A
EPA
United States
Environmental Protection Agency
Region 1
JFK Federal Building
Boston, Mass. 02203
         Final Supplemental
  Environmental Impact Statement
            November 1989

     Long-Term Residuals Management
         for Metropolitan Boston
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 s-xEPA
       Long-Term Residuals   Management for
                       Metropolitan Boston
       Final Supplemental Environmental Impact Statement
 November 1989
U.S. Environmental Protection Agency, Region I
  The U.S. Environmental Protection Agency has
just released the Final Supplemental Environmental
Impact Statement (SETS) on Long-Term Residuals
Management for Metropolitan Boston. This Final
SEIS responds to comments received on the Draft
SEIS issued on May 19,1989, and incorporates new
information and analyses provided since then.

  Since the release of the Draft SEIS in May 1989,
there have been several modifications to the Mas-
sachusetts Water Resources Authority (MWRA)
recommended plan including elimination of com-
posting as a residuals management technology; a
slight reduction in the landfill footprint to provide a
buffer between the proposed Walpole-MCI landfill
and abutting prison; design specifications for the
proposed landfill; designation of an alternative truck
route to the Walpole-MCI site for periods of high
truck traffic; and a plan for extending water and sewer
utilities to the Walpole-MCI site. In addition, EPA
has conducted expanded technical evaluations of
several issues including sludge quality, ground and
surface water impacts at the Walpole-MCI site,
property values and construction impacts. Based on
the additional environmental evaluation of sites and
residuals management options, and with addition of
several recommendations and mitigation measures
outlined in the Final SEIS, EPA confirms its original
acceptance of MWRA's preferred plan: digestion at
Deer Island, dewatering and heat-drying at the Quin-
cy Fore River Staging Area and landfilling at the
Walpole-MCI site.

  A 60 day public comment period will commence
on December 8,1989, with formal notification in the
     Federal Register, and end February 6,1990. Written
     comments on the Final SEIS will be accepted
     throughout the 60 day comment period. After the 60
     day public comment period ends, all public com-
     ments will be reviewed  and considered for  the
     Record of Decision to be released in the spring of
     1990.

      The Final SEIS is available for your review at the
     repositories listed below:

      Boston Public Library, Boston
      Hough's Neck Community Center, Quincy
      Maiden Public Library, Maiden
      MWRA Public Library, Charlestown.
      Norfolk Public Library, Norfolk
      Revere Public Library, Revere
      State House Library, Boston
      Stoughton Public Library, Stoughton
      Thayer Public Library, Braintree
      Thomas Crane Public Library, Quincy
      U.S. EPA Library, JFK Building, Boston
      Walpole Public Library, Walpole
      Winthrop Public Library, Winthrop

      WRITTEN PUBLIC COMMENT MAY  BE
     SUBMITTED UNTIL FEBRUARY 6,1990 TO:

      Ann Rodney
      U.S. EPA, Region I
      MEP-1900C
      JFK Federal Building
      Boston, MA 02203
      617-565-4424

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           Final Supplemental
   Environmental Impact Statement
               November 1989
       Long-Term Residuals Management

            for Metropolitan Boston


                    Prepared by:

                    United States
              Environmental Protection Agency
                     Region 1
                 JFK Federal Building
                  Boston, Mass. 02203


                 Technical Assistance by:


                       M'JS
                       *<5m
                    Metcatf&Eddy
PauIG. Keough /  ff              Date
Acting Regional Administrator
U.S. EPA, Region I

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              FINAL SUPPLEMENTARY ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ACTION:
SITING AND EVALUATION OF TECHNOLOGIES FOR
LONG TERM RESIDUALS MANAGEMENT FACILITIES
LOCATION:
Boston, Massachusetts and Metropolitan
Boston
DATE:


SUMMARY OF ACTION:
November, 1989
Final SEIS considers the environmental
acceptability of alternative locations and
technologies for the processing of residuals
from the new wastewater treatment facilities
for Boston Harbor
LEAD AGENCY:
U.S. EPA, Region I
JFK Federal Building,
Boston, Massachusetts 02203
TECHNICAL CONSULTANT:
Metcalf and Eddy, Inc.
Wakefield, Massachusetts
FOR FURTHER INFORMATION
Ann Rodney
Water Management Division
U.S. EPA, Region I
JFK Federal Building
Boston, Massachusetts 02203
FINAL DATE BY WHICH
COMMENTS MUST BE RECEIVED:
February 6, 1990

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                              TABLE OF CONTENTS
CHAPTER 1  INTRODUCTION	  1-1

     1.1   Organization and Contents of This Final SEIS	  1-1
     1.1   Relationship to Other Environmental Documents	  1-1

CHAPTER 2  MODIFICATIONS TO THE PROPOSED ACTION	  2-1

     2.1   Introduction	  2-1
     2.2   Sludge Processing	  2-1
           2.2.1   Description of Modifications	  2-1
           2.2.2   Implications	  2-1
     2.3   Landfill Procedures	  2-2
           2.3.1   Description	  2-2
           2.3.3   Implications	  2-4
     2.4   Designated Walpole Truck Route	  2-6
     2.5   Utilities	  2-6
           2.5.1   Water	  2-6
                   2.6.1.1  Landfill Liner System	  2-11
                   2.6.1.2  Leachate Collection System	  2-11
                   2.6.1.3  Runoff Control System	  2-11
           2.5.2   Sewer	  2-10
     2.6   Landfill Design	  2-10
           2.6.1   Landfill Design	  2-10

CHAPTER 3  EXPANDED TECHNICAL EVALUATION OF MWRA-SELECTED PLAN	  3-1

     3.1    Introduction	  3-1
     3.2   Reevaluation of Sludge Quality	  3-1
                   3.2.1.1  Primary Digested Sludge	  3-1
                   3.2.1.2  Trailer Pilot Treatment Plan	  3-2
           3.2.2   Results of the Analysis	  3-2
                   3.2.2.1  Primary Digested Sludge	  3-2
                   3.2.2.2  Trailer Pilot Treatment Plant	  3-3
     3.3   Ground Water Evaluation	  3-3
           3.3.1   Water Supply Wells	  3-4
           3.3.2   Groundwater Quality Impacts	  3-5
     3.4   Surface Water Evaluation	  3-8
           3.4.1   High Flow Condition	  3-8
           3.4.2   Low Flow Condition	  3-8
     3.6   General Property Value Impacts	  3-11
           3.6.1   Evaluation of the External Effects of
                   Undesirable Facilities	  3-11
                   3.6.1.1  Noise Effects on Property Values	  3-11
                   3.6.1.2  Other External Effects on Property Value..  3-14
           3.6.2   Limitations of the Analyses	  3-15
           3.6.3   Application of the Analyses to the Proposed
                   Walpole Residual Landfill	  3-16

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                        TABLE OF CONTENTS  (Continued)
     3.7   Construction Impacts	  3-17
           3.7.1   Walpole-MCI	  3-17
           3.7.2   Quincy FRSA	  3-18
           3.7.3   Deer Island	  3-19

CHAPTER FOUR  COMMENTS	  1-1

     4.1   Comments Received	  4-1
     4.2   Approach to Addressing Comments	  4-1

CHAPTER FIVE  RESPONSE TO COMMENTS	  5-1

     5.1   Groundwater and Surface Water	  5-1
           5. .1   Walpole	  5-1
           5. .2   Mitigation and Contingency	  5-4
           5. .3   Time of Travel	  5-4
           5. .4   Screening	  5-5
           5. .5   Incineration	  5-5
           5. .6   Rowe Quarry	  5-6
     5.2   Policy and Regulations	  5-6
           5.2.1   Alternatives and Data Quality	  5-6
           5.2.2   Regional Responsibility	  5-8
           5.2.3   Environmental Regulations	  5-8
           5.2.4   Navigable Waters Act	  5-9
           5.2.5   Acceptability of Alternatives	  5-9
     5.3   Landfill	  5-10
           5.3-1   Landfill Capacity	  5-10
           5.3.2   Landfill Design	  5-10
           5.3.3   Rowe Quarry	  5-11
     5.4   Air Quality and Odors	  5-11
           5.4.1   Areas of Impact and Sensitive Receptors	  5-11
           5.4.2   Data and Methodology	  5-12
           5.4.3   Meteorology	  5-13
           5.4.4   Greenhouse Gases	  5-14
           5.4.5   Odors	  5-14
     5.5   Residuals Characterization	  5-15
           5.5.1   Minor Residuals	  5-15
           5.5.2   Sludge Characteristics	  5-16
     5.6   Public Health	  5-18
           5.6.1   Toxicity of Residuals	  5-18
           5.6.2   Exposure Pathway	  5-19
           5.6.3   Population	  5-20
           5.6.4   Unusual Situations and Worker Health	  5-21
     5.7   Ecology	  5-22
           5.7.1   Wetlands	  5-22
           5.7.2   Federal Regulations	  5-23
                                      ii

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                         TABLE OF CONTENTS (Continued)
     5.8   Socioeconomics	  5-23
     5.9   Technologies	  5-24
           5.9.1   Deer Island	  5-24
           5.9.2   Source Reduction	  5-24
           5.9.3   Composting	  5-24
     5.10  Transportation and Traffic	  5-25
           5.10.1  Number of Trucks	  5-25
           5.10.2  Rail Haulage	  5-27
     5.11  Cost	  5-27
     5.12  Noise	  5-28
           5.12.1  Truck Alarms	  5-28
           5.12.2  Deer Island	  5-28
     5.12  Land Use	  5-29
     5.14  Marketability	  5-30
     5.15  Utilities	  5-30
     5.16  Visual	  5-31
     5.17  Historical and Archaeological Resources	  5-31
     5.18  Prisons	  5-31
     5.19  Editorial Comments	  5-32

CHAPTER 6  ACCEPTABLE'RESIDUAL MANAGEMENT OPTIONS AND MITIGATION	  6-1

     6.1   Introduction	  6-1
     6.2   Review of the Draft SEIS Recommendations	  6-1
     6.3   Review of New Issues,  Information and Modifications
           to the Plan	  6-3
     6.4   EPA Recommendations and Mitigation Measure	  6-4
           6.4.1    Residuals Processing	  6-4
           6.4.2   Water Quality Monitoring and Protection -
                   Walpole-MCI	  6-5
                   6.4.2.1   Leachate Collection System	  6-5
                   6.4.2.2  Landfill-Monitoring	;	  6-5
                   6.4.2.3  Contingency Plan	  6-8
           6.4.3   Other Mitigation Measures	  6-9

CHAPTER 7 - ERRATA	  7-1

     7.1   Text Changes	  7-1
     7.2   Table Changes	  7-16
     7.3   Figure Changes	  7-19

Appendix A - Water Transport Model

Appendix B - Alternative Landfill Capacity Scenarios

Appendix C - Comment Letters

References
                                      iii

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                                LIST OF TABLES


Table                                                                  Page

CHAPTER TWO - MODIFICATIONS TO THE PROPOSED ACTION

2.2-1      Estimated Quantities of Excess Dewatered Sludge Cake	  2-3

2.3-1      Available Landfill Capacity at Walpole-MCI Site (mcy)	  2-4

2.3-2      Estimated Total Capacity Requirements for Landfill
           of Residuals, 1996-2020	  2-5


CHAPTER THREE - EXPANDED TECHNICAL EVALUATION OF MWRA-SELECTED PLAN

3.3-1      Predicted Concentrations in Private Wells Due to a
           Ten Year 50 Percent Landfill Leak	  3-7

3.4-1      Predicted Concentrations Above Background in the
           Stop River Under Low Flow Conditions	  3-10

3.6-1      Characteristics of the Property Value Studies	  3-12


CHAPTER FOUR - COMMENTS

4-1        Comments Received on the Draft SEIS	  4-2

4-2        Winthrop Residents Submitting Letters Similar to
           Comment Letters 020 and #74	  4-7


CHAPTER FIVE - RESPONSE TO COMMENTS

5.4-1      Comparison of Maximum Annual Concentrations from
           Incineration and DEP Guidelines for Dioxin and Furan	  5-13

5.6-1      Summary of Upper Bound Excess Lifetime Cancer Risks
           Associated with Heat Drying (160 dtpd) At Quincy FRSA	  5-21

5.10-1     Number of Trucks During Landfill Construction Period	  5-27


CHAPTER SIX - ACCEPTABLE RESIDUALS MANAGEMENT OPTIONS

6.2-1      Acceptable Site and Technology Combinations	  6-1

6.2-2      MWRA General Marketing Strategy	  6-3

6.4-1      Recommended Mitigation Measures	  6-10
                                      iv

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Table                                                                   Page

CHAPTER SEVEN - ERRATA

5.4-2      Constituents of Concern Exceeding 10 Percent of the
           DEQE TEL Guideline Based on the Worst Case 24-Hour Maximum
           Concentration at Each Site	  7-17

5.5-2      Walpole-MCI Predicted Pollutant Concentrations in
           Stop River Due to a Landfill Leak	  7-18

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                               LIST OF FIGURES


     Figure                                                            £§E§


CHAPTER TWO - MODIFICATIONS TO THE MWRA-PROPOSED PLAN

2.3-1      Landfill Life at 25 Percent Solids (with 25 Percent
           Heat Dried Pellets)	   2-7

2.3-2      Landfill Life at 25 Percent Solids (with No Heat
           Dried Pellets)	   2-8

2.3-3      EPA and MWRA Agreed-Upon Landfill Use	   2-9

2.6-1      Schematic of Cap and Liner Systems	   2-12


CHAPTER THREE - EXPANDED TECHNICAL EVALUATION MWRA-SELECTED PLAN

3.3-1      Locations of Private Wellfields - Walpole-MCI	   3-5


CHAPTER SIX - ACCEPTABLE RESIDUALS MANAGEMENT OPTIONS

6.4-1      Preliminary Monitoring Well Location - Walpole - MCI	   6-7


CHAPTER SEVEN - ERRATA

3.2-6      Schematic of Cap and Liner Systems	   7-20

3.4-3      Walpole-MCI Existing and Proposed Utilities	   7-21

5.9-1      Potential Exposure Pathways for Landfill Sites	   7-22
                                      VI

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                                  CHAPTER ONE

                                  INTRODUCTION


 1.1   ORGANIZATION AND CONTENTS OF THIS  FINAL SEIS

 The  original  contents of the  Draft Supplementary Environmental  Impact
 Statement (U.S.  EPA,  DSEIS,  1989) are not reproduced here. The  Draft stands  as
 a document of record  and this Final SEIS contains modifications of or
 additions to  the contents of  the  Draft  SEIS as necessary.  This Final SEIS
 represents a  reexamination of the analyses, conclusions and recommendations
 contained in  the Draft Supplementary Environmental Impact Statement (SEIS).
 This reevaluation takes  into  account public and agency comments received on
 the  Draft SEIS,  technical information produced since publication of the Draft,
 and  modifications made to the Massachusetts Water Resources Authority (MWRA)
 recommended long term residuals management plan (MWRA, RMFP, FEIR, 1989).
 This Final SEIS  also  contains expanded  evaluations of critical elements of the
 MWRA-recommended plan including additional recommendations and proposed
 mitigation measures.

 The  MWRA's modifications  to its recommended plan and-the implications of those
 changes for effective residuals management are discussed in Chapter 2 of this
 document.   The expanded  technical evaluations, which address public health,
 characterization of the digested sludge, construction, property value and
 ground and surface water  effects are found in Chapter 3.  A large portion of
 the  document  is  devoted to presenting and responding to comments received on
 the  Draft  SEIS,  which can be  found in Chapters 1 and 5, respectively.  In
 Chapter 6,  conclusions and recommendations of the Draft SEIS are reviewed in
 light of comments or  new  information received.  Chapter 7 contains errata, or
 changes and corrections to specific sections of the Draft SEIS.

 1.2  RELATIONSHIP TO  OTHER ENVIRONMENTAL REVIEW DOCUMENTS

 In 1985, an EIS  and associated  Record of Decision (ROD) was prepared to
 evaluate the siting of the MWRA's new Wastewater Treatment Facilities.  These
 documents  supported the .selection of Deer Island as the preferred location for
 a secondary wastewater treatment plant for all MWRA wastewater flows
 (U.S. EPA, FEIS,  1985).  The  1985 Siting EIS and ROD,  however, required that
 supplemental environmental review be undertaken for a number of related
 components of the wastewater treatment plant,  including long-term residuals
management.

The Draft SEIS on long-term residuals management addressed several issues left
unresolved by the earlier Siting EIS,  including the methods and locations of
facilities for processing, reuse and disposal  of long-term residuals.   These
 issues have been addressed in several documents issued over the last two
years, including but not  limited to the MWRA's Draft Reports on Minor
Residuals Landfilling and Candidate Options (MWRA,  RMFP,  Landfill I and
Options I & II,  1988), the Draft Reports on Environmental Screening (MWRA,
RMFP, Screen,  I - III, 1988),  and the Residuals Management Facilities Plan,
Draft Environmental Impact Report (MWRA, RMFP,  DEIR,  1989).   After public and
                                      1-1

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agency review and comment the Final EIR and Facilities Plan was released in
August 1989.  In May 1989, the Long Term Residuals Management Draft SEIS was
issued and a similar process was followed to finalize EPA's Draft to produce
this Final SEIS.

The release of this Final SEIS will be followed by a public comment period
similar to that which followed publications of the Draft SEIS.  A Record of
Decision (ROD) will be issued by EPA within the next few months which will
state EPA's final recommendation and official position on the preferred
long-term residuals management plan for the MWRA.
                                      1-2

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                                 CHAPTER TWO

                     MODIFICATIONS TO THE PROPOSED ACTION
2.1 INTRODUCTION
This chapter describes changes to the residuals management alternatives as
presented in the Draft SEIS based on public comments and new information
developed since release of the Draft document.  Since the issuance of the
Draft EIR, MWRA has recommended changes to their preferred plan with regard to
sludge processing, landfilling and the designated Walpole truck route.  Each
of these changes is described below together with an evaluation of its
potential impacts and implications for the Final SEIS recommendations.

2.2  SLUDGE PROCESSING

2.2.1  Description of Modifications

The Draft SEIS considered residuals management alternatives using a sludge
composting facility for one third of the sludge and a sludge pelleti2ing
facility for the remainder, as proposed by MWRA.'. MWRA has more recently made
the decision to eliminate composting from the residuals management program
based on the potential that it could cause problematic odors, traffic, and
land use impacts (MWRA, RMFP, FEIR, 1, 1989).

The MWRA has also finalized its decision to use solid bowl centrifuges, rather
than belt filter presses, as the primary dewatering device for the long-term
residuals management period.  Belt filter presses used for dewatering during
the interim program will be used as backup equipment during the first phase of
the long-term management program.  The type of centrifuge that is proposed is
called a "high solids" centrifuge, which incorporates recent technology that
removes more water from the sludge.  The capacity of the heat driers  is a
function of the solids content of the dewatered sludge and thus a function of
the performance level of the centrifuges.

2.2.2  Implications

The elimination of composting as a second technology for residuals processing
reduces the redundancy and flexibility in the sludge processing system and
increases the importance of having adequate heat dryer capacity and a reliable
method of disposing of dried sludge and dewatered sludge cake.  MWRA  has
acknowledged that after 1999 the capacity of  the proposed six heat dryers  is
not adequate to pelletize all the dewatered sludge  in the event of the loss of
one or more heat drying/pelletizing trains, or if the performance level of the
centrifuges is less than the 25 percent cake  solids expected.  It is  also
important that the final design of the dewatering/heat drying facility allow
for a high degree of flexibility among process trains so as to allow  full
utilization of all available heat dryers regardless of which centrifuges are
in operation.  If the total available capacity of the heat dryers  is
inadequate to pelletize all dewatered sludge, MWRA  has proposed that  excess
dewatered sludge be hauled to the minor residuals landfill  in Walpole (MWRA,


                                      2-1

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RMFP, FEIR, 1, 1989).  Thus, the impacts of less than expected dewatering
performance and lack of adequate heat drying capacity are primarily associated
with the ultimate capacity of the landfill.  An analysis of landfill capacity
based on various dewatering and heat drier scenarios is presented in Section
2.3.

Since the decision was made to use "high-solids" centrifuges, MWRA has assumed
sludge cake solids in the range of 25 to 29 percent.  The Draft SEIS assumed a
more conservative sludge cake solids content of 20 percent for planning
purposes for all conditions and types of equipment.  The effectiveness of the
dewatering devices is dependent on the sludge feed solids content, the percent
volatile solids in the sludge cake, and the effectiveness of the chemical
conditioning system.  Although several cities in the United States are in the
process of procuring "high-solids" centrifuges, the operating data currently
available is mostly from on-site tests performed at several treatment plants
(M&E, 1989).  MWRA's anticipated performance compares reasonably well with
test results.  The anticipated ratio of primary to waste activated secondary
sludge, the percentage of volatile solids, and the feed sludge solids content
compare favorably with similar parameters in the test runs.  Therefore, based
on the data available, the centrifuges should be able to produce dewatered
sludge cake with a minimum of 25 percent cake; however, for planning purposes
the impacts of excursions to 20 percent solids are also considered below.
Quantities of excess sludge cake under various centrifuge performance
scenarios are presented in Table 2.2-1.

2.3  LANDFILL PROCEDURES

2.3.1  Description

Given the reliance on a landfill as a sludge management backup it is important
to verify that the MWRA-proposed Walpole-MCI landfill site has adequate
capacity to ensure a reliable long-term sludge management program.  Capacity
must be available for disposal of grit and screenings, six-month emergency
sludge disposal, and excess sludge or unmarketed heat-dried pellets if
necessary.

Presented herein is a landfill capacity analysis which is independent of the
analysis prepared by MWRA in the FEIR.  The landfill capacity available after
reserving capacity for grit and screenings, and liner, cap, and cover material
is 1.33 million cubic yards (mcy) as shown in Table 2.3-1.  Emergency sludge
disposal may be required when equipment breakdowns occur which would prevent
heat drying the sludge cake.  The capacity required for emergency sludge
disposal should accommodate a total of six months dewatered sludge cake
production over the project planning period of 25 years.  This analysis has
conservatively assumed that this would occur at the maximum sludge production
rate of 230 dry tons per day.  The volume required for emergency sludge cake
landfilling ranges from 0.24 to 0.16 million cubic yards for 20 to 29 percent
solids sludge cake.

In addition to this emergency situation, and because MWRA no longer plans to
construct composting facilities (which would have provided redundancy for the
heat drying/pelletizing process) additional sludge cake may need to be
landfilled under some conditions.

