36-
                    dom.me.ioc,
                          BOSTON. MASSACHUSETTS

-------
 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

                                       -37-
                               Couit  
-------
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."

                                       -38-
                    donuneiae.  douit 
-------
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
                                        -39-
                     Commeice,  (lowd 
-------
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

                                        -40-
                     Comtne,ice,  Cowit tzfte-fzoitincj Co.
                          BOSTON, MASSACHUSETTS

-------
 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



                                       -41-


                     Comme.ice.  Couit 
-------
 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

                                       -42-
                    Com.me.ice. Cowit 
-------
  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

                                       -43-
                     Comme.iae.  Couit <=ffe.fu3itlng Co.
                          BOSTON,  MASSACHUSETTS

-------
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.

                                       -44-


                     Commtiat.  Court tzR&poitiny Co.

                          BOSTON, MASSACHUSETTS

-------
  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
                  -45-
Commtiiae. Court etfe.hoitinq Co.
                  '
     BOSTON, MASSACHUSETTS
                                            L/

-------
 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.

                                       -46-
                     Commeice. Cou.it  
-------
 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

                                       -47-
                     Commtice. Coutt ezftthoitinq  Co.
                          BOSTON, MASSACHUSETTS

-------
 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

                                       -48-
                     Commtice. dowii  <^e,fioikln(j Co.
                          BOSTON, MASSACHUSETTS

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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

                                       -49-
                    Cotrumtce.  Cowd cfitboitinq Co.
                          BOSTON, MASSACHUSETTS

-------
          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.

                                       -50-
                              Cowd. tzff&ftoitlncj Co.
                          BOSTON, MASSACHUSETTS

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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

                                       -51-
                    Commtice. dowit ezff^ho^tinq Co.
   \                       BOSTON, MASSACHUSETTS

-------
 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

                                       -52-

                     Conuncice. Cowd. d?e,f2O^tlnc)  Co.
                          BOSTON,  MASSACHUSETTS

-------
           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

                                       -53-
                     Commeice. Cou.it ^e.fzoitLnq  Co.
                          BOSTON, MASSACHUSETTS

-------
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




                                       -54-



                    Comtne,iax, Coutt 
-------
           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

                                       -55-
                     C0mme.iat Cowit <=^e,fioitinq  Co.
                          BOSTON,  MASSACHUSETTS

-------
          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

                                        -56-

                     Commtice. Court 
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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.

                                       -57-
                              Cowit •zRe.fio'itlnq  Co.
                          BOSTON,  MASSACHUSETTS

-------
                          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

                                       -58-
                              Couit ^i^tlny  Co.
                          BOSTON,  MASSACHUSETTS

-------
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

                                       -59-
                    Commtice. Couit  
-------
           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-

                                       -60-
                    Conuneiae. Cowit czR&jpaitlnq Co.
                          BOSTON, MASSACHUSETTS

-------
 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 —




                                       -61-
                     Comm^ice, Cowit e^e-tuyitLnq  Co.
                                       I    j

                          BOSTON.  MASSACHUSETTS

-------
 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-




                                       -62-




                     Com.mx.ice. Cou.it <^e,oitin   Co.
                          BOSTON, MASSACHUSETTS

-------
 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.

                                       -63-
                     Cornmtice. Cou.it 
-------
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




                                       -64-



                     Comme.ic& Couik  eJ?e.^tin$ Co.


                          BOSTON. MASSACHUSETTS
22





23





24





25

-------
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




                                       -65-



                     Commtiae.  dowit 
-------
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

                                       -66-
                    donunvice, douit 
-------
 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



                                       -67-


                     Commtice. Cowit <=J^e.ttoitina  Co.
                                       '      tJ
                          BOSTON, MASSACHUSETTS

-------
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




                                       -68-




                     Comme.i&e.  Couit  ^e-ioitin  Co.
                          BOSTON. MASSACHUSETTS

-------
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

                                       -69-
                    Commvuie. Couit ^e.fion.tin^ Co.
                          BOSTON, MASSACHUSETTS

-------
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

                                       -70-
                               douit eflzkoiiing Co.
                          BOSTON, MASSACHUSETTS
24

25

-------
  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

                                       -71-
                     Conuru.ice. Cowit 
-------
 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.