                                      2-2

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       TABLE 2.2-1.   ESTIMATED QUANTITIES OF EXCESS DEWATERED SLUDGE CAKE
1996-1999
(Primary + 20%
Secondary)
Digested Sludge Quantity (dtpd)
No. of Heat Drying Trains Installed
Scenario 1 - 29* Solids, 67 lb/ft3
Heat Dryer Unit Capacity (dtpd)
Total Operating Capacity (dtpd)^
Excess Sludge Cake at Max.
Flows (dtpd)t2)
Scenario 2 - 25? Solids, 66 Ib/ft3-
Heat Dryer Unit Capacity (dtpd)
Total Operating Capacity (dtpd)^
Excess Sludge Cake at Max.
Flows (dtpd)(2)
Scenario 3 - 20% Solids, 65 Ib/ft3-
Heat Dryer Unit Capacity (dtpd)
Total Operating Capacity (dtpd)^
Excess Sludge Cake at Max
Flows (dtpdJ(2J
109-139
5
45
180
0
37
148
0
31
124
0
2000-2020
(Primary & Full
Secondary )
165-230
6
45
225
5
37
185
45
31
155
75
(1)  It is reasonable and conservative to assume that one unit will not be
     operating at any given time.
(2)  Maximum flows are expected to occur for 4 months each year.
                                     2-3

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      TABLE 2.3-1.  AVAILABLE LANDFILL CAPACITY AT WALPOLE-MCI SITE (mcy)



     Total available  volume                                       3.17

     Minimum Landfill Capacity  Requirements, mcy

          Grit and screenings                                     0.56
          Bottom  Liner                                            0.31
          Cap                                                     0.30
          Cover and Dike                                          0.6*1

               Total                                              1.8H

     Available Capacity Remaining                                 1.33


Source:  MWRA, RMFP,  FEIR, 1, 1989.

As discussed in Section 2.2 above, the heat drying/pelletizing unit capacity
is dependent on the solids content of the mechanically dewatered sludge.  The
solids .content of dewatered sludge cake may vary from as low as 20 percent to
29 percent.  As dewatered sludge cake solids decrease, excess sludge cake
quantities increase significantly (Table 2.2-1).  This excess sludge cake,
once delivered to the Walpole - MCI landfill site, would be mixed manually
with a bulking agent  (e.g. sand).  The volume of bulking agent that needs to
be added will also vary with the solids content of the sludge.  It has been
assumed that the ratio of bulking agent to excess sludge would range from 1:1
to 3:1 on a volume basis.

Although an aggressive program is being developed by the MWRA to market and
distribute heat dried pellets, provisions to landfill pellets have also been
considered.  Estimations of the volume required for landfilling pellets
assumes that the solids content of the heat dried pellets is 90 percent.  It
is not expected that  bulking agent will be required to improve the stability
or workability of the pellets.  The volume required for landfill pellets could
range from 0.68 to 1.35 mcy, depending on the solids content of the sludge
cake and the percentage of pellets assumed not to be marketed (up to
50 percent).

Table 2.3-2 provides  a summary of the total volume of excess sludge, six-month
emergency sludge disposal, and heat dried pellets (with bulking agents, as
necessary) that might need to be landfilled.

2.3.2  Implications

The impacts on the capacity of the landfill have been evaluated with regard to
the estimated volumes of residuals discussed above.  The required residuals
landfill volume varies greatly depending on the assumptions made in the
analysis.   However, the required volume largely depends on the effectiveness
                                      2-1*

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           TABLE 2.3-2.  ESTIMATED TOTAL CAPACITY REQUIREMENTS FOR
                     LANDFILL OF RESIDUALS,  1996 - 2020(1>
     Item                                        Volume

     Excess Sludge with Bulking Agent, mcy

          Mix Ratio  3:1                            0.08  - 5.52
          Mix Ratio  2:1                            0.06  -4.14
          Mix Ratio  1:1                            0.01  - 2.76

     Six-month Emergency Sludge Disposal with
     Bulking Agent, mcy

          Mix Ratio  3:1                            0.61  - 0.96
          Mix Ratio  2:1                            0.18  - 0.72
          Mix Ratio  1:1                            0-32  - 0.48

     Heat Dried Pellets, mcy

          50* Landfilled                            1.14  -  1.35
          25% Landfilled                            0.57  - 0.68


(1)  Volume at four months per year at maximum rates with one heat drying
     process train not in operation at all times.
(2)  Ranges represent 20 to 29 percent solids dewatered sludge cake.

and reliability of the dewatering facilities and, hence, the unit capacity of
the heat drying operations, and the degree of success MWRA has in marketing
heat dried pellets.  Two of the more likely scenarios for landfill use are
shown in Figures 2.3-1 and 2.3-2 (other landfill use scenarios and sludge
product volumes predicted under various drying, bulking, and marketing
scenarios are contained in Appendix B).

MWRA has recognized the need to preserve landfill capacity.  The EPA and MWRA
reached an agreement which calls for the MWRA to carefully husband the
utilization of the landfill to preserve capacity.  Specifically, the MWRA has
committed to a maximum rate of use of the landfill to ensure the "Available
Capacity Remaining" (ACR) is sufficient for the entire planning period
(Figure 2.3-3).  The assumptions that provide a basis for the agreement are
somewhat less conservative than some of the assumptions made in the analysis
presented here.  However, the MWRA has agreed that should these less
conservative assumptions not be realized, it may be required to utilize other
backup measures to ensure proper sludge disposal (letter of August 10, 1989
from Paul Keough, Acting Regional Administrator, EPA Region I to Paul Levy,
Executive Director, MWRA).

Because the use of landfill capacity is significantly dependent on the heat
drying capacity, MWRA should reserve the space necessary for construction of
two additional heat dryer process trains adjacent to the FRSA heat drying
                                      2-5

-------
facility as currently proposed.  Therefore, if the centrifuge performance or
heat dryer capacity and reliability has been less than anticipated during the
interim sludge management program and early long-term planning periods,
additional heat dryer capacity could be made available at the time of full
secondary wastewater treatment implementation.  This will enable the MWRA to
conserve landfill space by decreasing the reliance on landfilling as the
backup sludge management method.

2.4 DESIGNATED WALPOLE TRUCE ROUTE

In the Final EIR, MWRA has designated an alternate truck route to be used
during any period when more than 24 trucks per day will travel to the landfill
site (MWRA, FEIR, 1, 1989).  The alternate truck route proposed by MWRA is
similar to the one presented by EPA in the Draft SEIS for use by a portion of
the trucks, in the case of emergency sludge landfilling, and thus will have no
effect on the recommendations made in the Draft SEIS.  It should be noted,
however, that the route proposed by MWRA involves two more turning movements
than the one proposed by EPA, and that EPA continues to support the route it
recommended in the Draft SEIS.  Each route is acceptable and has similar
short-term impacts; however the route presented by EPA in the Draft SEIS  is
more direct and therefore more convenient for truck drivers travelling to the
landfill site.

2.5  UTILITIES

Since the publication of the Draft SEIS, the MWRA has developed a more
detailed plan for extending water and sewer utilities to the Walpole MCI
landfill site.  The alternatives proposed  in MWRA's Final EIR for connections
to Walpole's municipal water and sewer systems are described below.  EPA
believes the MWRA has examined several reasonable alternatives and  that with
these alternatives as contingencies, providing water and sewer services to  the
Walpole MCI site will be feasible and will not constrain the use of the site.

2.5.1. Water

In order to prevent causing a  "brown out", or water supply shortage due to
water withdrawal from the Walpole system,  the MWRA would install a  water
storage facility at the landfill.  Water would be withdrawn from the municipal
system during off-peak hours to prevent pressure fluctuations to neighboring
connections and ensure that an adequate water supply is readily available for
use at all times.

If this alternative is not feasible, the MWRA would either make a direct
hookup to  the MWRA's own water supply system  (bypassing the municipal system),
or truck potable water to the  site.  The nearest town  in the MWRA water  supply
system is  Norwood, which borders Walpole to the northeast.  To make this
connection, a dedicated water  line would have to be  installed a considerable
distance through some moderately populated areas of Walpole.  If potable  water
were trucked  to  the landfill site, water storage tanks would be installed at
the landfill.  Water would be  obtained from the MWRA system and transported in
                                      2-6

-------
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                    FIGURE 2.3-1. LANDFILL LIFE AT 25% SOLIDS (WITH 25% HEAT DRIED PELLETS)

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         •3:1 MIX RATIO
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                         YEAR


FIGURE 2J-2. LANDFILL LIFE AT 25% SOLIDS (NO HEAT DRIED PELLETS)
                                                                                     1.1 MIX RATIO

-------
   1400
o
^  1200
a
o
Q   1000-
ui
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<   800
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2

UJ   600
oc
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    400-
    200-
  I
1995
                        I
                       2000
  I
2005
2010
 I
2015
 I
2020
                                          YEAR
                 FIGURE 23-3. EPA AND MWRA AGREED-UPON LANDFILL USE

-------
tanker trucks having a capacity of approximately 5,000 gallons each.  During
the summer months when truck washing is more frequent and water is used for
dust control, the additional truck traffic for water transport could add up to
four trucks per day (MWRA, RMFP, FEIR, 1, 1989).

2.5.2. Sewer

The MWRA plans to discharge combined leachate and sanitary wastewater from the
landfill facility to the Walpole municipal sewer system.  An approximately
9,000 foot force main (two to four inches in diameter) from an on-site pump
station would be installed following Winter Street, then Route 1A north, to an
existing ten-inch sewer in the Walpole system.  The average daily discharge
would be approximately 15,000 gpd (gallons per day).  If necessary, a
wastewater storage facility sized large enough to regulate wastewater
discharges would be added to the already proposed pump station.  Discharges
would be made during non-peak periods to minimize impacts to the municipal
system.  Several MWRA interceptor sewers downstream from the Walpole extension
sewer have had capacity and constriction problems which the MWRA is working to
resolve through implementation of their infiltration and inflow (I/I)
management plans for these areas.

If connection to the Walpole municipal sewer system rs determined unfeasible,
alternative plans include the removal of wastewater from the site using tanker
trucks, or the installation of a dedicated sewer line from the site to the
nearest MWRA interceptor.  Trucking of the wastewater would require a maximum
of three tanker trucks per day using 5,000 gallon capacity tanks.  The
wastewater would be discharged into an MWRA interceptor at a manhole opening,
which could require modifications to serve as a receiving/metering station
depending on the site selected.

Installing a dedicated sewer line would involve constructing a force main or
gravity line north along Route 1A to connect to the MWRA interceptor located
at the border of Walpole and Norwood.  Downstream sewer capacity and
constriction problems would need to be alleviated through I/I controls as
described above (MWRA, RMFP, FEIR, 1, 1989).

2.6 LANDFILL DESIGN

The proposed Walpole MCI landfill will be designed and constructed  in full
accordance with the guidelines established by the Massachusetts Department of
Environmental Protection, Division of Water Pollution Control (DEP/DWPC).
Following is a summary of the main features of the landfill design and the
mitigation measures which MWRA will put in place in order to mitigate any
potential adverse impacts which could result from operation of the residuals
landfill.

2.6.1 Landfill Design

The proposed residuals landfill will be designed using state of the art
technology to minimize the potential for leaking and therefore provide maximum
protection from potential contamination.  The landfill design will  include a


                                     2-10

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double liner and double leachate collection system as well as measures  to
prevent contamination of stormwater runoff.

2.6.1.1 Landfill Liner System.  The landfill liner and leachate collection
systems proposed are shown in Figure 2.6-1.  The primary and secondary  liners
will each have a permeability of no greater than 1x10~' cm/sec as required by
the DEP/DWPC.  The synthetic primary liner proposed by MWRA is expected to
provide a greater degree of protection, as it will have a permeability  in  the
range of 1x10"'^ cm/sec.  The secondary liner will consist of natural clay or
bentonite and will protect soil and groundwater beneath the site in the event
of a leak in the primary liner (MWRA, RMFP, FEIR, 1, 1989).  The DWPC is
requiring that the secondary liner be a minimum of two feet thick.

2.6.1.2 Leachate Collection System.  The design and operation of the leachate
collection system will also serve to minimize the potential for contamination
of surrounding soils and groundwater.  The primary collection system will be
above the synthetic liner and will be surrounded by an 18-inch sand layer for
protection and drainage.  Under normal operating conditions, this system will
collect and transmit leachate away from the site and into the sewer system.
The secondary leachate collection system will be located below the primary
liner and will afford added protection in  the event of a failure in the
primary liner.  The secondary system would serve as a leak detection system
and would collect leachate until the leak  is found and repaired  (MWRA,RMFP,
FEIR, 1989).  Sampling and testing of both systems should be required to
monitor the quality of leachate entering the sewer system, and a leachate flow
monitoring program should be established in order to ensure optimum liner
performance.  The leachate collection system should also be designed to keep
leachate separate from uncontaminated stormwater.

2.6.1.3 Runoff Control System.  Potential  surface water impacts  resulting from
the construction and operation of  the residuals  landfill  include alteration of
existing hydrology and contamination of stormwater.   Protection  against these
impacts at the Walpole MCI site will be provided by  the stormwater control
system.  The existing runoff pattern will  be maintained wherever possible by
diverting runoff around  the landfill,  thereby sustaining  the  flow of runoff  to
the wetlands along the the Stop River.  Stormwater may  be  routed into
retention basins if necessary  in order to  settle solids prior  to discharge.
Any dikes, trenches and  berms  used  to divert runoff  will  prevent flow  into
exposed portion of the  landfill and  will  thus allow  stormwater to  remain
uncontaminated.  Stormwater falling  directly on  the  lined  portions of  the
landfill will be collected by  the  leachate collection system and discharged  to
sewers  (MWRA, RMFP, FEIR,  1,  1989).  Other measures  which will minimi2e the
potential for surface water  impacts  include the  construction  of 3:1  slopes on
the site to  promote  runoff and reduce  erosion, and  the use of hay  bales to
minimize the migration  of sediment.  Once a cell has reached  its capacity,  it
will  be capped  with  layers of clay and topsoil and  a system of ditches and
drainage pipes  will  be  installed  to direct runoff to a discharge or  retention
area  (MWRA,  RMFP, FEIR,  1,  1989).
                                      2-11

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              LLJ

              CO

              CO
              CL
              <
              O
      Sand Drainage Layer
 •*~'tO "  • o  -^-'   • • — --> • O
£ °o°0 o Intermediate Soil Cover ^»^
o y> t?^,^ rft^yfriHZft' J&ui
                                      RESIDUALS
           Leachate Pipe
                                 Sand Drainage Layer
                         a
              LU

              CO

              CO
              cc
              LU
              z
      Sand Drainage Layer
           O
                                                                    T
                                                                     2'
                                         r
                                        f-
                                                                     V
                                                                       6"
                                                                   V-6M
                                                                    li
                                                                          60 Mil Membrane
r-6-
Source: MWRA, RMFP, Landfill, 1,1988         in-Situ Soil

                    FIGURE 2.6-1. SCHEMATIC OF CAP AND LINER SYSTEMS

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                                 CHAPTER THREE
             EXPANDED TECHNICAL EVALUATION OF MWRA-SELECTED PLAN
3.1  INTRODUCTION

This section presents additional analyses prepared by EPA based on new
information that became available on the MWRA-recommended plan after release
of the Draft SEIS.  A description of each of these analyses and its
implications for the Final SEIS recommendations are discussed below.

3.2  DEVALUATION OF SLUDGE QUALITY

3.2.1  Analysis

Two additional sources of data have become available since the release of the
Draft SEIS.  Additional data regarding the character of primary digested
sludge is available from MWRA's ongoing monitoring program at Deer Island and
new data has been developed from MWRA's existing trailer pilot plant.
Presented below are analyses of the new data obtained from the digesters and
from the trailer pilot treatment plant.

3.2.1.1  Primary Digested Sludge

The MWRA operates an ongoing monitoring program at Nut Island and Deer Island
from which monthly sludge quality data was reported in the Draft SEIS.  The
data presented in the Draft SEIS was for through October 1988 for both Nut
Island and Deer Island.  New data is available up to May 1989, adding seven
months of data (October 1988 to May 1989) to the previously reported eight
months (March 1988 to October 1988).  All the samples for the new data set
were taken at the same sampling locations as those taken over the previous
eight months.

Subsequent to the May 1989 sampling, the MWRA changed the location for
digester sampling from the bottom of the digesters to a more completely mixed
area of the digester in order to obtain sludge samples more representative of
likely future sludge quality.  This was important for purposes of obtaining
classification of compost from the pilot plant.  Six consecutive months of
representative samples are required by the Massachusetts Department of
Environmental Protection (DEP) to classify the sludge quality according to
sludge product use categories (Type I, II, or III).  Data from the new
sampling location was not available to be included in this final SEIS and the
reported data does not reflect the change in sampling location which the MWRA
mentioned in its FEIR.

The two groups of monitoring data (March 1988-October 1988, and November 1988-
May 1989) were analyzed statistically to determine whether or not the means
(averages) of the concentrations of certain pollutants were different in the
two data sets.  The only significant changes in the monitoring results were
that the mean Boron and Molybdenum concentrations increased.  No other changes
in pollutant concentrations in the sludge were found.
                                      3-1

-------
A further analysis was performed to determine the implications of the changes
on the sludge quality impact analysis of the Draft SEIS.   A weighted  average
(30% Nut Island, 70$ Deer Island) was calculated using all the available
sampling data (March 1988-May 1989) for Molybdenum and Boron.   These  weighted
averages were compared to Table 3.1-3 in the Draft SEIS which  summarizes the
sludge quality used to assess impacts.

3.2.1.2  Trailer Pilot Treatment Plant.

Between April 1989 and September 1989 the MURA conducted  additional sludge and
wastewater testing at a pilot scale treatment plant located at Deer Island.
The pilot plant used effluent wastewater from the existing Deer Island
Treatment Plant which has already undergone primary treatment, as its
influent.  The pilot project was broken into four phases  and tested two types
of secondary treatment at different flow levels: a less conventional
anoxic/oxic system using an anaerobic selector followed by an  oxygen  system,
and a more conventional activated sludge system. Within each phase, the data
sampled during steady state conditions were analyzed.  Phases  I and II tested
the systems under a high flow of five to six gpm (gallons per  minute), while
Phases III and IV tested the systems under a low flow of approximately
three gpm.  The data from the Phase III and Phase IV (the low  flow period) is
used in this Final SEIS; data from Phase I and II is not currently available.

3.2.2  Results of the Analysis

Presented below are the results of the analyses of the data obtained from the
digesters and from the trailer pilot treatment plant.

3.2.2.1  Primary Digested Sludge.

Although the new weighted average for Boron (106 mg/kg) was higher than the
original weighted average (37 mg/kg), it was still lower than the projected
digested primary concentration (170 mg/kg). Therefore, because impacts were
assessed in the Draft SEIS using both projected and actual data, the original
analysis for Boron was sufficiently conservative and would not change due to
the new data.  The new weighted average for Molybdenum (11 mg/kg) was greater
than both the projected digested primary (11 mg/kg) and the earlier weighted
average (26 mg/kg).  When adjusted for secondary treatment, the estimated
Molybdenum concentration would be  108 mg/kg.  The Massachusetts limit for
Molybdenum application on non-agricultural and non-grazing lands is 40 mg/kg
and 10 mg/kg on agricultural and grazing lands.

PCB's were undetected in the samples for the new data set, however, the
detection limits were reported by the lab as being relatively high owing to
high levels of other organics present in the samples.  The following organic
compounds were detected during two months of testing for organics  (November
1988 and February 1989): chloromethane, 1,2-Dichloroethane(tot), toluene,
chlorobenzene, ethylbenzene, xylene, napthalene, 4-methyl-2-pentanone,
2-butanone, methylene chloride, 2-methylnaphthalene, n-nitrodiphylamine,
phenanthrene butylbenzylphthalates, di-n-butylphthalates, and bis(2-ethylhexl)
phthalates.  No attempt has been made to estimate concentrations of these
organics in future sludge or sludge products, however, because of  the high


                                      3-2

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variability of their presence and the difficulty in following the fate,
transport, and transformation of these organics during treatment.  Most  of
these organics will volatilize, transform, or bind during different stages of
the treatment process.  For this reason, very little literature has been
published on the fate of organic compounds in municipal sludge.

3.2.2.2  Trailer Pilot Treatment Plant.

Results of the pilot treatment analyses show that molybdenum concentrations
consistently exceeded sludge application regulations for Massachusetts.   In
all sludge samples measured, the molybdenum concentrations exceeded the
10 rag/kg land application limit for agricultural and grazing lands.
Approximately half of the samples exceeded the 40 mg/kg limit for land
application to non-agricultural and non-grazing lands.  The mean molybdenum
concentration (44.53 mg/kg) also exceeded the less stringent standard.

Two out of thirteen samples tested for copper also exceeded Massachusetts'
land application rate of 1000 mg/kg.  The mean (825 mg/kg) of the copper
samples, however, was below the 1000 mg/kg application rate.  All metals
concentrations would increase somewhat with digestion due to further mass
reduction and the conservative nature of metals. • Since impacts in the
Draft SETS were assessed using a projected digested combined concentration of
1240 mg/kg for copper (Table 3-1-4 of the Draft), the previously reported
analysis is sufficiently conservative and has not been revised.

The molybdenum concentration in the sludge could hinder the marketing of heat
dried pellets in-state because Massachusetts is the only state that currently
regulates molybdenum.  Significant reduction of molybdenum can be achieved
through selective enforcement and industrial pretreatment efforts.

3.3  GROUND HATER EVALUATION

As discussed in the Draft SETS, it unlikely that the landfill double liner and
leachate monitoring and collection systems would both fail simultaneously
(U.S. EPA, Draft SEIS, 1989).  In order for leachate-contaminated groundwater
to reach the prison water supply, the following chain- of events would have to
occur:

     1.   The leachate from a landfill cell is not captured or removed by the
          first leachate collection system, imbedded in an 18-inch thick layer
          of sand at the bottom of the cell.

     2.   The leachate then penetrates the primary synthetic liner, which has
          a hydraulic conductivity of approximately 1x10"' feet per year and
          is 60-mil thick.

     3.   After penetrating the primary liner the leachate is not captured by
          the second leachate collection system, which activates alarms that
          signal that the primary liner has been breached.
                                      3-3

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     4.   The leachate penetrates the secondary liner,  which consists of two
          feet of natural clay or bentonite having a hydraulic conductivity of
          approximately 0.1 feet per year.

     5.   After penetrating both liners undetected, the leachate migrates
          through at least approximately 25 feet of unsaturated soils to reach
          the groundwater saturated zone.

     6.   Upon reaching the saturated zone, the leachate gradually mixes with
          ground water.  Because leachate is a complex mixture of various
          contaminants that behave differently in different soils, some
          compounds will move at nearly the same rate as groundwater, while
          others will be significantly retarded and adsorbed by silt, clay,
          and inorganic material in the soils.  Due to varying conditions in
          topography, soil characteristics, and groundwater flow rates, the
          outer edge of the leachate plume would likely be highly irregular in
          shape and concentration.

     7.   The plume travels approximately 2,000 feet to the wetlands area
          along the Stop River and the pond, escaping detection by monitoring
          wells located down-gradient of the landfill cells.  Some of the
          leachate plume could then be adsorbed by organic deposits in this
          area, and contribute to surface water or be lost to the atmosphere
          through evapotranspiration, especially in summer months.

     8.   In order for contaminants to continue westward under the Stop River
          to the nearest water supply well (#4A), and reach concentrations
          that exceed water quality criteria protective of public health, at
          least three conditions would have to be met:

          •    Well MA's ground water capture zone would have to extend
               underneath the Stop River;

          •    Well MA would have to pump continuously during the time
               required to move the plume approximately 1,800 feet to the
               well; and

          •    The plume would have to reach the well undetected at
               concentrations great enough to exceed the effects of
               contaminant alteration and dilution.

While this scenario is unlikely, the possible impacts of such a chain of
events are assessed in this Final SEIS beyond the projected impacts evaluated
in the Draft SEIS.  Specifically, an investigation was conducted in order to
determine the potential for contamination of drinking water supply wells in
the area surrounding the Walpole-MCI site.

3.3.1  Hater Supply Hells

A total of ten water supply wells are located in the immediate vicinity of the
landfill site.  There are two private wellfields (two wells each) located on
Winter Street approximately 2000 feet from the intersection of Winter Street


                                      3-4

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and Route  1A.  The potential effects of a landfill leak on the private wells
were not evaluated in the Draft SEIS.  Based on concern expressed over the
issue during the comment period, an analysis of these wells is presented here.

Figure 3.3-1 illustrates the locations of the private wellfields.  One
wellfield  (Wellfield #1) belongs to a dog kennel and residence and is adjacent
to the northeast corner of the landfill site.  The second wellfield
(Wellfield #2), located directly across Winter Street from the first
wellfield, is associated with a horse farm (MWRA, RMFP, DEIR, 2, 1989).  The
distance between the landfill and Wellfields #1 and #2 is approximately 800
feet and 1200 feet, respectively.  For purposes of analysis, the yield of each
of the four wells was conservatively estimated as five gallons per minute
(gpm) which corresponds to DEP's estimate of the aquifer yield for regions
designated as LL2 (MWRA, RMFP, Screen I, 1988).  A map of the different
aquifer regions is presented in Figure 4.4.4 of the Draft SEIS.

Two other drinking water wells (the Pondville wells) lie approximately 3000
feet south of the landfill site.  One of these is currently used to supply
water to the Southwood Community Hospital (formerly known as the Pondville
State Hospital).  The estimated safe yield of this well is 60 gpm.  The second
well is owned by the Norfolk prison facility and has^een abandoned due to
high levels of manganese (MWRA, RMFP, FEIR, 1, 1989).  The four prison supply
wells to the west of the Stop River were investigated for the Draft SEIS and
are discussed in Section 5.5.2.2 of the Draft document.

3.3.2  Groundwater Quality Impacts

A groundwater contaminant transport model was used to investigate potential
groundwater impacts from an undetected,unremediated leak in the Walpole-MCI
landfill.  The model simulates the transport of a plume of contamination and
accounts for the effects of dilution by groundwater and retardation by soil
particles.   A complete discussion of the model development, inputs and
assumptions is presented in Appendix A.  The model was run until peak
contaminant concentrations were observed at the two private wellfields.  The
results of the private well investigations are summarized in Table 3.3-1.
Since the pumping rate of the private well is much less than the local
groundwater flow, no dilution from background flow would be expected and thus
the maximum concentration at the wells was assumed to be equal to the maximum
concentration developed by the model.  As shown in the table, pollutant
concentrations are predicted to be below the Massachusetts groundwater
criteria under even the worst-case scenario of a fifty percent leak for ten
years.  Only cadmium and mercury have predicted concentrations which even
approach the applicable water quality criteria.  The table also indicates that
the time required to reach peak contaminant concentrations at the private
wells would range from approximately 200 years to over 200,000 years.  In sum,
no adverse effects on private wells were predicted in the event of an
undetected, unremediated landfill leak.
                                      3-5

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                         -
                        '  r%f!  :|/J/V-^
                         rV^^/TT   L£il
      SCALE IN METERS

2000         0         2000
       SCALE IN FEET
            LEGEND

        APPROXIMATE SITE BOUNDARY

	APPROXIMATE LANDFILL BOUNDARY

 2 •     PRIVATE WELLFIELD LOCATIONS
       FIGURE 3.3-1.  LOCATIONS OF PRIVATE WELL FffiLDS-WALPOLE MCI
                                                             » r ic * L r A t DO v

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                                  TABLE 3.3-1.  PREDICTED CONCENTRATIONS
                        IN PRIVATE WELLS DUE TO A TEN YEAR 50 PERCENT LANDFILL LEAK
Metal
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Highest
Leachate
Concen-
tration
87(a)
3900(b)
310(a)
420(a)
1300(b)
60(a)
46(a)
30(b)
Mass
Groundwater
Standard/
EPA MCL
50
1000
10
50
50
2
10
50
Predicated Concentration
Well field //I
1.7
38.9
9.7
4.0
19
1.1
2.3
0.5
Well fie Id #2
0.7
16.1
4.3
1.6
8.1
0.6
1.0
0.2
Estimated Time to Peak (Years)
Wellfield #1 Wellfield #2
432
172800
269
134400
6240
355
173
672
513
205200
319
159600
7410
422
205
7980
Notes:  All units ug/1 unless noted
        (a) Source:  MDC,  1983.
        (b) Source:  MWRA,  ISPD,  Vll,  1989.

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As noted in the Draft SEIS,  the Pondville Wells are located south of the
landfill site,  upgradient of the predominant groundwater flow direction.  The
results of the 1988 and 1989 field investigations also indicate that the area
between the site and the Pondville wells is underlain by low permeability
deposits (MWRA, RMFP, FEIR,  1,  1989).   Therefore, under normal operating
conditions the wells would not  be expected to significantly influence the
groundwater flow beneath the site.

3.4  SURFACE WATER EVALUATION

For the Final SEIS, additional  investigations were conducted in order to
determine a range of flows which could be expected for the Stop River.  In
particular, estimates were derived for the seven day, ten year low flow (7Q10)
and the two-year flood at the Winter Street Bridge.  These extreme conditions
were then utilized to predict a range of potential contaminant concentrations
in the Stop River resulting from a potential landfill leak at the MCI-Walpole
site.

3.4.1  High Flow Conditions

There are no literature estimates of the two-year flood flows in the Stop
River or surrounding areas.  However, equations developed by the U.S.
Geological Survey  for small, rural streams in Massachusetts can be used to
provide a reasonable estimate of peak flood flows (Wandle,  1982).  A
recurrence interval of two years was chosen for the peak discharge because a
flood of this magnitude is relatively common when compared  to the 100-year
flood.  The following equation for the two-year flood was employed:


                             90., •  36.3."-6821


In the equation, Q   is the estimated two-year flood discharge  (cfs) and A is
the drainage area fsqWe miles).  Using the drainage area  upstream of  the
bridge, the two-year flood flow of the Stop River at the Winter Street  Bridge
was calculated as  158 cfs.  Since this flow is over 6,000 times the maximum
potential leachate flow, no adverse water quality impacts would be expected
under even the two-year flood flow conditions because any leachate reaching
the river would be sufficiently diluted.

3.4.2  Low Flow Conditions

Two estimates of the 7Q10 were evaluated.  The MWRA provided  information on
gaging stations on both the Stop  River and the Charles  River  (MWRA,  RMFP,
Screen I,  1988).  The first gage  is located on the Stop River,  two miles
upstream from  its  confluence with the Charles.   The 7Q10 estimate at  this gage
is  1.5 cfs (cubic  feet per second).  A second gage on  the Charles River,
12.6 miles downstream from the confluence of the Stop  River,  has been
recording stream flow since  1939.  Based on the  period  of record, the 7Q10 for
this location  is  14.2 cfs.  Drainage areas above these  two  gages are
12.8 square miles  and  184 square  miles,  respectively.   The  Massachusetts  DEP
(formerly DEQE)  investigated low  flow conditions in  the Stop  River  in order  to


                                      3-8

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 determine waste load allocations for their  1976 Water Quality Management Plan
 (DEQE,  1976).  Based on a shorter period of record, the 7Q10 estimated at the
 Charles  River gage was  11.6 cfs, slightly lower than the 11.2 cfs estimate
 provided by MWRA.

 A  typical assumption for purposes of analysis is that stream flow is
 proportional to drainage area.  Therefore, the 7Q10 at ungaged sites (such as
 the Winter Street Bridge) bears a ratio to the 7Q10 at gaged sites equal to
 the corresponding ratio of the drainage areas.  The Stop River upstream of the
 Winter Street Bridge has a drainage area of approximately 8.7 square miles.
 Using the most conservative 7Q10 value of 11.6 cfs in the analysis yields a
 7Q10 of  approximately 0.6 cfs at the Winter Street Bridge.

 Low flow water quality  impacts of a potential leak in the Walpole-MCI landfill
 were evaluated using the computer model of groundwater contaminant transport
 discussed in Section 3.3.2 (described in Appendix A).

 Leachate pollutant concentrations were determined by running the model for
 individual pollutants until the maximum concentrations were observed at the
 Stop River.  The time required to reach peak concentration varies and is
 influenced by the specific dispersion and retardation^characteristics of the
 individual contaminants.  The distribution of concentration across the
 contaminant plume was then utilized to determine the leachate pollutant mass
 loading  to the Stop River.

 Table 3.1-1 presents the predicted pollutant concentrations above background
 in the Stop River.  Long term effects due to fish consumption are not
 considered since the drought conditions used in the analysis are of limited
 duration.  Background concentrations of metals under low flow conditions are
 unknown  and thus cannot be used to predict the overall water quality in the
 Stop River.  However, as shown in the table, any projected or criteria
 exceedances under these drought conditions would be caused almost entirely by
 background pollutant concentrations, since the relative contribution of
 leachate concentrations is minimal.  Table 3.4-1 also indicates that the time
 required for these peak concentrations to be reached ranges from hundreds to
 thousands of years.

 While these predictions suggest that water quality impacts due to a leak in
 the landfill would be insignificant, it should also be noted that the impacts
 were predicted using extremely conservative assumptions.  For example, the
 leachate flow used in the analysis was 32,000 gallons per day for the entire
 landfill; a figure over twice the daily flow estimated by MWRA and one that
 corresponds to the infiltration of all rainfall occurring in an entire year.
 In addition, many of the highest leachate contaminant concentrations contained
 in the table were derived from data which included incineration ash which
would not be present in the Walpole landfill under MWRA's preferred plan.
Concentrations in sludge-only leachate would be lower.  In summary, potential
contamination of the Stop River in the event of an undetected, unremediated
landfill leak is not expected to be significant.
                                     3-9

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                       TABLE 3.1-1.   PREDICTED  CONCENTRATIONS  ABOVE BACKGROUND IN THE STOP RIVER
                                               UNDER LOU FLOW  CONDITIONS
Metal
Arsenic
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Highest
Leachate
Concen-
tration
87(a)
310(a)
420(a)
1300(b)
60(a)
46(a)
30(a)
Proposed Mass.
Fresh Surface
Water
Standard
50
1
11
1
0.012
-
0.12
EPA
Fresh Acute
Criteria
850
0.50
387
7.9
2.1
260
0.17
EPA
Fresh Chronic
Criteria
18(c)
0.27(d)
46
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 3.6 GENERAL PROPERTY VALUE  IMPACTS

 This section addresses  the possible effects on residential property values of
 a minor  residuals/emergency  sludge landfill at the Walpole-MCI site.  The
 following  text discusses what  is known generally about the effects of
 undesirable facilities  on property values, as reflected by sales prices of
 single family homes.  No literature was found which specifically addresses the
 effect on  residential property values of a grit and screenings/emergency
 sludge landfill.  However, assuming that such effects could perhaps be
 inferred from studies of other undesirable land uses, literature on the
 effects  on property values of sanitary landfills, power plants, airports and
 major highways was consulted and portions relevant to the residuals landfill
 are discussed below, and summarized in Table 3.6-1.

 3.6.1  Evaluation of the External Effects of Undesirable Facilities

 Many essential public facilities such as airports, landfills and power plants
 may generate external effects including noise, odors, pollution, traffic,
 potential  public health risks, visual intrusions and other factors of possible
 negative impact.  It is possible that any one these aspects can affect
 residential property values and be reflected in the sales prices or rents of
 such properties.  However, these environmental factors usually account for
 only a small proportion of housing price differentials.  The major
 determinants of the differences between the prices of different properties at
 a particular point in time are house quality and size, lot size and
 characteristics of the municipality (e.g., tax rate) and the quality of
 services (e.g., schools) (Abelson, 1979).  Major determinants of the
 difference in the price of a single property over time are demand, interest
 rates and  the regional economy.   Nevertheless, environmental factors do
 generally have some effect on residential property values and pertinent cases
 are discussed below.  It should be noted, however, that with the exception of
 airport and highway noise, most studies do not attempt to attribute the effect
 on  property values to specific external factors (e.g., noise, visual
 intrusion).  Rather they evaluate the overall effect of the undesirable
 facility on residential property values.  In doing so, there is an implicit
 assumption that no conclusive evidence can be found of direct relationships
 between specific external factors and property value.

 Specific external effects are discussed below first, followed by a discussion
 of  the general effects of undesirable facilities on residential property
 values.

 3.6.1.1  Noise Effects on Property Values.  Daytime background noise levels
 for many residential neighborhoods are in the 45 to 55 decibel (dBA) range,
 with a five dBA reduction at night, as measured on the "A" scale of a standard
decibel meter. It is generally agreed that for levels above 75 dBA a
 significant fraction of the exposed population will be "highly annoyed" by a
given noise level (Nelson, 1982).  Empirical studies of the effects of airport
noise on housing prices tend to support the theory that individuals are
willing to pay more for comparable housing located in relatively quieter
residential areas.   Nelson (1980) evaluated the results of 13 studies and
                                     3-11

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TABLE 3.6-1.   CHARACTERISTICS OF THE  PROPERTY VALUE STUDIES
Author (s)
Date
Abelson,
1979
Blomquist,
1978
Crether &
Mieszkowski
1980
Hwang &
Rudzitis,
1977
Maler, 1977
Mieskowski
& Saper, 1978
PIE
Foundation,
1981
Location
Australia
Winnetka, IL
New Haven, CT
Chicago metro
area
N/A
Toronto,
Ontar io
Pleasant
Plains, NJ
Andover, MN
Type of
Facility
or Effect
Airport and
highway
Electric
power plant
Non -residential
land uses
Solid waste
landfills
Environmental
quality
Airport
Hazardous
waste site
Conclusions
No significant effects of noise on property values
Within 11,500 feet of plant, decrease in value of
typical property by .9 percent for each 1,150 feet
closer to the plant
Trend indicates that public housing & Industry
adversely effect residential land values, but not
statistically significant
Trend indicates increase in land values as distance
from the landfill increases, for a distance of
approximately 1 ,980 feet from a landfill, but not
statistically significant
The study of property values cannot give viable
estimates of the willingness to pay for environmental
quality
Significant reduction in housing values as a result
of being located in areas affected by airport noise
The study fails to show that the property values
approach is useful for estimating the damages from
hazardous waste disposal.

-------
TABLE 3.6-1 (Continued).  CHARACTERISTICS OF THE STUDIES
Author (s)
Date
Price, 1988
Nelson,
1977
Nelson,
1980
Nelson,
1982
Schamalen-
see, 1974
Webb, 1980
Location
Florida,
Westchester
Co. , NY &
Manitoba, BC
Washington,
DC
Various
N/A - survey
Los Angeles,
CA
3 Mile Is.
area, PA
Type of
Facility
or Effect
Landfills
Air quality
Airport
Highway
Landfills
TMI nuclear
power plant
Conclusions
Florida: residences within 1-1/2 miles experienced
1-3} less annual appreciation than comparable area.
NY: 8.1% less annual appreciation.
Canada: study inconclusive because prices were not
estimated before construction started.
People are willing to pay for better air quality
Airport noise raises the ambient noise level by
approximately 20 decibels and affects property
values at approximately .4 to 1.1} per decibel
Noise affects property values in range of .16-. 63%
per decibel, averaging .4} per decibel
No significant effect on property value.
Owners estimated significant (16}) loss in property
value after THl incident where plant visible

-------
found that taking into account  the  number  of flights,  the  time  of day  and the
perceived loudness of the noise,  airport noise  significantly  affects property
values.  The average rate of the  effect on property  values is approximately .4
percent to 1.1 percent per decibel  when the change occurs  from  the 45  to 55
decibel range (for quiet areas) to  the 65  to 75 decibel  range (for impacted
areas).  In the case of airports, noisy and quiet properties  will differ by at
least 20 decibels (Nelson, 1980).

Highway noise also significantly  effects  land values.  Nelson (1982) surveyed
the results of nine studies of actual housing prices and found  that the
effects of highway noise on land  values in fourteen  different housing  markets
are fairly consistent.  It was found that  highway noise  affects property
values in the range of  approximately .16  to .63 percent per  decibel when the
change occurs from the 45 to 55 decibel range (for quiet areas) to the 65 to
75 decibels range (for impacted areas), with an average  of .4 percent  per dBA
(Nelson, 1982).

Although the reasons are not clear, the  type of noise  appears to significantly
affect the level of the impact on residential property values.   Highway noise
is shown to have a lesser impact  on property values  (.16 to .63 percent per
decibel) than airport noise (.4 to 1.1 percent per decibel).   The reason for
this may either be implicit in the difference in the type of noise (relatively
continuous for highways, intermittent or  various for airports)  or may be
related to other external effects of each facility (e.g. odors, aesthetics).
In either case, because the level of noise generally decreases with distance
from its source, it can be concluded that the market impact of the noise
decreases with distance from the  source.

3.6.1.2  Other External Effects on Property Values.   With few exceptions,  the
remaining studies do not specify  which particular external factors (i.e.,
noise, odor, etc.) contribute to the property value effects of undesirable
facilities, although some property value effects are generally found.   In  one
case,  involving a Washington, D.C. study, it was found that people were
willing to pay more for housing where they perceived better air quality
(Nelson, 1977).  In all of the other studies consulted, however, no such
distinction is made.  An example of such a study is one in New Haven,
Connecticut in which the effects of non-residential land uses on single family
housing prices is addressed. Commercial,  high density residential and
industrial uses were evaluated for their  impacts on residential land values.
A trend was found  in which industrial uses and public housing had some  impact
on land values, but the effects were not  found to be large enough to be
significant (Grether and Mieszkowski, 1980).   In another study using the
owners' estimates of sales prices of single family homes,  it was  found  that  a
steam-electric power plant had the effect within  11,500 feet (2.2 miles),  of
decreasing the value of a typical property by  .9 percent for each  1,500 feet
closer to the plant (Blomquist,  1978).

In the most recent study  of sanitary landfills,  facilities in  Florida and  in
Westchester County, New York were found,  in comparison  to  control areas
(similar areas without any undesirable land uses),  to have distinctly negative
impacts on land values.  In Florida, homes within one and a half miles of a
landfill experienced an annual value  increase  of one  to three  percent less


                                      3-14

-------
annually than,homes in the control area, with the greatest decrease in
appreciation experienced by higher priced homes.  In New York, the cost of
housing increased 33.8 percent annually in the control community, compared to
25.1 percent in the community with the landfill, a difference of 8.7 percent
(Price, 1988).  The author did, however, qualify this difference by explaining
that other market factors favored the control community over time (e.g.
revitalizing the downtown, lower utility costs).  Another analysis of four
sanitary landfills in Los Angeles prepared for the EPA in 1971 concludes that
there were no effects on residential land values that could be attributed
directly to the disposal sites (Schmalensee, 1974).  It should be pointed out
that 15 years ago people were less likely to perceive the external effects
than they are today.  At that time, in fact, it was believed that "sanitary
landfills do not produce ground and surface water pollution" (Hwang and
Rudzitis, 1977).  The same authors found no significant effects on property
values resulting from landfills in the Chicago metropolitan area.

In a study of the area around a nuclear power plant shortly after the Three
Mile Island incident, 57 percent all of the people living within sight of the
plant (two miles) estimated a substantial loss in the value of their property
with an average estimated loss of 16 percent.  Where the plant was not visible
(over two miles away), the percentage of residents .perceiving a loss in
property value dropped from 57 percent to 20 percent, and further declined
over distance to no loss at five miles (Webb, 1980).  Although Webb concludes
that a view of the plant may effect property values, it can also be concluded
that residents with a-view of the plant were more likely to perceive a loss in
property value.  In addition, the results of this study are limited due to the
small sample size and in part because they reflect the subjectivity of
individual perceptions.

3.6.2  Limitations of the Analyses

Correlating property value effects with the characteristics of an undesireable
facility is an inexact "science" in which findings of no effect occur with
significant frequency.  It should also be noted that with the exception of the
literature on airport and highway noise, the studies surveyed do not attempt
to attribute the effect on property values to a specific external effect
(e.g.,  noise, visual intrusion), but rather attribute the effect on property
values to the undesirable facility in general.  Although it is generally known
what the external effects of the residuals landfill could be, limits on the
precision of the reported studies restricts the ability to make inferences
from these studies on the property value effects of the proposed residuals
landfill.  Caution must also be applied in making broad assumptions in regard
to the similarity of the effects of various facilities.  For example, it
should not be assumed that the operations mode,  external effects or property
value effects of the residuals landfill are the same as those of a sanitary
landfill.  In addition,  it is assumed in the majority of these analyses that
individuals all possess sufficient mobility and resources to relocate, and
that the negative factor influencing price can be statistically quantified and
identified separately from all other factors.
                                     3-15

-------
Furthermore, the literature surveyed indicates that in order for external
effects to influence property values, the nature of the disadvantages must be
appreciably perceived by the participants in the housing market.  Finally, two
authors expressed doubt that the property value approach is valid.  One study
evaluating the impacts of a hazardous waste site concluded that the study
fails to show that the property values approach is useful for estimating the
value of external effects from hazardous waste disposal (PIE Foundation,
1981).  In a second analysis of the approach, Maler (1977) also found that the
study of property values cannot give viable estimates of the willingness to
pay for environmental quality.  Despite these limitations, some general
relationships between external environmental effects and property values have
been identified which can be applied to the residuals landfill.

3.6.3  Application of the Analyses to the Proposed Walpole Residual Landfill

Assuming that 1) the property value approach is a viable method for estimating
effects of external factors on property values; and 2) some of, or parts of,
the studies discussed above are relevant to the residuals site, then some
inferences can be drawn regarding the potential effects of the proposed minor
residuals landfill.  These studies show that there can be a range of effects
on property values resulting from proximity to negatively perceived land
uses.  The literature also indicates that, generally, offsite noise above
75 decibels can have a definite negative effect on property values, while
visual intrusion probably has some effect.  However, it should be noted that a
particular land uses potential effect on surrounding property values depends
on a composite of factors such as prevailing winds, degree of natural
buffering, the nature and extent of the activity, vehicular access patterns
and distance to residential land uses.