                                       -72-

                              Cowd  ^zfzo'itlny Co.
                          BOSTON, MASSACHUSETTS

-------
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

                                       -73-
                     (2omrne.ice. Cowit  
-------
   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

                                       -74-
                     Commnice.  Couit 
-------
  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.

                                      -75-
                    Comm&ics, Couit tzftzfiQitlnq Co.
                          BOSTON, MASSACHUSETTS

-------
 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



                                       -76-



                     Commtice, Couit  ^iio-itlnc  Co.
                          BOSTON, MASSACHUSETTS

-------
 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-

                                       -77-
                     Comnmiae. Cowii 
-------
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


                                       -78-
                     Commiw  Couit  ^e-jpaitin^ Co.

                          BOSTON, MASSACHUSETTS

-------
 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?

                                       -79-
                     Comme.'uie, Couit 
-------
  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.

                                       -80-

                     Comme.ic&  Cou.it 
-------
 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-




                                       -81-



                    Comme.itn. Couit 
-------
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



                                        -82-



                     Commtice.  Cowd  
-------
 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

                                       -83-
                     Com.me.iGs. Couit 
-------
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.


                                       -84-


                     domme-iae.  Couit ezfte.fio'itlnc) Co.

                          BOSTON. MASSACHUSETTS

-------
 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


                                       -85-

                              Couit ^e.^ting  Co.

                          BOSTON. MASSACHUSETTS

-------
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




                                        -86-



                     Commeice. Cou.it czffe.fio'itlny Co.


                          BOSTON, MASSACHUSETTS

-------
 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-




                                       -87-



                              dowit  <^&io^tina Co.
                          BOSTON, MASSACHUSETTS

-------
  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.


                                        -88-


                     Commvuie,  Cowit 
-------
  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


                                       -89-
                     Commt.'uie. Couit <=j?e.tujitlnq  Co.
                                        *     c/
                          BOSTON,  MASSACHUSETTS

-------
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



                                       -90-


                     Conuntice.  Couit 
-------
 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

                                       -91-
                    Comme.ice.  Coait 
-------
           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-
                                       -92-


                     Commtiae. Cowit <£fte.f*o*Mn) Go.

                          BOSTON, MASSACHUSETTS

-------
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

                                       -93-
                     Commeice, douit <^e.hoi.tLna do.
                          BOSTON, MASSACHUSETTS

-------
          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

                                       -94-
                     Comme.ice.  Couit  ^R^itin^ Co.
                          BOSTON, MASSACHUSETTS

-------
 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

                                       -95-
                     Comme,ios. Cowik 
-------
            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

                                        -96-

                     Cornmeice.  Cou.it 
-------
 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.

                                       -97-
                     Comme.ice. Cowit. 
-------
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?


                                        -98-


                                Cou.it eRii^ Co.
20          ln
22



23



24



25
                           BOSTON, MASSACHUSETTS

-------
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
                                       -99-
                     Comme.tc& Court c^&htoitLnq  Co.
                          BOSTON,  MASSACHUSETTS

-------
 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

                                        -100-

                     Cotnnwict Couit tztfe/xjtting Co.
                           BOSTON, MASSACHUSETTS

-------
 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

                                       -101-
                     Comtmicx, Court  tzffefiotting  Co.
                         BOSTON, MASSACHUSETTS

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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
 
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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

                                       -103-
                     (lommtice. Cowit 
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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

                                        -104-


                     Com.nu.ice.  Cowit  ezfte-fzoitincj Co.

                          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)
 17
 18
 19

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 21
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                                       -105-
                              Cowit d3e.ku}iiinq Co.
                                        *     iJ
                          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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                              -106-              .
                                Couit eRzboitlnq Co.
                    .S. GOVERNMENT PRINT.NG OFFICE: ,979.602-676/341
                           BOSTON. MASSACHUSETTS

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