The following inferences can be drawn regarding the environmental effects on
residential property values of the proposed minor residuals landfill:

     •    There appears to be a quantifiable relationship between noise level
          and property value, where the point source noise level is above
          75 dBA.  At the Walpole site this could apply to three properties
          only during active construction and closure of the three closest
          landfill cells.

          Visibility of the facility (both physical visibility and
          social/political visibility)  can adversely affect property values.
          The residuals landfill could be visible from a limited number of
          residences on Winter and Main Streets during the winter, when there
          is no foliage.   However, these impacts can be identified but not
          quantified.

     •    There is no conclusive evidence that relatively more intensive
          activity at an undesirable facility can significantly alter
          residential property values in the immediate vicinity. However, it
          is likely that the greatest effects on property values would result
          from more intensive short-terra activities such as construction or
          emergency landfilling of sludge cake than from normal operations.
                                     3-16

-------
     •    Under normal operating conditions,  the  residuals  landfill  should not
          generate as significant property  value  impacts  as those described in
          the literature for sanitary landfills because for the residuals
          landfill: 1) the quantity of material to be deposited and  therefore
          the extent of other activities (trucking, bulldozing) is minimal
          compared to the average sanitary  landfill; 2) the quality  of the
          material is more controllable and is not hazardous;  and 3) the site
          will not attract the scavenger birds (gulls), which  makes  a sanitary
          landfill so visible from a distance.

     •    Measurable impacts, such as groundwater contamination, can have
          significant impacts on property values.  Such impacts are  not
          expected at the Walpole residuals site.  However, should they
          occur, the literature indicates that the negative effects  on
          property values are lessened once the  impact is mitigated. MWRA is
          committed to mitigating such impacts immediately, should they occur.

3.7  CONSTRUCTION IMPACTS

Since the release of the DSEIS, additional  project information presented for
MWRA's recommended plan has allowed an expansion  of .the more general
construction impact analysis presented in the DSEIS.  The new information
presented below supplements the Draft SEIS's analysis of  construction impacts.

Landfill and residuals processing facilities construction could cause short-
term environmental and socioeconomic impacts.  For the most part, however,
these impacts should be insignificant or can be mitigated to insignificance.

3.7.1  Ualpole-MCI

Air quality construction impacts would be f'  erated from  excavation equipment
disrupting the soil and dust. Potential fugitive  dust impacts would be
controlled using standard dust control techniques such as water spray, hay or
mulch, chemical dust suppressants, or vegetated  covers, depending on the bare
soil exposure time.  In addition, the site  buffer distance to residential
areas and wildlife habitat, and the construction.occurring in a depressed area
should significantly diminish the occurrence of offsite dust impacts.

The construction impacts associated with trucks  will occur during the
construction of each phase (cell) of the landfill.  New phases are expected to
be constructed every five years for a 12 month period, during which both
construction and operation activities would be simultaneous.  Construction
materials would be delivered six days a week.  The actual timing of landfill
phase construction will depend on how quickly the capacity of prior phases is
used up.

Since only approximately fifty percent of liner and capping material would be
available onsite, the additional material would be imported  six months prior
to construction.  Any boulders excavated during the landfill phase preparation
should be used to create berms to minimize the visual and noise effects of the
landfill operation, rather than removed from the site.  This would reduce the
number of trucks by approximately 15 percent during the site preparation


                                     3-17

-------
phase, from nine to eight trucks under normal operations (from 49 to 41 in the
worst case).  During worst case trucking operations, significant impacts along
the main access route would be anticipated.  To minimize this impact an
alternate access route would be utilized to reduce the truck volume and
consequently, the impact along the first access route, as described in
section 4.2.4.2 of the Draft SEIS.

3.7.2  Quincy FRSA

Construction at the FRSA will involve building demolition and soil excavation,
as well as construction of a new building, sludge storage tanks, pellet
storage silos and heat drying facilities for short term residuals management
(MWRA, RMFP, FEIR, 1, 1989).

Prior to the commencement of soil excavation and construction, meteorological
monitoring stations and dust monitoring instruments would be established.
These monitoring locations would be selected to encompass the entire
construction area and would be based on prevailing wind direction and
potential public exposure to contaminants in the soil.  Background dust and
VOC air quality data would be obtained during a normal construction day before
soil excavation and-construction activities commenced.  If particulate matter
or VOC in the air at the monitoring stations exceed the background levels, the
source of the exceedances would be determined immediately.  If the source is
excavation-related, the activity resulting in the exceedances would be
terminated and the area secured to reduce the VOC and/or the particulate
matter measurements to background levels. Recommended dust control measures
include revising the work pattern, reducing the excavation area, water spray,
wetting agents such as calcium chloride, hay or mulch, or other appropriate
dust suppressants (Haley & Aldrich, Procedures, 1989).

Construction noise could be extremely difficult to suppress because it would
not be a stationary activity, but would vary due to mobile sources and various
construction activities.  However, construction noise will be temporary in
nature.  Mitigation measures to minimize construction noise include not
scheduling construction activities at night or on weekends and ensuring that
the construction-equipment is maintained in good working condition and fitted
with sound control devices (such as diesel engine mufflers).

The FRSA area has a history of high ambient noise levels during the daytime,
including construction noise.  Currently, residences are exposed to noise
related to residential construction activities near the site.  Existing noise
levels at the nearest residence are within the range of anticipated
construction noise levels.  Therefore, noise impacts from the facility
construction should not have an adverse impact upon the surrounding
neighborhood and other sensitive receptors.

Existing groundwater contamination would be expected to be influenced by a
pumping well associated with construction dewatering.  Groundwater would be
treated, as necessary, before discharge into the Fore River, so any adverse
impacts would be mitigated.  Excavated contaminated soils would be handled and
disposed of in accordance with DEP guidelines (Haley & Aldrich,
Procedures, 1989).


                                     3-18

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The MWRA proposed construction plan would minimize excavation, thereby
reducing the amount of construction dewatering required, which would in turn
limit migration of contaminants.  Hay bales and silt fences would control
erosion and sediment accumulation in the existing drainage structures during
the demolition phase.  A new drainage system would be installed at the outset
of construction and would include a siltation basin to filter sediment prior
to discharge.

Potential construction impacts upon earth resources could result from site
preparation activities such as building demolition and soil excavation.  The
primary concern is the disturbance of hazardous substances and their migration
to the water. To reduce the amount of soil to be excavated during
construction, the foundations for all new facilities will be built on piles.
Subsurface activities will be avoided in areas delineated as contaminated.  As
discussed previously, migration of contaminants will be controlled by
utilizing hay bales, sandbags and silt fences.  Once construction activities
ceased, new structures and pavement will cap the underlying surface (MWRA,
RMFP, DEIR, 1, 1989).

3.7.3  Deer Island

The construction of the residuals facilities would occur at the southern
portion of the island.  The distance between the residuals construction
activities and residences in the City of Winthrop should reduce the adverse
impact associated with construction noise.  Therefore, construction of the
residuals facilities would not increase ambient noise levels above those
anticipated to be generated by the secondary wastewater treatment plant
activities.
                                     3-19

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                                 CHAPTER FOUR
                                   COMMENTS
4.1 COMMENTS RECEIVED
As part of the EIS process, comments on the Draft SEIS were received by EPA
during the sixty day comment period following the issuance of the Draft
document.  In order to facilitate public comment, EPA held three public
hearings (In Quincy on June 22, 1989, in Cambridge on June 27, 1989, and in
Walpole on June 29, 1989) at which oral comments were received.  In addition,
the document was distributed to the previously established Citizens Advisory
Committee, thirteen public libraries or other repositories in the metropolitan
Boston area, and over fifty other parties, including state and federal
agencies, local governments, scientists and interested individuals.  Over
5,000 parties on EPA's mailing list were notified of the availability of the
document.

Written and oral comments were received from elected officials, government
agencies and private individuals and organizations through letters and at the
public hearings.  Every comment has been reviewed by EPA and the following is
a discussion of the approach taken by EPA to addressing the comments.

4.2 APPROACH TO ADDRESSING COMMENTS

In order to be responsive to commentors and address comments in an efficient
manner, EPA has conducted a review of all comments received and developed a
complete list of issues raised.  From this list, a matrix of issue categories,
individual commentors and their affiliations was developed (Table 4-1).
Categorizing issues and responses in this manner allows all aspects of an
issue to be discussed comprehensively and allows for clear presentation of the
particular issues of concern.  Each issue has been addressed in a separate
section of Chapter 5.  The issues are presented in the matrix in alphabetical
order for ease of use by the reader with the section number for the issues
response noted.

Some comments received by EPA were either very general, expressed the writers'
opinion without addressing a particular-issue, or were specific to the MWRA's
Draft EIR.  These comments are considered "general comments" in Table 4-1 and
were considered by EPA but did not require a direct response.  Copies of all
original comment letters can be found in Appendix C of this Final SEIS.
Transcripts of the public hearings are available from U.S. EPA Region I.

Comment letters were given identification numbers, as listed in Table 4-1
(gaps in the numbering system do not denote missing letters, or any particular
order).  These numbers are also shown on each letter as reproduced in
Appendix C.  As noted in Table 4-1, Comment Letter Number 20 represents a
letter to EPA published in a local newspaper, regarding EPA's acceptance of
incineration at Deer Island.  Residents of Winthrop cut the letter out of the
newspaper, signed it, and sent it to EPA as a comment on the Draft SEIS.  The
names of other people who sent this letter are listed in Table 4-2.  Comment
Letter Number 74 is one of approximately 100 letters with nearly identical
content also about incineration at Deer Island; the names of the senders of
similar letters are also listed in Table 4-2.
                                     4-1

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TABLE 4-1.  COMMENTS RECEIVED OH THE DRAFT SEIS

LETTER
ID #
1
2
3
4
S
6
7
B
9
10
11
12
13
14
15
16
17
18

NAME AFFILIATION OR RESIDENCE
JAMES M. BRADY, ATTY. BRADY & HONAC, P.C.
CAROL S. MINKUITZ WALPOLE
LAURENCE HAGNER NORFOLK BOARD OF HEALTH
CONGRESSMAN BARNEY FRANK U.S. HOUSE OF REPRESENTATIVES
LARRY BASSIGNANI NORFOLK
JIM GIEBFRIED NORFOLK
GARY MOLINO NORFOLK
JACK OLIVIERE NORFOLK
KURT CZARNOWSKI NORFOLK
ROBERT GRANT NORFOLK
JANE M. DEUEY NORFOLK
JOHN C. HAHN UALPOLE
SALLY DEUEY NORFOLK
CLEMENTINE GNERRE REVERE
LARRY BASSIGNANI NORFOLK
LARRY BASSIGNANI NORFOLK
BARBARA McCONVILLE OUINCY
LARRY BASSIGNANI NORFOLK
ISSUE AMD ISSUE NUMBER
1
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X


X













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X
X

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X


X
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X
X
X
X
X
X

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X
X
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X
X













Public Health
in

X


X
X







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Sludge Character
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X
X

X
X

X
X


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X










X






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* General c eminent s do not address any technical issues or information.

-------
TABLE 6-1 (Continued).  COMMENTS RECEIVED ON THE DRAFT SEIS

LETTER
ID #
19
20
22
26
27
33
34
35
36
37
38
39
40
41
42
43
44
45
NAME AFFILIATION OR RESIDENCE
STEVEN BLIVEN MASS. COASTAL ZONE MANAGEMENT
G. TACELLI UINTHROP (1)
JOHN RAFFERTY UALPOLE
ROBERT A. DeLEO ROBERT A. DeLEO, ATTY.- REVERE
LARRY BASSIGNANI NORFOLK
WILLIAM SANJOUR EPA • WASHINGTON, D.C.
HUGH B. KAUFMAN EPA • WASHINGTON, D.C.
SHEILA LYNCH BENTTINEN, CHAIR FRIENDS OF BOSTON HARBOR ISLANDS
JOANNE DANISH. CHAIR UALPOLE BOARD OF SELECTMEN
JOSEPH GERMANO UALPOLE BOARD OF SELECTMEN
WILLIAM HAMILTON UALPOLE BOARD OF SELECTMEN
LAURENCE MANGER NORFOLK
DOROTHY RE 1 CHARD FOR CONGRESSMAN BARNEY FRANK
JOHN GIORGIO UALPOLE TECHNICAL ADVISORS
JOANNE MUTI, CHAIR UALPOLE CAC SPEAKING PRIVATELY
CAROL MINKUITZ UALPOLE CAC SPEAKING PRIVATELY
LARRY BASSIGNANI NORFOLK
JAMES GIEBFRIED NORFOLK CAC
ISSUE AND ISSUE NUMBER
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4-^2
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-------
TABLE 4-1 (Continued).  COMMENTS RECEIVED ON THE DRAFT SEIS


LETTER
ID «
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62


NAME AFFILIATION OR RESIDENCE
GARY NOLI NO
FRANK CINTOLO WALPOLE CAC
EHILE DE MENTO WITHROP CAC
DAVID GRABER, ENGINEER WINTHROP CONSULTANT
JOHN HAHN WALPOLE
JACK OLIVERI NOFOLK CAC
KURT CZARNOUSKI NORFOLK
BOB GRANT NORFOLK
JOE FINNERAN NEPONSET INDIAN RES. CONSERVANCY
JANE DEWEY NORFOLK
SALY DEWEY NORFOLK
JIN HARRIS HOT PROVIDED
JANES BRADY WALPOLE
NR MCCORHACK WALPOLE TOWN MEETING MEMBER
ED RYAN WALPOLE
HASSAN YEAGER WALPOLE
JOE DELOIS WALPOLE

Air Quality ft Odors
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-------
TABLE 4-1 (Continued).  COMMENTS RECEIVED ON THE DRAFT SE1S

LETTER
ID #
63
64
65
66
67
68
69
70
71
72
74
122
123
124
125
126
127
128
NAME AFFILIATION OR RESIDENCE
MR HAMILTON UALPOLE BOARD OF SELECTMEN
REP. ALFRED E. SAGGASE MASS. HOUSE - 20TH SUFFOLK DISTRICT
HANK MAIORANA UALPOLE
SHEILA LYNCH BENTTINEN, CHAIR FRIENDS OF BOSTON HARBOR ISLANDS
DR SAM MALOOF
JIM MACRITCHIE QUINCY CITY SOLICITOR / NURA REP.
PETER MOR1N FOR MASS. SENATOR PAUL HAROLD
SHAWN DONOVAN NORMANDAU ENGINEER. (REVERE CONSUL.)
TOM TIMCOE HOUGHS NECK COMMUNITY COUNCIL
HANK MAIORANA NEEDHAM
JACKIE HURLEY WINTHROP (2)
DR. SAMUEL MALOOF, PH.D. NOT PROVIDED
DENISE SALEMI, PRES. REVERE CITIZENS AGAINST SLUDGE
DAVID STAMOLEY, P.E. CONSULTANT - QUINCY
JIM H I GHTOWER, COMMISSIONER DEPT. OF AGRICULTURE, AUSTIN, TX
WILLIAM F. LAWLESS, CHIEF REG. BRANCH, NE CORPS OF ENGINEERS
SHEILA LYNCH BENTTINEN, CHAIR FRIENDS OF BOSTON HARBOR ISLANDS
PHVLISS MCLEAN UALPOLE
ISSUE AND ISSUE NUMBER
5.4 Air Quality & Odors



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X

X

X
X


X

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-------
TABLE 4-1 (Continued).  COMMENTS RECEIVED ON THE DRAFT SEIS
LETTER
ID #
129
152
153
154
155
156
159
160
161
179
180
181
182
183
NAME
MIRIAM NOOAN
SHAWN DONOVAN
HARLAN M. DOLINER, ATTY.
GREGORY P. BIALECKI, ATTY.
S. DAVID GRABER, P.E.
CORNELIUS O'LEARY
JEROME E. FALBO
BETSY JOHNSON
CHRISTOPHER H. LITTLE, ATTY.
HARLAN M. DOLINER, ATTY.
LARRY BASSIGNANI
ADELE JOHANNA TORO
LARRY BASSIGNANI
LARRY BASSIGNANI
AFFILIATION OR RESIDENCE
OUINCY
NORNANDAU ENGINEER. (REVERE CONSUL.)
MCGREGOR, SHEA & DOLINER
HILL & BARLOW (WALPOLE COUNSEL)
CONSULTING ENGINEER (UINTHROP)
ACTING DIRECTOR, EOEA
CHAIR, WINTHROP NOISE/AIR COMMITTEE
FPCAC CHAIRPERSON
TILLINGHAST COLLINS & GRAHAM
MCGREGOR, SHEA & DOLINER
NORFOLK
FRANKLIN PARK IMPROV. CONN., REVERE
NORFOLK
NORFOLK

> Air Quality & Odors
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-------
               TABLE 4-2.  HINTHROP RESIDENTS SUBMITTING LETTERS SIMILAR
                            TO COMMENT LETTERS 120 AND 174
   Name
     Name
      Name
Herbert &  Isabella  Guttell
George & Patricia Dick
Dick Mosher
mr. & Mrs. T. Tomasanis
John Biggio
Mrs. Bruno
Carol M. Douglas
David M. Wescott
James & Elizabeth Collins
Helene Beddeos
Joseph Indrisano
Alan A. Brown
Rosemarie Facale
Edward J. Bandoni
Barbara A. Bandoni
Agnes Briggs
Marian Cashman
Colin & Jeanne Cash
Leslie A. Fay
Arline Festa
Mr. & Mrs. John Boudrou
James G. Wallace
Leo Rabinovitz
Arthur & Barbara Cummings
Janet Shore
Herbert & Isabelle Guttell
John Fife, Jr.
Roger Hathaway
Charles Forster
Joan Grimes
Carole Bahine
Ella R. Cochrane
Mr. & Mrs. T. Stern
Brian Crombie
Matteo Caradonna
Gail Struzziero
Yvonne Wstcott
Nancy Ctombie
Jane Starbuck
Chris Driscoll
Anthony Mararkowski
Pat Sullivan
Barbara & Roger Sinois
Paula Dolan-Pare
Robert Balach
Capezza Family
 Jim  & El-len  Lyone
 George Blaisdell
 Lynn M. Guibano
 Natalie R. Furlong
 Deborah S. Federico
 Anne Broder
 Mr.  & Mrs. Handler
 William & Florence Moore
 Lillian G. Broder
 Kennedy Family
 Iris C. Freeman
 Fred & Mary  Wood
 Paul Silvey
 Marie Skomro
 Carven Family
 Cathrine C.  Giromini
 Carolyn Fisichella
 Mary Kelly
 Emile Dimento
 Donald A. Regan
 Patricia Sullivan
 Joy  Machcinski
 G &  M Jackraan
 Robert J. Brooke
 Lisa A. Alberghini
 Virginia Aliberti
 Mary P. Stefano
 William & Joan Murray
 John Johnson
 Mr.  & Mrs. Edward Hines
 Edward W. Belliveau
 James Cullinane
 Joseph Falk
 John Goli
 William McNeil
 Karen M. Leslie
 Harvey Barbe
 Rita Casey
 Carol Dolan
 Robert Adams
Norman M. Lovly
 Doloras A. Hickey
 Anne M. Aliner
Dorothy J. May
Bruce & Eileen Johnson
Mr. & Mrs. J. Cumindle
Lorraine Reczek
Mr. & Mrs. F. Long
Pam Irvin
Mr. & Mrs. P. Scola
J. Poscend
G. Tacelli
George D. Dick
Rhoda Zagorsky
George D. Dick, Jr.
Patricia A. Dick
Joanne Bomarsi
Edward F. Bomarsi
Jamis Polino
Douglas Simonton Family
S. & N. DeModena
                                            U-7

-------
                                 CHAPTER FIVE

                             RESPONSE TO COMMENTS

The following is a presentation of the comments received on the Draft SEIS and
EPA's responses.  As discussed in Chapter 1, the comments are grouped into
categories or issues.  General comments on each issue are discussed first,
with specific comments or questions and responses following the general
discussion.  As will become evident, many of the issues overlap, and where
this occurs, the reader is referred to other appropriate discussions in this
section.  In some cases, the issue has already been covered elsewhere in this
Final SEIS, particularly in Chapters 2 or 3; in such cases the reader is
referred to the appropriate section of this Final SEIS.  Also, all section
numbers referred to in the response correspond to sections of the Draft SEIS
unless otherwise noted.

5.1  GROUNDWATER AND SURFACE WATER

5.1.1  Walpole

Many commentors expressed general concern that the proposed Walpole MCI
residuals landfill would pose risks to surface water and groundwater resources
and requested that EPA ensure that additional study and modelling be performed
in order to thoroughly assess the potential impacts of a landfill leak.

An evaluation of potential water quality impacts on surface water and
groundwater resources at the Walpole-MCI site was presented in Section 5.5.2
of the Draft SEIS.  The Draft SEIS studies focused on the Stop River and the
prison water supply wells to the west of the Stop River.  In general, the
studies concluded that a landfill failure would not cause water quality to be
significantly altered from existing conditions.  The Draft SEIS concluded that
it is highly unlikely that both landfill liners and leachate collection
systems would fail, allowing migration of contaminants.  Moreover, there would
be substantial time to remediate any leaks or contamination.

In order to more thoroughly assess the potential for-contamination of water
resources,  however, EPA has continued its independent review and analysis.
EPA has prepared additional surface water and groundwater analyses (including
computer modelling of contaminant migration) as part of an expanded technical
evaluation of the MWRA-preferred plan.  The additional studies were conducted
to investigate potential water quality impacts on the Stop River under low
flow conditions and to evaluate potential risks to private water supply
wells.  Details of the methods, assumptions and results of these analyses are
presented in Sections 3-3, 3.1 and Appendix A of this Final SEIS.  These
additional analyses reconfirm EPA's original finding that pollutants entering
groundwater from a landfill leak would not result in concentrations in the
Stop River or at the private wells that exceed applicable drinking water
quality standards, even under the worst-case scenario of a 50% leak occurring
undetected for 10 years.

The delineation of the Zone II and Sole Source Aquifer boundaries has also
received careful consideration.  Additional analyses conducted by MWRA have
                                     5-1

-------
demonstrated that the landfill does not lie within the Zone II  area of the
prison wells and that only a small portion of the landfill footprint is
located within Zone III.   The MWRA has also conducted additional field
reconnaissance and evaluation of .topography, groundwater elevations, bedrock
outcroppings and overall  site drainage and has confirmed the previous findings
that groundwater from the site drains away from the Neponset Sole Source
Aquifer and into the Charles River Basin. Based on a detailed examination of
the procedures and assumptions of MWRA's investigations and a thorough review
of additional sources of  information as outlined in the Draft SEIS
(Section 4.4.3.2), EPA supports the conclusion that the landfill footprint
lies outside of the Zone  II and Neponset Sole Source Aquifer boundaries.

EPA has outlined below a  summary of the methods and assumptions employed in
the prediction of potential water quality impacts.  As noted previously an
expanded technical evaluation of both groundwater and surface water resources
has been prepared for this Final SEIS and is included in Sections 3-3 and
3.4.  The assumptions and methodology employed in the assessment of water
quality impacts are discussed in those section and in Appendix A. The reader
is also referred to the Draft SEIS sections described below for a further
explanation of the information used in the water quality investigations.
Following is a summary and response to the main issues raised by commentors on
the Draft SEIS.

Some commentors asked why the leachate flow calculations did not include the
possibility of peak operating flows or rainfall events. As discussed  in the
Draft SEIS Section 5.5.2.2, average operating flows and average annual
rainfall were used since  the groundwater travel time from the footprint to the
prison wells was estimated as 30 years.  Subsequent analyses have predicted
that contaminant travel times from the footprint to the water supply  wells
would generally be on the order of hundreds to thousands of years.  The
effects of peak flow conditions would thus be moderated over a long period of
time and would not be reflected in groundwater pollutant concentrations.

Flow rates for the receiving ground waters and surface waters were  calculated
individually and the methods and assumptions are outlined in the Draft SEIS in
Section 5.5.  In response to comments regarding the calculations for  the Stop
River, a revised flowrate was developed  for the analysis of the potential
impacts which could be expected under drought conditions.  A discussion of the
revised flow rate calculation is presented as part of the expanded  technical
evaluations included in Section 3-4 of this Final SEIS.

As described in Section 5.5.2.2 of the Draft SEIS, maximum leachate
concentrations measured from MWRA digested primary sludge and from  digested
primary sludge and combustion ash were used to predict water quality  impacts
of a breach in the MCI-Walpole landfill.  Under the preferred MWRA  plan
incineration has been eliminated as a residuals management technology;
however, the potential impacts of landfilling combustion ash were  included  in
the water quality analyses.  Although the proposed landfill will potentially
contain digested combined primary and secondary sludge, data for leachate
analyses on the combined sludge is unavailable because secondary treatment at
the Deer Island wastewater treatment plant  is not yet on-line.  While it  is
true that secondary treatment will probably result in higher removal  rates and


                                      5-2

-------
thus higher concentrations of leachate pollutants, it should be noted that
over half of the maximum leachate concentrations used in the water quality
analyses were derived from the data which includes the combustion ash.  As
discussed in the Draft SEIS, ash resulting from the incineration of digested
sludge would be expected to have the highest metals concentrations due to the
destruction of much of the sludge product which serves to "dilute" the
remaining metals.  Thus, the leachate pollutant analyses do provide a
conservative estimate of metals concentrations.

As noted in the Draft SEIS, metals are of particular concern since they
generally remain in the sludge or sludge product after digestion and heat
drying. However, some commentors were concerned that the leachate pollutant
calculations did not include concentrations of other contaminants such as
pathogens or volatile organic compounds.  These constituents were not included
because they are expected to be destroyed by the sludge processing and thus
are less likely to be present in the leac'hate.  In fact, the leachate
concentrations for these pollutants reported in the Draft SEIS Section 3.1
were below detection limits.  In addition, contamination concentrations from
grit and screenings would be less than concentrations from sludge or sludge
products.

The method used to calculate background ambient water pollutant concentrations
varied depending on the information available.  As noted in Section 4.4 of the
Draft SEIS, the MWRA conducted several rounds of water quality sampling at the
various sites during different periods of 1988.  In some instances there were
difficulties in the sampling or testing and the results of portions of the
sampling programs were described as qualitative.  The sample numbers and
locations of these qualitative results are presented in the text of the Draft
SEIS.  In other cases information was unavailable and thus conservative
assumptions were required.  However, the results of all samples taken are
summarized in the Draft SEIS, Appendix D. In each case the specific
methodology and assumptions used were stated in Section 5.5 of the Draft SEIS
under the individual water quality analyses for each site.  For example, in
the assessment of water quality impacts for the Rowe Quarry site it is stated
that there was no data available for background pollutant concentrations in
Rumney Marshes and so the background concentrations 'measured in the
groundwater were conservatively used instead.  The notes below each table in
Section 5.5 summarizing the results for each site also specify the data source
or assumptions used in the analysis. In instances where background
concentrations are not accompanied by a footnote an average of the non-
qualitative data presented in Appendix D was used.

The calculation of potential water quality impacts presented in the Draft SEIS
was conservative in a number of respects.  First, the procedure did not
account for dispersion, dilution or retardation of contaminants in the
aquifer.  In addition, although some of the metals used in the water quality
analysis were not detected in ground or surface water during the MWRA sampling
program, concentrations were assumed to be at one-half of the detection
limits.  This type of analysis is generally conservative because it assumes
that pollutants already exist on-site.  However, the approach still allows for
a comparison of the relative contribution of leachate pollutants to any water
quality violations which may result.


                                      5-3

-------
The expanded technical assessments presented in this Final SEIS have shown
that even under worst-case leak and drought assumptions no water quality
criteria exceedences are predicted for the Stop River.   Thus,  none of the uses
presently approved for downstream•reaches of the Stop River would be
affected.  The Stop River is not used as a source of water supply in
downstream reaches and therefore drinking water standards were not included in
the surface water analysis.

Some commentors correctly noted that an error was made in the  calculation of
Stop River concentrations under the 50 percent leakage scenario.  The error
was presented in the Draft SEIS in Table 5.5-2 and resulted in an
overprediction of the contaminant concentrations.  The revised values for the
50 percent leakage scenario is contained in Section 7 of this  Final SEIS.

5.1.2  Mitigation and Contingency

Several commentors expressed concern that the Draft SEIS section on residuals
landfilling did not adequately discuss mitigation and contingency plans.

Mitigation and contingency plans are briefly outlined in Section 5.5.2.3 of
the Draft SEIS and'a'more complete discussion of the features  of landfill
design and operation is presented in Section 6.4.2 of this Final SEIS.  The
double liner, double leachate collection system will minimize  risk of
contamination by protecting against and providing an early warning of a
landfill leak.  A rigorous monitoring program will be established as an added
precaution in order to closely monitor surface and groundwater  resources
surrounding the site.  It is extremely unlikely that both liners will fail and
that contaminants will migrate undetected past the leachate collection and
environmental monitoring systems.  However, should contamination of private
water supplies occur, the MWRA has committed to providing alternative sources
of water (MWRA, RMFP, FEIR, 2, 1989).

5.1.3  Tine of Travel

Comnentors asked for a more thorough discussion of the method used to develop
the tine of'travel estimate. • In particular, commentors questioned the value
of hydraulic conductivity used and asked for a discussion of the influence of
pumping on groundwater travel tines.

A complete discussion of the groundwater time of travel is included in
Appendix A of this Final SEIS (Section A.6).  The estimated time required for
groundwater to travel from the landfill footprint to both public and private
wells has been thoroughly  investigated and evaluated using a variety of
conservative assumptions and calculation procedures.  The results of the
investigations indicate that groundwater velocity within the Zone II region of
the prison wells is not significantly influenced by pumping since the slope of
the groundwater table varies by only ten percent under pumping  conditions.
The estimated travel time of 30-50 years presented in the Draft SEIS appears
to be a conservative approximation of the time required for groundwater  to
travel from the landfill to the prison wells.

-------
5.1.4  Screening

Some connentors raised concern that the EPA was not consistent in its
application of the screening process in that it did not rule out the Walpole-
MCI site based on the evaluation of water supply issues.  The results of the
screening analysis of candidate sites is discussed in Chapter 2 of the Draft
SEIS.

Throughout the multi-step screening process potential groundwater, surface
water and water supply impacts were identified as screening criteria.  In
particular, the presence or absence of drinking water supplies within the
potential impact area of the sites was one criterion used to screen candidate
options for detailed analysis (see Section 2.4.1.3 of the Draft SEIS).  At
this screening stage, the Walpole-MCI site was identified as being at the edge
of Zone II, and within the Zone III for the prison water supply wells (see
Appendix E, Draft SEIS).  However, after considering all screening criteria,
the Walpole-MCI site was retained for detailed analysis in the Draft SEIS.

5.1.5  Incineration

Connentors questioned the methodology and assumptions* employed in the
prediction of potential water quality impacts resulting from incineration at
Stoughton.

The environmental impacts of the technology options were predicted using a
conservative analysis.  However, in instances where public health was a major
concern, the potential impacts were generally evaluated using a worst-case
scenario.  Therefore, the water quality impacts due to incineration at
Stoughton were held to a higher standard than at the other sites because
Brockton Reservoir is a currently planned potential source of drinking water,
while the affected surface waters at the other processing sites (the Fore
River and Boston Harbor) are not.  The assumptions used in the deposition
analysis are presented in Section 5.5.4.3 of the Draft SEIS.  These  included
use of maximum month sludge quantities to be processed (160 dry tons per day),
an incinerator stack of 150 feet, a conservative value for deposition velocity
(1.3 cm/second), a pollutant runoff--transport vaule of 50 percent plus direct
deposition to the waterbody, and the assumption that all pollutants  remain  in
the water column during the water body's hydraulic retention time.  These
assumptions are sufficiently conservative for the analysis conducted.
Predicted water quality impacts at the Brockton Reservoir are summarized  in
Table 5.5-6 of the Draft SEIS, which includes a discussion of drinking water,
fish consumption and aquatic life criteria.  Water quality impacts at Glen
Echo Pond are compared with the standards for surface water and aquatic life,
as shown in Table 5.5-7 of the Draft SEIS.  Drinking water criteria and
combined water and fish consumption criteria were not included in the
assessment of water quality impacts on Glen Echo Pond since it is unlikely  to
be used as a drinking water supply (see Draft SEIS Section 4.4.5.3).
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 5.1.6  Rowe Quarry

 One conmentor expressed concern about the hydrologic connection between the
 Roue Quarry and the Rumney Marsh.

 The hydrologic connection between the Rowe" Quarry site and the Rumney Marshes
 has not been clearly defined.  However, for purposes of analysis it was
 conservatively assumed in the Draft SEIS that a connection exists and
 therefore potential water quality impacts on the marsh were evaluated and
 presented in Section 5.5.3.3.  Groundwater impacts were also assessed and are
 included in Section 5.5.3.2 of the Draft SEIS.  Although it has been reported
 that the groundwater table is very near the surface at the Rowe Quarry site,
 the aquifer beneath the site is not utilized as a drinking water source.

 5.2  POLICY AND REGULATIONS

 5.2.1  Alternatives and Data Quality

 Some commentors questioned EPA's ability to ensure the quality of data used
 and to conduct independent analyses as required by NEPA, when the data for the
 SEIS were "piggybacked" from MWRA's EIR.  It was requested that EPA ensure
 that all reasonable alternatives had been equally explored, particularly no-
 action, privatization of the facilities and use of private landfills.  One
 conmentor believed that segmentation of the evaluation of the residuals
 management, siting options, and wastewater treatment siting processes was
 inappropriate and another felt that the SEIS should present one preferred
 alternative and not leave the analysis "open-ended".

 EPA's screening and analysis of long-term residuals management alternatives
 was prepared as a "piggyback" document which draws heavily on the data
 provided in the technical and scientific studies conducted by MWRA for its EIR
 and associated documents.  However, EPA conducted independent evaluations of
 the data and assumptions used by MWRA and supplemented the data where
 necessary to meet NEPA requirements.  The EPA also critically evaluated the
 process by which MWRA developed and screened its candidate options, as
 described below.  By coordinating closely with MWRA throughout development of
 its Draft EIR, EPA was able to ensure that MWRA's scope, methodologies and
 analysis were as consistent with EPA needs as possible.  EPA reviewed the
 scopes of MWRA's environmental studies, sampling methodologies and locations,
 and modeling analyses, and was present on-site during representative field
 efforts by MWRA.  Throughout, EPA and DEP were fully involved in the MWRA
 environmental review process.  However, wherever MWRA's analysis was not
 satisfactory or sufficient for EPA needs,  EPA conducted independent analyses,
 as stated above, to supplement MWRA's work.   Thus the Draft SEIS is an
 independent document from the MWRA's EIR.

 EPA is obligated by the CEQ (Council on Environmental Quality) NEPA
 regulations to evaluate a reasonable range of alternatives and to specify the
 preferred alternative or alternatives.   What constitutes a reasonable range in
each case varies depending on the nature of the project.  In addition, EPA's
own NEPA regulations provide guidance regarding evaluation of alternative
 locations,  capacities, construction phasing  and methods of management.  Both


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sets of guidelines were used as basis for identification and screening of
alternatives throughout this environmental review.  The CEQ's and EPA's NEPA
regulations both direct the agency to avoid duplication of other agencies'
efforts as much as possible in carrying out review responsibilities.  Inter-
agency coordination ensures that project reviews are conducted efficiently and
cost-effectively, while maximizing information sharing by the agencies
involved.  A "piggyback" CIS is a recognized and appropriate method of EIS
preparation.

The NEPA regulations (40 CFR Parts 1500-1508) do not require identification of
the agency's preferred alternative at the Draft EIS stage.  Section 1502.14 of
these regulations does, however, presume the existence of a preferred
alternative at the time the Final EIS is filed.  EPA's preferred alternative
for long-term residuals management program is identified in this Final SEIS in
Chapter 6.

Because the SEIS was "piggybacked" on MWRA's EIR for long term residuals
management, this was an iterative process that closely followed the steps of
MWRA's own screening and analysis for the EIR.  EPA, however, applied its own
NEPA-mandated screening criteria to ensure that MWRA's screening was
consistent with its requirements.  At each stage of-.-the screening, EPA ensured
that a reasonable range of alternatives was carried into the next phase of
analysis, concluding with a set of flexible, diverse and comprehensive
alternatives for detailed analysis.  For a more detailed description of the
screening process, see Section 2.1 and Figure 2.1-1 of the Draft SEIS.  It
should be noted that this process and the final alternatives did differ from
MWRA's in a number of ways, most noticeably in that the Stoughton site was
considered for heat drying and the Deer Island site was considered for heat
drying and incineration.

The no-action alternative for this SEIS was considered to be discontinuing the
short-term residuals management after 1995 program with no other means of
disposing of MWRA's residuals (see Chapter 2 of the Draft SEIS).  Thus, the
no-action alternative could theoretically lead to resumption of sludge
discharges to Boston Harbor, which is a major focus of the harbor cleanup and
has been deemed illegal by the U.S. District Court., for the District of
Massachusetts.   Therefore, the no action alternative was eliminated early in
the screening process.

Privatization of long-term residuals facilities and the continued use of
private landfills were eliminated as alternatives during Phase I screening on
the basis that these options are unreliable because they would remove control
of sludge processing from MWRA.   In using private or privatized facilities,
MWRA could be subject to problems such as unscheduled disruptions in service,
uncontrollable disposal costs,  landfill closures due to design inadequacies
and liability for contamination from improperly designed or operated private
landfills which it uses but has no control over.  Thus, reliance on such
facilities would jeopardize MWRA's ability to ensure the legal,
environmentally sound disposal  of its sewage sludge.  In addition, siting new
commercial landfills is extremely difficult and it is likely that in the
long-term,  they may not be able to provide sufficient capacity.  Nothing in
this analysis prevents  the MWRA from pursuing private disposal options (such
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as private landfills) in the future, if appropriate, but the MWRA will also
have its own facilities to use at all times.

EPA's Final EIS for the Siting of Wastewater Treatment Facilities for Boston
Harbor and subsequent the ROD (Record of Decision) supported the selection of
Deer Island as the site for the new secondary wastewater treatment plant and
required that related components of the project, including long-term residuals
management, undergo additional environmental review.  The environmental review
was partitioned in this way because of the vast number of related components,
the necessary timing of decisions made, the infeasibility of adequately
addressing the environmental effects of all the components in a single phase,
and because decisions on these various components were not determinative of
the treatment plant siting decision (and vice-versa).

The long-term residuals siting options were evaluated independently from
management options early in the evaluation process for organizational
purposes.  It was believed that this method of analysis would provide the
greatest flexibility and diversity of options and would ensure that the
evaluation of siting options and management options would not have undue
influence on each other. However, in the final analysis of alternatives, the
combination of sites, technologies and operating procedures were evaluated
together.

5.2.2  Regional Responsibility

Several commentors asked why the definition provided for regional
responsibility includes only major wastewater treatment facilities and not all
major public facilities that provide regional benefits and negative local
impacts.

This criterion was difficult to define and no real consensus on  its definition
or importance was possible among the relevant parties, including state and
federal agencies and citizens task forces and advisory committees.  There were
extreme differences of opinion regarding what constituted a locally burden-
some land use benefitting the region as a whole, and how to measure such
burdens and benefits.  However, the Massachusetts Secretary of the Executive
Office of Environmental Affairs, in his review of MWRA's October  1988  filing
endorsed DEP's opinion that "this criteria should be used to highlight the
distribution of regional responsibility specifically with regard to permanent
long-term wastewater facilities" (MWRA, RMFP, FEIR, 2, 1989).  Respecting that
distribution of such facilities is a state prerogative, EPA accepted this
definition.

5.2.3  Environmental Regulations

Several  commentors expressed concern over the ability of the MWRA facilities
to meet  the requirements of state and  federal environmental regulations and
asked that the state regulations from  which MWRA  is exempt should be discussed
as well  as those to which the Authority is subject.

The information regarding state laws MWRA must comply with  is taken from  the
MWRA enabling legislation, which does  not specify those from which  it  is


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exempt.  The .Draft SEIS covers compliance with applicable state and federal
regulations for each area of potential impact, such as air quality
(Section 4.3) and historic preservation (Section 4.9).  It was considered to
be reasonable not to evaluate MWRA's compliance with regulations which ..do not
apply to it..

Several commentors asked why the  Massachusetts Solid Waste Site Assignment
Criteria do not apply to the siting of the residuals landfills.  This is
discussed in Section 5.5

5.2.4  Navigable Waters Act

Some coonented that the Stop River is a navigable water and that medical waste
and radioactive material in the sludge is prohibited by the Navigable Waters
Act from being discharged into the River; therefore residuals cannot be put in
the Walpole landfill.  Another comnentor pointed out that EPA is required by
Congress to phase out landfilling of hazardous material.

The residuals landfill at the Walpole-MCI site is not expected to discharge
into the Stop River due to the state of the art design and measures being
taken to prevent a leak, including double lining, »double leachate collection
systems and monitoring, which will minimize the potential for a discharge to
occur.  These details are described in further detail in Section 3.3 of this
Final SEIS.  In addition, the residuals materials would not be defined as
hazardous waste under federal definition nor would it contain medical or
radioactive waste.  A more detailed discussion of the constituents of the
residuals materials can be found in Section 3.1 of the Draft SEIS and Section
3.2 of this Final SEIS.

Section 201 of the Hazardous and Solid Waste Amendments to the Resource
Conservation and Recovery Act addresses the land disposal of hazardous
waste.  The amendments ban the placement of bulk or noncontainerized liquid
hazardous wastes in landfills, call for regulations to minimize the disposal
of containerized liquid hazardous waste in landfills, and call for EPA to
review all listed hazardous wastes to determine whether land disposal of each
waste would be protective of human health and the.enwironment.  These
provisions do not apply to the MWRA residuals or the proposed Walpole-MCI
landfill because the residuals would not be classified as hazardous waste.
However, EPA believes that the intent of the amendment, that is, the
protection of human health and the environment, would be met at the proposed
landfill.

5.2.5  Acceptability of Alternatives

Conmentors wondered why, given that adverse impacts were found at each of the
acceptable sites, siting of the residuals facilities is considered acceptable.

EPA acknowledges that adverse impacts could potentially result from some of
the site uses, but also believes that, at those sites deemed acceptable, these
impacts can be mitigated to acceptable levels as described in Section 6.2 of
the Draft SEIS.  In addition, there is a strong need to terminate the illegal
and environmentally damaging practice of discharging sewage sludge to Boston
Harbor.

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Compensation

One conmentor asked why there is no discussion of compensation to owners of
adjacent property at Rowe Quarry.

No taking of adjacent properties would occur as a result of the use of the
Rowe Quarry site for a residuals landfill.  The quarry itself would be
purchased directly from its private owner, or if necessary would be taken by
eminent domain, with the owner receiving just compensation (fair market value)
in payment.  If any surrounding land owners believed that the siting of the
residuals landfill would amount to a partial taking of their property, the
burden of proof of such taking would lie with the landowner.  In addition, it
would be up to the MWRA and the particular landowner whether some compensation
was in order, apart from any takings.  This applies to all sites and adjacent
properties.

5.3  LANDFILL

5.3.1  Landfill Capacity

Conmentors questioned whether the Rowe Quarry and Halpole MCI landfill sites
have adequate capacity for residuals for the 25-year planning period.

Both the Rowe Quarry Site and the Walpole Site have adequate capacity for
disposal of minor residuals (grit and screenings) for the entire 25-year
planning period.  The capacity of a landfill at the Rowe Quarry Site would be
approximately 3.50 million cubic yards (mcy) after accounting for loss of
capacity due to the realignment of Route 1.  The capacity of the Walpole MCI
Landfill has been revised to 3.17 mcy from 3.20 mcy.  Additional capacity
analysis for the MWRA-recommended Walpole landfill site can be found in
Section 2.3 of this Final SEIS.

In addition to accepting all of the minor residuals, the Walpole landfill site
will have capacity for disposal of a portion of the heat dried pellets and of
dewatered sludge, if required, during the planning period.  Neither landfill
site considered has the capacity to accept the entire volume of minor
residuals, heat dried pellets, and excess dewatered sludge produced over the
entire planning period.  The landfill can, however, accommodate all grit and
screenings and a sufficient portion of the heat dried pellets or excess
dewatered sludge to ensure backup for the re-use of the sludge product.

5.3.2  Landfill Design

Commentors expressed concern that regardless of the landfill design, it is
probable that the landfill will leak and there is potential for explosion from
methane generated in the landfill.

The proposed design of the landfill is described in detail in Chapter 3 of the
Draft SEIS and MWRA's Final EIR (MWRA, RMFP, FEIR, 1, 1989).  This design will
minimize the amount of leachate generated, and will be designed with both a
primary and secondary leachate collection system that will, along with the
double liner system, minimize the potential for escape of landfill leachate to
the subsoil.

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Tests performed on the minor residuals and sludge indicate that the leachate
produced from' these materials will not be hazardous.  The potential for
pollution from a landfill leak is addressed in Sections 3.3 and 3.4 of this
document.

The MWRA addresses the production of gas from the landfill in their Final EIR
(Volume 1, Chapter 1).  A gas collection and venting system will be
incorporated in the design.  The volume of gas predicted to be generated from
grit, screenings, excess dewatered sludge, and pellets is low and not expected
to require extensive mitigation.  EPA concurs with this analysis but
recommends that provisions be made to continuously monitor gas production.  In
the event that the gas production becomes excessive, remedial action (such as
a vacuum on the venting manifold system) can be taken to collect and remove
the gas.

5.3.3  Rowe Quarry

Several comnentors mentioned, with regard to the Roue Quarry site, that the
Draft SEIS does not address the availability of daily and intermediate cover
from nearby locations and the traffic that would be generated by deliveries of
liner, cover, and cap materials.  One commentor mentioned that the EPA ignored
the problem the MWRA will have in installing a liner at the bottom of the Rowe
Quarry.

The Rowe Quarry site does lack any suitable cover material either on-site or
nearby (MWRA, RMFP, Landfill, II, 1989).  Also approximately 25 percent of the
cover material required for the landfill at the Walpole MCI site would need to
be imported.  Truck traffic generated by transport of cover material was
addressed in the Draft SEIS, Section 5.3.  Section 5.10 of this Final SEIS
further describes the additional trucks required for the transport of liner
and cap.

Some blasting would be required to install a liner at the bottom of the Rowe
Quarry to reshape the quarry floor, stabilize rock walls, and install
impassive drainage trenches.  Additional fill material would be imported to
establish the required separation of the bottom of-the landfill from the water
table (four feet) (MWRA, RMFP, DEIR, 1989).  Although the installation of a
liner at the bottom of Rowe Quarry would be more complex than at the
Walpole MCI site, the EPA believes the engineering and design of such a liner
would be feasible and environmentally acceptable.

5.4 AIR QUALITY AND ODORS

5.4.1  Areas of Impact and Sensitive Receptors

There was some confusion among comnentors regarding the different areas
evaluated for different potential impacts (e.g., air quality and public
health),  and the sensitive receptors defined for air quality and odor
impacts.
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The areas evaluated in the Draft SEIS for each category of impact were
selected based on a conservative assumption of the area that might be
affected.  Thus for example, a one kilometer radius is a conservative
assumption of the area of potential air quality and odor impacts for the
landfill.  A two kilometer study area was used in the public health analysis
of landfill sites because a variety of contaminant pathways are evaluated,
including inhalation, ground and surface water and ingestion (Section 1.8 of
the Draft SEIS).  Whereas for the potential incineration sites, a three
kilometer impact area was used for both air quality and public health studies
because airborne contaminants released from an incinerator stack would have a
larger potential transport, and therefore, impact area (Section 4.3 of the
Draft SEIS).

The criteria used in the Draft SEIS for defining air quality sensitive
receptors is based on the potential air emissions for any of the sludge
processing technologies (incineration, heat drying and composting).  For
consistency, the same criteria were used to define sensitive receptors for the
potential landfill sites.  The list of sensitive receptors for each site can
be found in Appendix C of the Draft SEIS, and includes receptors such as
schools, residences, hospitals, recreation areas, libraries and churches.

5.4.2  Data and Methodology

Coonentors questioned the emissions analysis for certain pollutants
(tetrachloroethylene at Deer Island, nitrogen oxide, phosphoric acid), and why
particular pollutants (dioxin, furan, asbestos) were not included  in the air
quality analyses.

Tetrachloroethylene emissions were analyzed for Deer Island, both  over land
and over water, and no exceedences were predicted.  This result was
inadvertently omitted from  the Draft SEIS and this addition  is made  in Chapter
7 (errata).

The short-term nitrogen oxide (HOx) guideline was not  included  in  the Draft
SEIS because it is triggered only  if a new source or modification  of an
existing source results in  an increase of 250 tons per year  or more.  None of
the three residuals processing technologies (heat drying,  composting or
incineration) will emit 250 tons or more per year of NOx  (MWRA,  Air
Derivation,  1989).

The major concern of  commentors with the phosphoric acid emission  rate was  the
uncertainty of  the five percent conversion of phosphorous  pentoxide  to
phosphoric acid.  Five percent  is  a  reasonable,  though not conservative,
estimate of the proportion  of phosphorous  that  would  be converted  to acid.
However, other  conservative assumptions were used  in  the emissions modelling
analysis (worst-case  meteorologic  conditions, maximum capacity  operating
conditions).  EPA believes  that using  a more  conservative  conversion rate
would  have produced unreasonably  conservative,  unrealistic predictions.  Under
the conditions  modeled,  the predicted  concentration  of phosphoric acid
exceeded the TEL  (threshold effects  exposure  limits),  one  of the DEP
guidelines used  to assess  air quality  impacts  (Section 5.M.5.1  Draft SEIS).
Because  TELs are  guidelines and not  regulatory  limits,  this exceedence  does


                                      5-12

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not necessarily preclude state permitting of an incinerator, and was not
regarded as an unacceptable impact.

The predicted dioxin and furan concentrations from the heat drier and
incinerator are compared to the new DEP annual average guidelines for these
pollutants in Table 5.4-1.  As illustrated in the table, the guidelines are
not predicted to be exceeded at any of the sites.


        TABLE 5.4-1 - COMPARISON OF MAXIMUM ANNUAL CONCENTRATIONS FROM
           INCINERATION AND DEP GUIDELINES (1) FOR DIOXIN AND FURAN

Site


Deer Island
Spectacle
Stoughton
Stoughton
Island
- 150 ft. stack
- 213 ft. stack
Concentration
(picogram/m3)
0.012
0.013
0.015
0.009
Percent of
Guideline
26
29
33
18
Sources: MWRA, Air Derivation, 1989 and Maillet, 1989.
(1) Guideline for both pollutants is .045 picograms/cubic meter.


Samples of sludge from the existing Deer Island Wastewater Treatment Plant
were analyzed for asbestos content at three different times during
December 1988.  The results of these analyses ranged from three million to 54
million fibers of asbestos per dry gram of sludge.  An in-stack asbestos
concentration of 1.24 fibers/cm3 was calculated by MWRA using the maximum
concentration of fibers found (54 million per dry gram of sludge) and making
the following assumptions (MWRA, RMFP, FEIR, 1, A, 1989):

     •    all of the fibers are retained in the sludge solids as they travel
          through the heat dryer;

          the asbestos fibers are partitioned downstream of the heat dryer in
          the same proportion as the sludge solids (i.e. as particulate sent
          to the afterburner and sludge pellets);

     •    no destruction of asbestos fibers occurs in the afterburner.

This in-stack concentration results in a predicted ambient air asbestos
concentration at the point of maximum deposition (as determined by the model
used in the Draft SEIS) of 4.73 8 10'5 fibers/cm3, which is lower than the TEL
for asbestos (2 x 10"fl fibers/cm3).

5.4.3  Meteorology

One commentor asked about the meteorology involved and the options evaluated
in the air quality modelling.
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Five years of surface and upper air meteorological data from Logan Airport,
Boston and Portland, Maine were entered into the Industrial Source Complex
Short Term Model, which was used to predict air quality impacts, is described
in Section 5.1.1.1. of the Draft SEIS.  These data were used for all of the
residuals processing sites.  Options evaluated include the operating
conditions cited by MWRA in the Air Emissions Derivation Report (MWRA, Air
Derivation, 1989), the rural stability mode (excluding the Quincy FRSA site)
and a cartesian grid system of one hundred receptors at each site.

5.1.1  Greenhouse Gases

The contribution of residuals incinerator emissions to the "greenhouse effect"
was a concern for some commentors.

Predicted concentrations of carbon monoxide and nitrogen dioxide, two gases
which contribute to the "greenhouse effect," are shown in Tables 5.1.1 through
5.1.5 of the Draft SEIS.  Two other "greenhouse" gases, methane and
chloroflourocarbons (CFCs), are not expected to be emitted from a sludge
incinerator.  The concentrations of carbon monoxide and nitrogen dioxide
emitted by the residuals processes are a fraction of the National Ambient Air
Quality Standards (NAAQS), and thus are considered to be an insignificant
contribution to the greenhouse effect.

5.1.5  Odors

Commentors asked what mitigation measures would be taken to prevent odors from
the residuals processing facilities beyond the residuals site boundaries.
Others asked if the odors from all of the residuals materials that could be
brought to the landfill are the same and why there is not more data for
landfill odors.

Emissions from composting facilities would have a two stage countercurrent
scrubber system which have a removal efficiency rate of at least 85 percent
and up to 99 percent, mitigating odor impacts to insignificance (MWRA, Air
Derivation, 1989).  Emissions of odors from sludge storage tanks would be
controlled by a dry scrubbing system using activated carbon adsorption and
alumina saturated with potassium permanganate.  Removal efficiencies of this
technology is expected to be in the range of 70 to 90 percent; thus odors from
the storage tanks should be minimal (MWRA, ISPD, II, 1989).  Centrifuges will
be used to dewater the sludge, minimizing its exposure to air.

Active carbon adsorption of ventilated air and recycling of the ventilated air
from the heat drying process will control odors released from the dewatered
sludge (Draft SEIS Section 5.1.6.1). Two cyclone separators and an afterburner
will be used for odor control on the heat dryers.  The dual cyclone uses
centrifugal force to remove or recycle fine particles from the emissions then
a fan transports exhaust gas to the afterburner which reaches 1800° F, a
temperature at which any volatiles present are combusted (Section 3-2.1, of
the Draft SEIS).  Combustion of gases would also control odors from a
residuals incinerator (Section 3-2.5 of the Draft SEIS).
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The types of odors that would result from each residuals material that may be
brought to the landfill (grit and screenings, heat dried pellets or dewatered
sludge) are discussed in Section 5.1.3.1 of the Draft SEIS.

During the preparation of the Draft SEIS, EPA performed a literature review
and drew from past experience to identify potential sources  of odor impacts
from residuals treatment and handling practices.  No information was available
as a basis for predicting odor impacts from disposing of wastewater residuals
in landfills other than qualitatively.  To compensate for the inability to
make quantitative predictions of odors at nearby receptors,  EPA made the
conservative assumption that significant odors could be produced by landfill
operations and that daily covering of landfilled materials would be required
to control the odors (U.S. EPA, 1978).  With this mitigation, EPA considered
the odor impacts at the landfill acceptable.  If adequate cover is not applied
daily, the odor impacts could potentially be significant and unacceptable, as
reflected in Section 5.4.3.1 of the Draft SEIS.

5.5 RESIDUALS CHARACTERIZATION

5.5.1  Minor Residuals

Several commentors requested more information about the process minor
residuals undergo before landfilling, the potential for volatile organics in
the minor residuals, and why the landfilling siting requirements were less
stringent for minor residuals than for a solid waste landfill.

Minor residuals include screenings and grit which are removed at the earliest
stages of wastewater treatment.  Screenings include any coarse solids or large
objects present in the wastewater which will not pass through coarse screens
or bar racks located at headworks, CSO facilities, and the entrance to the
wastewater treatment plant. Screenings could be anything able to be flushed
down a toilet, poured down a drain, and for areas of combined sewers, anything
that would fit down a storm drain on a street including rags, sticks, tree
branches, tennis balls, etc.  These materials are physically removed and
transported to the landfill and thus do not undergo any chemical or biological
treatment.

No testing was done for Volatile Organic Compounds (VOC's) in grit and
screenings because no VOC's are expected to be present in them.  As discussed
above, screenings are usually identifiable objects which do not contain VOC's
in measurable quantities, and because grit has a higher density than the
organic material in the wastewater, the velocity of the waste stream in the
grit settling area does not allow for the settling of organics. Any organic
matter present would bypass grit settling and continue through the treatment
plant.  In addition, by their very nature VOCs evaporate when exposed to air,
so any that were in wastewater with the grit and screenings  (i.e., water
clinging to the solids) would be released during collection and transport.

The distinction between solid waste and wastewater residuals landfill siting
is made by the Massachusetts Department of Environmental Protection (DEP),
which regulates solid waste landfills under G.L. c.111, S.150A  (implementing
regulations at 310 CMR  16.000 and. ,19.000), and wastewater residuals landfills


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under G.L. c.83 s.6 and 7 and G.L. c.21 s.26-53 (implementing regulations at
314 CMR 12.00).  This is an issue of state law, and EPA's Draft SEIS reflects
the DEP position.  The DEP regulatory scheme is based on physical and
operational differences between the types of landfills, including the
following (Powers, 1989).

     •    Traffic impacts -  The number and types of vehicles going to a
          residuals landfill are much less, and under much more control of the
          landfill operator, than those entering a solid waste landfill
          because the quantity of materials is more uniform and less, and
          because the residuals landfill accepts materials from only one
          "user" - the same entity which operates the landfill.

          Equipment - The number and type of heavy equipment operating on the
          site would be much less for a residuals landfill than for a solid
          waste landfill because residuals require less compaction and
          movement than solid waste.  This would result in lower noise impacts
          to the surrounding area.

     •    Hours - Again because the landfill "user" is also the operator, the
          hours of operation and extent of working landfill face can be
          controlled for a residuals landfill.

     •    Leachate - Leachate would be easier to control from a residuals
          landfill than from a solid waste landfill because of the
          predictability of the residuals material as compared to typical
          solid waste (note that DEP residuals landfill regulations still
          require stringent leachate control and collection precautions).

          Fires - There is minimal potential for fires at a residuals landfill
          because less gas is generated.

Current federal regulations do not distinguish between wastewater residuals
and solid waste.  Solid waste disposal is federally regulated under the
Resource Conservation and Recovery Act; the implementing regulations
concerning solid waste (including sludge landfills) are found at 40 CFR 257.
The federal regulations governing solid waste landfill design and siting are
more general than the Massachusetts regulations, and a landfill which meets
the DEP residuals landfill regulatory requirements would necessarily meet
EPA's regulations as well.

5.5.2  Sludge Characteristics

Several comments were made regarding the quality of the^VRA sludge including
questioning the status of the PCB levels previously reported in long-term
residuals management documents, the potential for volatiles and semi-volatiles
such as phthalates in the sludge and sludge products, the potential for
classification of the sludge as hazardous waste, and the inclusion of reports
on toxics from watchdog agencies such as the Boston Harbor Toxics Report.  One
commentor asked whether or not the EPA would regulate the land application of
sludge products.
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Although there were some analytical problems which led to inaccurate PCB
concentrations being reported in earlier MWRA documents, the EPA's Draft SEIS
reported the corrected PCB concentrations characteristic of existing MWRA
sludge quality.  Section 3.2 of this document discusses sludge quality and
information on concentrations of contaminants in sludge available since the
Draft SEIS.

As was discussed in the Draft SEIS, all pollutants measured in the Toxicity
Characteristic Leaching Procedure (TCLP) test performed for MWRA primary
digested sludge were below the existing limits of the Massachusetts DEP and
EPA standards for hazardous waste.  These standards are based on the use of
the Extraction Procedure Toxicity Test (EP-Tox), which generally results in
concentrations similar to or lower than the TCLP test.  Even with the
increases in concentration due to secondary treatment, the MWRA sludge is not
expected to be classified as hazardous waste.  However, the MWRA will have to
conduct further toxicity analysis on its combined primary and secondary-sludge
prior to landfilling.

The EPA will permit and enforce any federal standards or guidelines for
processing, treatment, or application of the MWRA sludge or sludge products
which are in effect at the time of facility 'operation-*  EPA has proposed
federal regulations for the management of sewage sludge, but these have not
yet been promulgated.  Until final regulations are in effect, interim guidance
for permitting via the NPDES program will be used.

The chance of volatile organic compounds (VOC's) being present in the pellets
is extremely unlikely because these pellets are heat dried at 700 degrees
Fahrenheit and routed through an afterburner which would volatilize and
destroy any VOC's remaining.  Dewatered sludge which could potentially be
landfilled in an emergency situation could contain limited quantities of
VOC's.  However, the concentrations would be greatly reduced because there are
several stages in the treatment process (including sludge thickening,
secondary treatment settling, anaerobic digestion, and heat drying) where
volatile organics would be stripped off, biodegraded, or removed.

The primary sludge will be gravity thickened and wilt have odor control off
gases which may contain some VOC's.  The secondary sludge will be thickened by
centrifuges which may discharge VOC's through their vents.  Most volatile
organic compounds are soluble and therefore would not settle in the sludge in
the primary stage of the plant.  The secondary  treatment process should strip
significant amounts of VOC's from the wastewater.

The anaerobic digesters, which will treat both primary and secondary sludge,
will also volatilize VOC's.  If emitted in the gas from the digesters, they
would be routed to either blowers, a generator, or a waste gas burner where
they would be combusted. After dewatering, heat drying the sludge to 700
degrees Fahrenheit would continue to volatilize any remaining compounds, which
would be routed through an afterburner to further remove VOC's.

EPA receives and evaluates a variety of data related to Boston Harbor and the
MWRA sewer system.  The data used in predicting sludge quality as described in
the Draft SEIS (Section 3-D and Final SEIS (Section 3.5) were Judged to be
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the best available data from which to project future residuals quality.
Review of the Boston Harbor Toxics Project's Third Annual Report on Toxic
Discharges into Boston Harbor revealed that the report is a compilation  of
information from other sources already available to EPA that have been
evaluated for the Draft and Final SEIS.  The only exception was CSO monitoring
data which is not relevant to predicting sludge quality or impacts.

5.6  PUBLIC HEALTH

5.6.1  Tozicity of Residuals

A number of commentors were concerned with the potential toxicity or hazard
associated with chemical or biological components of the sludge and landfill
material.  Specifically, individuals were concerned with potential impacts on
the Stop River (Halpole) and Rumney Marshes (Roue Quarry) and with potential
disease transmitting organisms at both landfill sites.

The toxicity or hazard of sludge or landfill material was presented in the
Draft SEIS as it relates to the potential for leachate to escape from the
landfill and impact either the Stop River or Rumney Marshes.  The sludge
toxicity was evaluated by a comparison of TCLP (Toxicity Characteristic
Leaching Procedure) leachate analyses of MWRA digested primary sludge with
existing and proposed regulatory limits (Section 3.1 Draft SEIS).  It was
concluded that the sludge is not hazardous; pollutants tested were found to
leach at lower concentrations than the limits established by EPA and DEP.

Potential impacts on public health, including routes of exposure, were
discussed in Sections 4.8 and 5.9 of the Draft SEIS.  A further evaluation of
the potential impact of the landfilled materials on the environment, and there
for public health, was conducted by modeling potential impacts from leachate
under a range of leak scenarios in Section 3.3 of  this Final SEIS.  While an
unremediated leak is not expected the scenarios were evaluated to provide a
complete analysis.  A description of leachate travel time and the potential
for a landfill leak to occur and affect private wells located at properties on
Winter Street, along the northern edge of the proposed landfill can be found
in Sections 3.3 and 3.4 of this Final SEIS.  A summary of the conclusions are
as follows:

     •    The contaminant travel time from the landfill to the downgradient
          private wells, should a leak occur, is sufficient to allow
          remediation  (See Section 3.3)

          The contaminant travel time from the landfill to the Stop River,
          should a leak occur, is on the order of  hundreds to thousands of
          years.  (See Section 3-4)

          Contamination of the downgradient  private wells by metals is not
          expected from a landfill leak even under the worst-case  scenario of
          a 50 percent leak.   (Section 3.3)

The time of travel is  significant because  it is  an indication of  the
feasibility of remediation of any leak.  The times of  travel  predicted here
allow sufficient time  for remediation.

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These conclusions confirm previous determination of no significant impact on
groundwater or surface water from the proposed Walpole landfill, and therefore
confirm the conclusion that there would be no significant impact on public
health.  An evaluation of contaminant concentrations in the Stop River
predicted no exceedences of water quality criteria protective of public
health.

Public health impacts were concluded to not be significant from migration of
metals to the Rumney Marshes.  This conclusion was made because although water
quality criteria were exceeded in the ambient surface water, it was felt to be
unlikely that the assumptions built into the criteria (approximately 16 meals
per year of fish from the marshes over a lifetime) would be realized.  More
general environmental impacts to the marshes are discussed in the response to
comments on ecology (Section 5.7).

The evaluation of sludge quality in the Draft SEIS included discussion of
pathogens (or disease causing organisms) in sludge and their potential impacts
(Section 5.1.1, 5.1, and 5.5).  It was concluded that pathogens would not be
present in the heat dried or composted sludge at levels which would present
health hazards because most of the landfilled material will go through two
levels of pathogen reduction required by EPA.  The .first and second levels are
referred to as Process to Significantly Reduce Pathogens (PSRP) and Process
for Further Reduction of Pathogens (PFRP), respectively.  All of the MWRA
sludge is expected to be processed by anaerobic digestion (PSRP).  During
normal operation, all-of the material would also be heat dried (PFRP).  Should
the processing equipment be taken off-line for repairs, MWRA's anaerobically
digested sludge (PSRP) would be landfilled.  Hazards are felt to be low due to
the use of these processes.  Also, organisms have been found to be short-lived
when introduced into the soil environment, and the landfill liner and daily
cover will significantly reduce the potential for public exposure.

5.6.2  Exposure Pathway

Several commentors questioned how exposure pathways identified were evaluated,
indicating only limited qualitative information was available in the DSEIS, or
questioned how potential additive or synergistic effects of contaminants were
handled.

The public health assessment in the Draft SEIS (Sections 4.8 and 5.9) is a
qualitative assessment in which exposure pathways of concern were identified
and were discussed qualitatively.  To put the relative impacts of the
different pathways into perspective, a prior risk assessment performed for the
City of Boston was cited.  Since that report was written in 1986, exposure
assumptions from it may not be completely up-to-date; however, the relative
doses for the different exposure pathways are expected to remain similar and
the information was provided to help better understand how exposure to
contaminants can occur.  Given that a quantitative assessment of dose, hazard,
and risk was not made, a discussion of how potential additive and synergistic
effects of chemical mixtures are handled was not presented.
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Quantitative evaluation of public health impacts was limited to a comparison
with standards and guidelines identified in Section 5.9.2 of the Draft SEIS.
A suggestion was made that potential additive effects be considered by summing
the chemical-specific ratios of predicted chemical concentrations to criteria,
resulting in an overall hazard ratio.  While that is a standard method used to
evaluate mixtures in the workplace, as described by the American Council of
Government Industrial Hygienists (ACGIH), it is not considered a standard
method for evaluating contamination in water or ambient air.  Therefore, this
evaluation of additive effects was not made.

Additional information provided by MWRA on potential lifetime cancer risk for
the MWRA-selected sites is summarized below.  The percent of cancer risks for
each exposure pathway is shown in Table 5.6-1 (MWRA, RMFP, FEIR, 3, 1989).
Some of the assumptions used in MWRA's assessment may underestimate the public
health risk.  For example, all emissions of volatile organic compounds (VOCs)
were assumed to be in a gaseous form and are not included in any deposition
pathway.  However, this omission would not significantly affect the predicted
risk because inhalation is the major exposure pathway for VOCs and this risk
is accounted for by VOCs in a gaseous form.  Also, small inland surface water
bodies in the Quincy FRSA area have been identified as potential recreational
fishing areas and Impacts from consuming fish from these ponds were not
included by MWRA in the assessment.  However, since it is unlikely that the
ponds support a significant fish population, consumption, and thus exposure
would probably be low.  Even with the uncertainty in MWRA's analysis and  the
omission of potential risk factors, the MWRA-predicted risk is sufficiently
below the significance level to support the conclusion that the proposed  plan
at Quincy FRSA will not result in significant impacts on public health  in the
community.  This confirms the conclusions presented in the Draft SEIS.

Chemical-specific risks were summed to determine potential risks associated
with each exposure pathway, and pathway-specific risks are summed to assess
overall site risks.  Summing chemical- and pathway-specific risks to determine
total risks assumes that cancer risks are additive.  While this is likely for
chemicals acting on the same organ,  it is less likely where chemicals act on
different organs.  Synergistic effects consider that the collective effect  of
a mixture of chemicals is more than the sum of individual chemicals.  An
analysis of synergistic affects was not  included because assuming all effects
are additive may over-estimate risks.  Not  including potential synergistic
effects may under-estimate risk.  However, the MWRA analysis showed a risk
level an order of magnitude less than the significance level, which does
provide a margin of safety.

5.6.3  Population

A few comments were directed toward potential populations in the vicinity of
the sites.  Issues raised ranged from too little emphasis on sensitive
populations to not enough importance given  to the high population density in
the vicinity of Quincy FRSA.

Human populations in  the vicinity of the different  sites are discussed  in
Section 4.8 of the Draft SEIS.  The approximate number of people within the
study areas, based on  1980 U.S. Census Data, and projected  percent change in


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          5.6-1  SUMMARY OF UPPER BOUND EXCESS LIFETIME CANCER RISKS
             ASSOCIATED WITH  HEAT  DRYING  (160 dtpd) AT QUINCY FRSA
	Exposure Pathway	Total Risk	

Inhalation                                     66.1

Soil Contact(a)                                 0.3

Ingestion of Vegetables                        27.2

Swimming*b)                                     2.1

Ingestion of Fish                               3.8


Source:  MWRA, RMFP, FEIR, 3A, 1989-

(a)  Includes both dermal contact and ingestion of soil.
(b)  Includes both dermal contact and ingestion of water.


population through the year 2010 were presented.  In addition, sensitive
populations were identified based on land use, focusing on the elderly, young
children, and the chronically ill.

It was suggested that population size or size of sensitive populations be used
to rank processing sites.  The public health evaluation was conducted to
determine whether any of the sites or technologies should be eliminated based
on significant impacts to public health.  It was not used independently to
rank sites.  At the Quincy FRSA site no significant public health impacts were
predicted, therefore it is considered environmentally acceptable for the MWRA
to use the site for residuals management.

5.6.4  Unusual Situations and Worker Health

A few coonentors questioned why worker health, potential impacts from traffic
accidents and accidental releases due to temporary breakdown of pollution
control equipment were not evaluated as part of the public health assessment.

Worker health is regulated by the Occupational Safety and Health
Administration and will be considered and protected when developing a facility
health and safety plan.  Truck traffic is discussed as part of Section 1.2 of
the Draft SEIS.  Impacts from traffic accidents are not expected because
trucks will add insignificantly (less than five percent) to traffic at the
proposed residuals sites.  Any impacts from a potential traffic accident would
be remediated immediately, causing no long-term exposure or public health
impacts.  Accidental release due to breakdown of pollution control equipment
is temporary in nature and not expected to impact long term health.  EPA has
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suggested that provisions be made for additional heat drying trains,  which
would add redundancy to the processing system,  so that trains with any type of
problem would not have to operate, preventing continued problem releases from
faulty equipment.

5.7 ECOLOGY

5.7.1  Wetlands

Coonentors expressed concern with the delineation and protection of wetlands
at the Halpole MCI site and the effects of drainage and runoff on wetlands
near the landfill. In addition, questions were raised regarding the impacts of
contaminated groundwater on wetlands and on fish and wildlife in the Stop
River (Maipole) and in the Rumney Marsh (Rowe Quarry).

The wetland areas at the Walpole MCI site were delineated by the MWRA and
field verified by the EPA in a site walkover.  The differences between the
EPA's wetland boundaries (Draft SEIS) and the MWRA's (Draft EIR) are
relatively minor and in either delineation, the wetlands lie outside of the
required buffer zones.  Because wetland delineations require the agreement of
the local conservation commission and state and federal agencies, the final
delineation of wetland boundaries will be determined by the agreement of these
agencies during the landfill design stage.  Given the current agreement that
the wetlands are outside the landfill footprint and buffers, any discrepancies
in the wetland delineations are not expected to affect the landfill siting
evaluation.

Impacts to the wetlands due to recharge (drainage and runoff) resulting from
landfill construction would be minimal.  The cell system of landfill operation
will assure that only one fifth of the landfill footprint would be excavated
at one time.  Temporary ditches, berms, and dikes around the open cell will
divert runoff around the open cell to simulate the original flow pattern.
Only the rainfall falling directly into the open cell would be removed from
the recharge contribution to a wetland area.  After each landfill cell area is
completed it will be capped, covered and graded to resume its natural runoff
pattern. "The mitigation section of this Final SEIS (Section 6.4.2) describes
the on-site drainage controls that should be specified during landfill design.

The impacts of potentially contaminated groundwater on fish and wildlife  in
the Stop River and the Rumney Marsh were presented in Tables 5.5-2 and 5.5-3
of the Draft SEIS (acute and chronic aquatic life criteria).  An additional
analysis of the potential impact of leachate on the Stop River (using revised
flow estimates) is presented in Section 3.2 of this Final SEIS.

Impacts to wetlands adjacent to the Walpole MCI site and the Rowe Quarry  could
only occur if the landfill leaked.  However, as described in Section 3.3,  even
if a leak occurred the contaminant level would be below water quality criteria
and thus no impacts on aquatic life in wetlands are anticipated.
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 5.7.2   Federal  Regulations

 Conmentors were concerned with compliance with Section 404 of the Clean Hater
 Act  (executed by the  U.S. Army Corps of Engineers and the EPA) and
 Presidential Executive Order No.  11990 concerning wetlands protection.

 Because the landfill  lies outside of the buffer zone of all regulated
 wetlands, the project would be in compliance with Section 104 of the Clean
 Water  Act and consistent with Executive Order 11990, which stipulate that
 wetlands impacts should be avoided unless no practicable alternative exists.
 Not  only will there be no direct impacts on wetlands (i.e., filling), but
 indirect impacts will not be significant because surface water drainage
 patterns will be maintained and fish and wildlife protected.  However, review
 of the wetland  delineation by local, state and federal authorities will be
 required as described above.

 5.8  SOCIOECONOMICS

 Concern was expressed by commentors that the residuals facilities will have
 adverse economic effects on residential property values surrounding the
 Halpole, Qulncy and Rowe Quarry sites, and that tax-exempt use (or in the case
 of Halpole, non-prison use) of the site will adversely effect municipal
 revenues.

 Section  3.6 of  this Final SEIS addresses potential property value effects of
 the  residuals landfill facilities, particularly at the Walpole MCI site.  This
 analysis concludes that although property value impacts cannot be accurately
 predicted, there  is a possibility that they may occur as a result of the
 residuals facilities, but that if measures are taken to mitigate such effects,
 property values are as likely to be restored.  In addition, the Department of
 Corrections has established expansion plans for MCI Cedar Junction, which
 involve  an addition from the west wall of the prison.  This will not be
 affected by the residuals management facilities in Walpole (MWRA, RMFP, FEIR,
 2, 1989). Therefore,  participation by Walpole in the Prison Expansion Grant
 program  will not  be hindered by MWRA activities at the site.
                                                   A. ,.
 Commentors asked  that EPA consider the loss of future tax revenue to the
 cities  from the use of the Rowe Quarry and Quincy FRSA sites.  EPA agrees that
 alternative uses  of each of these sites could generate substantial tax
 revenues for the  cities of Maiden and Revere or Quincy and Braintree,
 respectively.    However, EPA does not agree that these opportunity costs should
 be used  in evaluating the site alternatives.  Doing so would substantially
 favor public sites, including Walpole and the Quincy FRSA, over privates
 sites.   Also,  there is no certainty that such revenue generating uses will
 actually occur at these sites.  However, the MWRA has indicated that it is
 prepared to negotiate with host communities to mitigate costs associated with
 facility development and operation (MWRA, RMFP,  FEIR, 2, 1989).  The city of
Quincy has already negotiated an agreement with the MWRA for compensation for
 the use of the FRSA site as a staging area.
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5.9 TECHNOLOGIES

5.9.1  Deer Island

Some comnentors wanted to know why EPA found heat drying and incineration to
be environmentally acceptable at Deer Island, when MHRA eliminated these
options.  Others asked that EPA ensure that use of the site for residuals
processing would not conflict with wastewater treatment plant engineering and
construction and would not violate the HOD (Memorandum of Understanding)
between MWRA and Winthrop.

MWRA eliminated Deer Island as a potential residuals processing site during
the screening process based on the regional responsibility criterion.
Although EPA's screening criteria also included the institutional criterion of
regional responsibility, for which the Deer Island site was not favored, this
was weighed against other criteria for which Deer Island was favored.  These
included technical, cost and environmental criteria as well as other
institutional criteria including timely implementation and consistency with
NEPA requirements (see Section 2.U of the Draft SEIS).

EPA's more detailed analysis of the Deer Island residuals processing site was
conducted consistent with all the other processing sites considered.  In
particular for this site, air and water quality impacts were examined
closely.  As discussed in Section 6.2 of the Draft SEIS, Deer Island was found
to be environmentally acceptable for digestion, dewatering and heat drying of
sludge, and was also found to be conditionally acceptable for incineration,
subject to further analysis to assess potential air quality impacts.
Nevertheless, use of the Deer Island site for incineration was not recommended
by EPA unless several other more preferable residuals management alternatives
were not appropriately developed by MWRA (see Section 6.3 of the Draft SEIS).

EPA has continually reviewed the Deer Island alternative for compatibility
with the secondary wastewater treatment facilities.  For example, in the Final
EIR, EPA identified a potential conflict between  the batching plant  for  the
wastewater facilities construction and potential  residual facilities at  Deer
Island.  However, on further examination, due to  the timing of construction,
the site will be available for residuals facilities after completion of  the
use of  the batching plant.  One of the tasks of the Deer Island program
management consultant is to resolve any construction or engineering  conflicts
according to a pre-established procedure.   A review of the Memorandum of
Understanding (MOU) between MWRA and Winthrop indicates that the residuals
facilities will not violate any of the terms of the agreement.

5.9.2   Source Reduction

One  commentor feels that EPA should place more emphasis on  source reduction  as
a method for  improving  the quality of MWRA  sludge and another  felt  that EPA's
predicted removal  efficiencies were unrealistic and should  be  based on
information from  the MWRA pilot plant.

EPA  strongly  supports source reduction as a means of  improving wastewater
treatment plant efficiency and sludge quality.  This  is  reflected  in Section


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6.3 of the Draft SEIS, where EPA recommends pretreatment, source reduction and
targeted enforcement as means of reducing the levels of toxics in MWRA's
sludge products.

The federal Clean Water Act requires that EPA develop permit limitations for
the MWRA effluent discharge and that MWRA develop a pretreatment program to
ensure compliance with those permit limits.  The pretreatment program involves
setting and enforcing discharge limits for industries and localities
contributing to the MWRA sewer system in order to prevent disruption of the
sewage treatment system, adverse environmental impacts or disruption of sludge
use or disposal.  In a recent audit of MWRA's pretreatment program, EPA found
both improvements and deficiencies.  Improvements included increased staffing
and routine inspections, improved issuance of local standards and over $1.6
million dollars in penalties since October, 1988.  However, significant
problems still remain, including the lack of adequate compliance tracking and
monitoring systems and the lack of a comprehensive enforcement strategy.
EPA's specific recommendations relevant to sludge quality are discussed in
Section 6.2 of this Final SEIS.

The EPA removal efficiencies expressed in Table 3.1-2 of the Draft SEIS are
based on a particularly comprehensive review of the Mterature in this field
performed by EPA for the Wastewater Conveyance System SEIS (EPA, SEIS,
1988).  The data in Table 3.1-2 represent the most conservative information
found in the review and have incorporated data available from the MWRA pilot
plant at Deer Island.-  Additional data available from the pilot plant studies
can be found in Section 2.5 of this Final SEIS.

5.9.3  Composting

A few commentors asked that EPA clearly establish its acceptance of the MWRA
decision to eliminate composting.

EPA concluded in the Draft SEIS that composting is an acceptable sludge
processing technology for certain sites, and maintains that conclusion.  On
the basis of MWRA's commitments to use the landfill as a backup to the pellet
marketing program (if necessary), to conserve landfill capacity for such
backup (see Section 2.3.2), and to take certain steps to enhance the
likelihood of pellet marketing success, EPA has concluded that it is
reasonable to drop composting as a major processing technology, despite the
added flexibility (and, hence, reliability) it contributed to the overall
program.  Further, this conclusion is supported by the fact that elimination
of composting will likewise eliminate certain negative impacts associated with
construction and operation of composting facilities, and enable MWRA to focus
marketing efforts on use of the pellets product.

5.10 TRANSPORTATION AND TRAFFIC

5.10.1  Number of Trucks

Several questions were raised regarding the number of truck trips to the
landfill sites. Comnentors questioned why there is a difference in the number
of truck trips to the two proposed landfill sites and requested that EPA


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evaluate the additional truck traffic created by the transport of materials
for the liner, cap and cover to the landfill sites.

Cover was included in the truck trips projected for  each landfill site in the
Draft SEIS and the difference in the truck trips to  the two proposed landfill
sites reflects the need for obtaining more cover from offsite for Howe
Quarry.  At the Rowe Quarry site, all landfill cover must be brought in to the
site; for Walpole MCI approximately 25 percent of the cover will need to come
from off site.  For grit and screenings landfill only (Scenario 1 in the Draft
SEIS), this represents a difference of two trucks per day.  In each of the
remaining scenarios described in the Draft, more residuals material would be
carried to the landfill site and thus more cover is  required, with the
quantity of cover to be trucked in to Rowe Quarry always four times that to be
taken to Walpole.

The landfill construction schedule was not available at the time the Draft
SEIS was prepared, but is now available and can be used in analyzing the
effect of transporting liner and cap to the landfill.  This information is
presented below for three different cases:

     •Case 1   - grit and screenings only to be disposed of at the landfill
               (Scenario 1 of the Draft SEIS)

     Case 2    grit and screenings and excess dewatered sludge in the maximum
               month to be disposed of at the landfill

     Case 3    grit and screenings, excess dewatered sludge in the maximum
               month and 50 percent of pellets to be disposed of at the
               landfill.

The cap and liner materials will be delivered at different times during the
five year construction cycle for each landfill cell.  The cycle starts with
site preparation in the first year, which involves no trucking since EPA
recommends that excavation materials be used to create buffering berms at the
landfill site.  Importation of the liner material will take place for a six
month period during the second year of the construction cycle.  Landfill
operations will begin in the third year; for three months of this year one-
half of the cap material will be delivered to the site.  No construction
materials are imported to the site during the fourth year.  In year five, the
second half of the cap material  is delivered during a three month period, and
the construction cycle is completed.  Table 5.10-1 represents the maximum
number of trucks for each case, at the end of the landfill life (2015-2019),
when the quantity of residuals is greatest.
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               TABLE 5.10-1.  NUMBER OF TRUCKS DURING LANDFILL
                             CONSTRUCTION PERIODS
Number of Trucks Per
Materials
Grit, Screenings & Cover
Dewatered Sludge'^'
Additional Cover
50% Pellets(2)
Additional Cover
TOTAL YEARS 1 and 4<3)
TOTAL YEAR 2^
TOTAL YEARS 3 and 5(5)
Case 1
Walpole Rowe
5 7


5 7
16 18
14 16
Case
Walpole
5
37
15

57
68
66
2
Rowe
7
37
60

104
115
113
Day(1)
Case
Walpole
5
37
15
11
2
70
81
79

3
Rowe
7
37
60
11
5
120
131
129
(1)  Construction materials will be delivered six days/week in 22 cubic yard
     trucks.
(2)  Assumes 25% solids in dewatered sludge.
(3)  Year numbers refer to years within each five year construction period.
(4)  Over a six month period.
(5)  Over a three month period.

5.10.2  Rail Haulage

A commentor asked why there are no plans to continue rail haulage of residuals
product.

In the Final EIR MWRA has indicated that rail haulage of pellets will continue
for the long term residuals for long haul destinations;  this should
substantially mitigate the effects of truck traffic at the Quincy FRSA.
Analysis of the effects of rail haulage can be found in the Interim Residuals
Management (MWRA, ISPD, 1989).

5.11 COST

Some commentors asked why EPA did not evaluate certain costs associated with
the particular residuals management alternatives.
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Cost was an important factor in the screening process for residuals management
technologies and sites.  Chapter 2 of the Draft SEIS (especially Sections 2.2
and 2.4) reflect the cost considerations which were applied to candidate
technologies and sites during the screening process.  As discussed in
Section 5.1.3 of the Draft SEIS, cost was not used as a deciding factor in the
detailed analysis of acceptable residuals management plans (or site/technology
components) because the cost estimates available for various options did not
differ by more than the potential error involved in generating the cost
estimate (that is, cost differences were not significant in relation to the
accuracy of the cost estimates).

5.12 NOISE

5.12.1  Truck Alarms

Concern was expressed by commentors regarding the feasibility of effective
control of noise from composting at the Quincy FRSA, particularly with the
sound of truck backup alarms.  Objections were also made to the statement that
noise is less objectionable in a high noise environment.

EPA acknowledges in Section 5.6.6.3 of the Draft SEIS that truck alarms could
effect ambient noise levels at the Quincy FRSA site, and several mitigation
measures to minimize the use of trucks are recommended.

In a high noise environment, a 5 dBA increase in the ambient noise level is a
smaller percentage increase than in a low noise environment and, therefore,
should be a relatively less instrusive change.  EPA does, however, recognize
that even in a high noise environment, a noise level increase beyond existing
high levels could be problematic.  This is reflected in Section 5.6.6 of the
Draft SEIS.

5.12.2  Deer Island

One commentor asked about the relevance of the noise analysis for Deer Island
residuals facilities and another requested that noise generated by barges be
reevaluated.

The residuals facilities will be located at the southern end of Deer Island,
away from sensitive receptors.  Operating noise emissions are not expected to
increase above those associated with the secondary wastewater treatment
facilities (Section 5.6.8, Draft SEIS and Draft and Final EIS on Wastewater
Treatment Facilities; EPA, 1984 and EPA, 1985).  All residuals facilities will
be located in enclosed structures, which should sufficiently minimize any
noise produced by residuals processing. Mechanical pumping equipment used to
transfer the sludge to barges will be located inside buildings or tunnels.
Construction noise impacts will be minimized by not scheduling construction
during evenings or on weekends, and by maintaining construction equipment in
good working order (MRWA, RMFP, FEIR, 1,1989).

Barge noise should not be significant during the day due to the louder and
closer noise produced by the wastewater treatment facility.  However, noise
levels at the closest receptors in Winthrop could be exceeded in the evenings
and on weekends.   Thus barge trips should be limited to daytime when possible.

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5.13  LAND USE

Concern was expressed by some comnentors that zoning, and existing, projected
and proposed land uses around the Walpole and Howe Quarry sites were not
portrayed accurately in the Draft SEIS and that the residuals facilities are
not compatible with existing land use and zoning.  In addition, there was some
confusion as to the difference between proposed and projected land use.

The difference between projected and proposed developments is defined in the
Draft SEIS in Section 1.1.3.  Projects in the approval/permit stage are
classified as projected, while those in the conceptual stage are considered
proposed.  For example, for Deer Island the construction of the new secondary
wastewater treatment plant was classified as "proposed" because although it is
not now existing it has already received approvals and permits.  In contrast,
the announcement by IKEA Corporation of their idea to build a complex on the
Stoughton site was classified as "possible" because it has not yet undergone
any permitting or approval processes.  Projected and proposed development
projects are described in the Draft SEIS using data provided by the
communities in which each site is located.  The total number of new and
proposed residential units was not tabulated because the number of units
proposed or completed was not finalized.  Reference is made, however, to the
largest developments, particularly around the Howe Quarry site, and an attempt
was made to convey that residential and commercial development in the area is
ongoing (Section 4.1.5.3).

Zoning and existing, projected and proposed land uses around each potential
residuals site is described in order to evaluate the compatibility of the
residuals facilities with such land uses. Municipally-designated zoning is
evaluated not because it reflects the current use of the site, but rather
because it reflects the community's anticipated and desired character of the
area. Likewise, existing land use on the site itself is described in order to
assess the potential change in land use that may affect the surrounding
area.  For example, the land use around the Walpole MCI site is characterized
as residential and institutional, as these two uses abut and surround the
site.  The site itself is classified as vacant and the zoning, as designated
by the Town of Walpole, is rural residential.

As described in the Draft SEIS (Section U.I.5), the land uses surrounding the
Rowe Quarry include highway-commercial, industrial, and residential uses.  The
Quarry itself is an industrial use.  The portion of the site that is located
in Maiden and most of the site in Revere is zoned highway business; in Maiden
a variety of uses are allowed in this zone, from multi-family residences to
some industrial uses (by special permit).  A variety of zones surround the
site, from industrial to various densities of residential.  While there could
be impacts to the residential areas around the quarry if the site were used
for minor residuals landfilling, these could be mitigated.  It was determined
that given the existing site use (industrial) and the overall mixed character
of the area,  the potential use as a residuals landfill would not be
incompatible with surrounding land use (Draft SEIS, Section 5.2.3).

One commentor felt that EPA had mistakenly, in the Draft SEIS, classified land
around Rowe Quarry as vacant/undeveloped when it should be classified as


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parks/recreation/conservation Section 4.1.5).   The EPA classification is
correct.  The major area classified as vacant/undeveloped  around  the quarry is
the Rumney Marsh and, while it has been designated an ACEC (area  of critical
environmental concern), the great majority of  the approximately 1,000 acres of
the marsh is not publicly owned conservation land.   Approximately 150 acres
owned by the Metropolitan District Commission  and a smaller municipally owned
area can be classified as conservation land.  Another 150  acres is owned by
the Massachusetts DPW (Department of Public Works)  and is  to be used for the
Route 1 realignment.  The remaining majority of the land is privately held and
is not necessarily undevelopable, although the ACEC designation severely
limits the possibilities of development (Orfant,  1989).

One commentor questioned why compatibility with existing land use and zoning
is not listed as a significance criterion.  Compatibility  with local zoning is
addressed as a measure of significance ("any direct conflict with local, state
or federal land use policy . .") as described  in Section 5.2.1 of the Draft
SETS.  Although compatibility with existing land use is not specifically
listed as a criterion, it is considered in the analyses of the individual
sites, as described above.

5.14 MARKETABILITY

Several commentors agreed with EPA's concern regarding MWRA's ability to
market all of the heat dried pellets and the potential effects of unmarketed
sludge products on the landfill capacity.

Since the release of the Draft SEIS, EPA has been active in ensuring that MWRA
is able to dispose of sludge and sludge product in the event that not all of
the sludge can be marketed as heat dried pellets.  As described in Section
2.3.2 of this Final SEIS, MWRA and EPA have executed an agreement in which
MWRA commits to a maximum rate of capacity use for the life of the landfill.
MWRA has agreed that it may have to use backup disposal measures if marketing
of all the product is not possible.  While landfilling of pellets or sludge is
specifically discussed as a backup measure, MWRA has indicated it may seek
others if necessary and appropriate.  In this  manner, EPA has sought to ensure
that reasonably adequate disposal capacity will be maintained throughout the
full planning period.  In Chapter 6 of the Draft SEIS, EPA laid out several
measures for MWRA to take to help ensure marketability of the sludge
products.  Section 6.2 of this Final SEIS EPA  reviews these five steps and the
progress MWRA has made since the Draft SEIS.

Further discussion of landfill capacity can be found in Sections 2.2 and 2.3
of this Final SEIS.

5.15 UTILITIES

Several conmentors were concerned with the availability of adequate water
supply for the Walpole MCI landfill site, questioned the potential for water
supply shortages, and suggested that the MWRA build an on-site water storage
facility.  The sewer capacity at the Walpole MCI and the need for pretreatment
of leachate was also questioned.
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Section 2.5 of this Final SEIS describes MWRA's revised plans for meeting the
utility requirements for operating the residuals landfill at the Walpole MCI
site.  The EPA feels the MWRA has provided sufficient evidence that any
potential problems with water supply or sewer capacity will be met with
acceptable alternatives such as the construction of on-site storage facilities
or the use of a dedicated sewer line.

5.16 VISUAL

Commentors felt that the visual analyses should have defined the exact number
of residences that would be affected by the residuals facilities and that the
users of the Boston Harbor Islands Parks should be considered in the Spectacle
Island analysis.

The location of residences that would likely be affected by the residuals
facilities are described in Section 5.7 of the Draft SEIS.  It was not
possible to determine the exact number of residences that would be affected by
the residuals facilities without access to each residence in the study area.
Section 5.7.5 of the Draft SEIS acknowledges the visual effects on park users
of the proposed Spectacle Island site.

5.17 HISTORIC AND ARCHAEOLOGICAL RESOURCES

Commentors asked that HHRA be required to explore preservation options for
each candidate site and that an agenda and schedule for archaeological review
and mitigation at each site be established.

Section 5.10 of the Draft SEIS describes a general cultural resources agenda
for each site.  It also describes a reconnaissance survey of the Walpole site
that was performed for EPA in early  1989 and generally outlines a recommended
agenda for additional field work at the site.  For the FRSA site, historic and
archaeological review and documentation have been completed by MWRA to the
satisfaction of the National Park Service (NFS,  1989).  For each site,
historic and archaeological resource preservation is described by a Memorandum
of Agreement (MOA) executed by the Advisory Council on Historic Preservation,
EPA and the Massachusetts Historical Commission, with the concurrence of the
MWRA and DEP.  For the long-term residuals management plan, the MOA sets out
procedures for archaeologic and historic review and mitigation.  The MOA is
presented in Chapter 7 of this Final SEIS, which appends  it to the Draft SEIS
as Appendix F.

5.18 PRISONS

A few commentors expressed concern regarding the effect of  impacts such as
odors and noise, on the confined population in the prisons  that abut the
Halpole site.

It is not expected that odors and noise will be significant  inside the prisons
due to the height of the surrounding walls.  However, a literature search
conducted by EPA to identify any studies on this issue yielded no pertinent
information.  Therefore, EPA does not believe  it reasonable  to draw any
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conclusions regarding what impacts the landfill might have on prisoners or
prison employees beyond those drawn concerning the general population of the
area.

5.19 EDITORIAL COMMENTS

Coonentors requested a feu editorial changes, primarily associated with
typographical errors in the Draft SEIS.

Editorial changes to the Draft SEIS can be found in Chapter 7 of this SEIS.
                                     5-32

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                                  CHAPTER SIX
            ACCEPTABLE RESIDUALS MANAGEMENT OPTIONS AND MITIGATION

6.1  INTRODUCTION

This chapter presents a review of the recommendations made in the Draft SEIS,
and the new information, new analyses and major modifications made to the
MWRA-recommended plan since the release of the Draft SEIS.  It then presents
EPAs recommendations and a complete set of corresponding mitigation measures.

6.2  REVIEW OF THE DRAFT SEIS RECOMMENDATIONS

In the Draft SEIS, EPA found several site/technology alternatives acceptable
as components of MWRA's long-term residuals management program (Table 6.2-1).
The Draft EIR presented one of these options as its recommended plan, a
combination of heat drying and composting of sludge at the Quincy FRSA and
landfilling of grit and screenings (and dewatered sludge and heat dried
pellets on an emergency basis) at the Walpole-MCI site.  As stated in the
Draft SEIS, EPA was not fully convinced that this plan would adequately
provide for the treatment and disposal of all residuals during the planning
period (1995-2020) because the plan relies on the beneficial reuse of sludge
products which currently have projected contaminant concentrations that could
Jeopardize its marketability. In addition, competition from other new
generators of similar products could decrease the potential market available
to MWRA.

Since the release of the Draft SEIS, MWRA has chosen to eliminate composting
as a sludge processing technology, relying even more heavily on beneficial


           TABLE 6.2-1.   ACCEPTABLE SITE AND TECHNOLOGY COMBINATIONS

Site          Transfer    Dewater     Heat Dry    Combust    Compost    Landfill

Walpole                                                                    X
MCI

Rowe                                                                       X
Quarry

Stoughton                                X

Quincy            XXX                     X
FRSA

Spectacle                    X            XXX
Island

Deer                         XXX
Island
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reuse of sludge as heat dried pellets.  Although supportive of the goal of 100
percent reuse of sludge products, EPA still believes that the recommended
residuals management program must ensure a reliable long-term solution, and
sludge discharge to Boston Harbor must not resume.  In the Draft SEIS,  EPA
laid out five steps that MWRA should take to help guarantee that adequate
sludge product distribution takes place throughout the planning period.  Each
of these steps is summarized below, along with the MWRA's efforts to respond
to them.

MORA should commit in its Final EIR to maximize landfill capacity, in the
event it can not market its product, by landfilling heat dried pellets rather
than dewatered sludge.  In the Final EIR the Authority has committed to
emergency landfilling of heat dried pellets rather than dewatered sludge cake
whenever possible.  MWRA has also signed an agreement with EPA to use the
landfill at one of two rates agreed to by EPA.  If the rate is exceeded at any
time, MWRA has committed in the agreement to put only excess pellets in the
landfill until it is not in excess of the agreed upon rate (Keough, 1989).
This agreement seeks to ensure that landfill capacity is rationed prudently
throughout the planning period.

MWRA should obtain commitments from government agencies to use MWRA's product
for their fertilizing and soil enhancement needs.  Although no commitments
have yet been made by the agencies, the MWRA Board of Directors has authorized
the MWRA to seek such agreements with state agencies.  MWRA has also committed
in the Final EIR to negotiate with state agencies to accept and use sludge
product of suitable quality.  The MWRA has already held informational meetings
with these agencies to educate them about use of the pellet product.

MWRA should obtain from the DEP a classification of the compost being produced
by the Deer Island pilot plant and should begin a program of significant
distribution of that product.  Even though composting is no longer included in
the long-term residuals management plan, MWRA should continue to pursue DEP
classification of the material from the pilot composting plant.
Classification and distribution of the existing compost material will help
establish MWRA as a producer of beneficial sludge products and demonstrate its
ability to1 successfully negotiate the regulatory process.  In June 1989, MWRA
changed the digester sampling location from the bottom (where heavy metals
concentrate) to the middle, which is more representative of the product being
produced.  Six months of testing is needed for a DEP classification.
Therefore, testing should be completed in November, and data should be
prepared and submitted to DEP for classification by approximately February
1990 (B. Tansel, 1989).

For metals which potentially exceed regulatory standards for the distribution
of sludge products, the MWRA should present in its Final EIR a plan for
confirming the projected levels of these chemicals, and then if confirmed, for
reducing these levels through pretreatment, source reduction, or targeted
enforcement.

Although MWRA has made significant improvements in their Toxics Reduction and
Control (TRAC) program over the last  few years, deficiencies do remain.
Improvements are needed to upgrade data management and enforcement management


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systems, establish suitable local limits and reduce the concentrations of
molybdenum in the sludge to below Massachusetts standards.

MiRA should present in the Final .EIR a marketing strategy for sludge
products.  MWRA has committed in the Final EIR to the general marketing
strategy summarized in Table 6.2-2,  but has not made progress towards the
specifics requested by EPA in the Draft SEIS (identifying methods to be used
to contact prospective buyers; advertise; transport the product and assist
buyers in obtaining appropriate permits if necessary).

                TABLE 6.2-2.  MWRA GENERAL MARKETING  STRATEGY


          Negotiate agreements with government agencies to use product;

          Hold workshops in the spring of 1990;

          Market research and development, including: applied research
          projects in mid-1990, expanded applied research with MWRA pellets in
          1992, quality monitoring and toxic reduction, and program
          administration and planning.


Source:  MWRA, RMFP, FEIR, 1, 1989.

6.3 REVIEW OF NEW ISSUES, INFORMATION AND MODIFICATION TO THE PLAN

In addition to the changes listed above, the following modifications to the
plan and new information have become available since the release of the Draft
SEIS, as addressed in Chapter 2 and 3 of this document.

          The footprint, and thus the capacity, of the proposed landfill at
          the Walpole site was slightly reduced;

          High solids centrifuges have been chosen for dewatering sludge prior
          to its introduction into the heat driers, with the interim
          facilities' belt presses retained as backup equipment;

     •    Wastewater produced during dewatering at the FRSA will be pumped
          into the Quincy sewer system when it is operating under capacity,
          when the system is operating at or above capacity the wastewater
          will be hauled to Deer Island via the returning digested sludge
          barge;

          All air intakes and exhaust stacks at the Quincy FRSA will include
          mufflers;

          MWRA has provided sufficient alternatives to ensure that utilities
          can be provided at the Walpole MCI landfill site without disrupting
          local water and sewer service.
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EPA performed additional technical analysis of certain aspects of the
MWRA-recommended plan which yielded the following results.

     •    Predicted concentrations of molybdenum in the sewage sludge
          (41 mg/kg) may exceed the Massachusetts criterion (40 tng/kg) for
          application to non-agricultural, non-grazing land.

     •    Under conservative, worst case, low flow conditions, Stop River
          predicted pollutant concentrations above background (resulting from
          potential leakage from the Walpole MCI landfill) are well below the
          applicable freshwater standards.  In addition, even under the worst
          case, most conservative scenario of a fifty percent leak for ten
          years, pollutant concentrations at the private wells near the
          Walpole MCI landfill site are predicted to be below the
          Massachusetts groundwater standards.

     •    Additional analysis of data provided by MWRA indicates that no
          significant risks to public health are associated with the
          MWRA-recommended siting of the residuals landfill and processing
          sites.

     •    In general, a literature search showed that environmental factors
          usually account for only a small proportion of potential inputs to
          property values, and that house and lot size and quality, municipal
          services and regional economy are more important determinants of
          property value.  However, in some studies noise was shown to have a
          potential impact on property values.  Only three properties near the
          Walpole-MCI landfill are predicted to have temporary noise levels in
          the range discussed in the literature studies.

In addition, MWRA and DEP have entered into an agreement to have approved
plans before construction begins to minimize migration and impacts of
hazardous materials from the Quincy FRSA; a mitigation/demolition plan for the
Quincy FRSA has been conditionally accepted by the National Park Service (NPS,
1989).

6.4  EPA RECOMMENDATIONS AND MITIGATION MEASURES

With the following mitigation measures, EPA believes that the MWRA recommended
plan of digestion on Deer Island, dewatering and heat drying at the Quincy
FRSA, and landfilling at the Walpole-MCI site will be environmentally
acceptable for reliable sludge processing and disposal throughout the 25-year
planning period.  In addition, because MWRA will have to build and operate the
residuals facilities, and because EPA recognizes MWRA's primacy in determining
what combination of sites and processes would best serve its needs, this plan
is also EPA's preferred plan.

6.4.1  Residuals Processing

MWRA has acknowledged that, assuming at least one heat drying train is
sometimes unusable, in the later part of the project period sludge generation
would exceed the capacity of the proposed six heat drying trains.  In


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addition, if the centrifuges do not perform at the expected level at all times
(at least 25 percent solids), sludge generation would exceed heat drier
capacity in the later part of the project period.  EPA recommends that MWRA
act to ensure that space will be available at the Quincy FRSA for possible
construction of at least two additional heat drying process trains.  The heat
drying facilities should also have the flexibility to allow for full use of
all available heat dryers, regardless of which centrifuges are operational.

The performance of the heat dryers and centrifuges should be closely monitored
prior to implementation of secondary treatment, so that a determination can be
made as to if, when and how many additional units should be installed.  As
discussed in Section 2.3 of this Final SEIS, MWRA and EPA have signed an
agreement regarding husbanding of the landfill to ensure adequate capacity
throughout the 25 year planning period.  EPA's acceptance of MWRA's plan is
conditioned on MWRA adherence to that agreement.

6.4.2 Hater Quality Monitoring and Protection - Walpole-MCI

The proposed residuals landfill at the Walpole-MCI site described in Section
2.6 of this Final SEIS will be designed using state of the art technology and
in full accordance with guidelines established by the.DEP Division of Water
Pollution Control (DWPC).  The following recommendations for monitoring at the
landfill site will ensure that in the unlikely event of a leak, detection will
occur quickly and remediation can occur in a timely manner to ensure
protection of ground and surface water quality.

6.4.2.1  Leachate Collection System

The Walpole-MCI residuals landfill will have a double liner and double
leachate collection system, as described in Section 2.6 of this Final SEIS.
Systematic sampling and testing of both systems should be required in order to
monitor the quality of leachate entering the sewer system.  Systematic testing
can be used to establish a baseline of the quality and quantity of the
leachate so that any irregularities that may indicate a leak would be
immediately apparent.  A leachate flow monitoring program should be
established in order to ensure that the liners perfoco continuously at their
optimum levels.  The leachate collection system must also be designed to keep
the leachate separate from uncontaminated stormwater.

6.4.2.2  Landfill Monitoring.  The state of the art design and operation of
the residuals landfill is expected to fully mitigate any potential adverse
impacts.  However, a systematic sampling and testing program must be
established in order to monitor any potential contaminant releases to the
areas surrounding the landfill site.

Materials Monitoring.  A monitoring program should be established for all
materials which are deposited on site during both the construction and
operation phases of the project.  Soils used in the construction of the
landfill liner, leachate collection and capping systems should be sampled
prior to use.  All grit and screenings deposited within the landfill during
normal operations should be tested, as should any pellets or sludge which
require disposal.  The materials monitoring program will thus provide a
measure of quality control over landfill deposits and construction materials.

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Groundwater Monitoring.  In the unlikely event that both the primary and
secondary liners failed and the leak was not detected by the leachate
collection system, there would be a potential for on site contamination of
groundwater to occur.   Therefore, a series of monitoring wells should be
installed surrounding the site to provide an early warning of contaminant
migration from the landfill before significant impacts occur.  The wells
should be sampled at regular intervals and be compared with background data in
order to detect changes in groundwater quality.  As discussed in Section 3.4
of this Final SEIS, the rate of contaminant migration is expected to be on the
order of hundreds to thousands of years and thus the early detection afforded
by these wells will provide sufficient time for cleanup and repair.  As with
all aspects of the landfill design, the exact number and location of the
monitoring wells should be defined during the design stage and will be subject
to complete DEP approval.  However, for purposes of illustration a possible
monitoring well configuration has been developed for this Final SEIS
(Figure 6.1-1).

The approximations of the locations and spacing of wells were determined using
numerical and statistical approximations of the likely path and shape of a
possible leachate plume.  A discussion of the method used is included in
Appendix A.  The results of the analysis suggest that, in general, a
monitoring well spacing of approximately 500 feet to 1000 feet would be
sufficient to detect a potential leachate plume.  A spacing of approximately
400 feet would probably be needed in areas where the monitoring wells are
closer to the landfill, such as between the site and the private wellfields
located along Winter Street.  In all, the analysis predicted that
approximately 12 wells would provide sufficient capacity for contaminant
detection.  As discussed above, the actual location and number of wells will
be defined and approved during the design stage.

While the well configuration shown in the figure are approximate only, it
serves to highlight the general areas which should be monitored.  A series of
monitoring wells should be installed along the slope between the landfill and
the eastern side of the Stop River, with an additional well adjacent to the
Stop River impoundment.  Wells should also be installed along the northern
boundary of'the site between the landfill and the private wells and along the
western boundary between the landfill and the Neponset Sole Source Aquifer.  A
well should also be located upgradient from the site to provide representative
background groundwater quality data.  It is recommended that at some
monitoring locations a cluster of wells be installed in order to obtain
samples at various depths throughout the aquifer.  Bedrock wells may also be
required to monitor flow in fractured bedrock.

EPA recommends that MWRA utilize existing monitoring wells wherever possible,
both prior to and during the landfill operation stage.  For instance, the
existing wells can be used to monitor groundwater quality in the period prior
to landfill construction and operation.  Quarterly water level measurements
would also provide additional data for design of the final monitoring well
configuration.  Staff gages and piezometers should be installed as well for
continued investigation and evaluation of the site's groundwater flow
regime.  In order to ensure the establishment of a comprehensive, tailor-made
monitoring program, MWRA should provide an opportunity for EPA and DEP input
into the design, installation and operation of the monitoring wells.

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       SCALE IN METERS

2000          0          2000
        SCALE IN FEET
        LEGEND

APPROXIMATE SITE BOUNDARY
                                             	APPROXIMATE LANDFILL BOUNDARY
APPROXIMATE LOCATION OF
POTENTIAL MONITORING WELLS
     FIGURE 6.4-1. PRELIMINARY MONITORING WELL LOCATION-WALPOLE MCI
                                                                       IFTC »L r B t OO

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The sampling schedule and list of parameters should be defined in the plan of
operation.  EPA recommends that all observation wells be sampled on a
quarterly basis and suggests that MWRA sample public water supply wells at
least once a year.   MWRA should also sample and test the two nearby private
wellfields once a year at the request of the individual property owners.  The
list of sampling parameters should be continually evaluated and refined
throughout the life of the project.  At the very least, MWRA should sample for
metals and total organic carbon, with additional sampling for other more
specific parameters as the need arises.  MWRA should continue to evaluate the
results of pilot studies and conduct additional leachate analysis prior to
landfill operation in order to further define a list of likely sampling
parameters.  MWRA may choose to monitor for contaminants which migrate most
quickly (i.e., those with zero or low retardation factors) and should also
sample periodically for contaminants for which drinking water standards exist.

In addition, advances in wastewater treatment or groundwater monitoring may be
realized in the period prior to actual landfill operation and may influence
the list of sampling parameters.  Several factors can therefore potentially
affect the choice of sampling parameters.

The remedial action'to be taken by MWRA in the event of a landfill leak should
depend on the amount of residuals material stored in a particular cell.  If
the cell is nearing capacity it should be capped to prevent further
infiltration thereby halting leachate production.  If the cell leaks before it
reaches capacity, the residuals material should be removed so that the leak
may be found and repaired.  Repairing the leak in this fashion will therefore
preserve cell capacity.

Surface Water Monitoring.  A sampling and testing program should be
established to monitor nearby surface waters.  As noted above, runoff will be
diverted around the site to minimize the potential for stormwater
contamination.   Although no contamination is expected to occur,  all
stormwater discharges to surface waters should be monitored at regular time
intervals.  In addition, the Stop River should be sampled both above and
below  all stormwater outfalls.  The Stop River impoundment should be
monitored at various locations as well.

6.4.2.3  Contingency Plans.  The combination of state of the art technology
and the rigorous environmental monitoring described above is expected to
provide complete mitigation of impacts from operation of the proposed Walpole-
MCI residuals landfill.  It should be emphasized that neither the Final EIR
nor this Final SEIS are design documents and that the measures discussed above
will be refined and subject to agency review and approval during the design
stage.  A detailed contingency plan must be prepared prior to construction of
the landfill and this plan should identify all the appropriate design features
and monitoring plans which will be required to prevent contamination of the
site and surrounding areas.  The contingency plan should also include a
discussion of methods to be implemented by MWRA in the event that remedial
action is necessary.  In the unlikely event of leachate contamination, MWRA
should either remediate or replace public and private water supplies.
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6.4.3  Other Mitigation Measures

In addition to those measures outlined above, the following are recommended by
EPA as additions to the MWRA-recommended plan.  A complete set of the
mitigation measures described in this chapter and Chapter 6 of the Draft SETS
are shown in Table 6.4-1.

Additional mitigation measures include the following:

     •    Whenever possible, residuals barge trips to and from Deer Island
          should be limited to the daytime, when they will not add
          significantly to the ambient noise level;

     •    MWRA should continuously monitor the landfill for methane gas
          production and if excessive amounts of gas are produced the problem
          should be remediated immediately;

     •    The materials excavated in preparing the Walpole site for the
          landfill should be used to form berms on the site to mitigate noise
          and visual impacts and to reduce the number of trucks leaving the
          site during this stage of the landfill construction
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                                CHAPTER SEVEN
                                    ERRATA

The errata contained herein correspond to the Long-Term Residuals Management
Draft SEIS, 1989 prepared by the U.S. EPA, Region I. After technical and
editorial review of comments received the following changes were made.
Corrections are grouped according to text, table and figure changes.

7.1  TEXT CHANGES

Page 3-35, Section 3.2.6.  Last sentence changed from "In Massachusetts, a
minimum of five feet of unconsolidated soil must be provided between the
landfill bottom and the groundwater table." to read "Massachusetts currently
requires a minimum separation distance of four feet between the bottom of the
landfill and the high groundwater level.  Five feet is the new standard
proposed by the Division of Water Pollution Control."

Page 3-49, Section 3.4.2.  First paragraph, third sentence changed from "The
Maiden/Revere town line splits the site in half." to read "The Maiden/Revere
town line splits the site in half; total population in Maiden is 52,174 and in
Revere is 39,512."

Page 3-61, Section 3.4.5.  First full paragraph, after the first sentence
which ends "...and Central Artery Depression projects." followed by "Planning
and design for excavate disposal at Spectacle Island is on-going and Figure
3.4-14 represents the most recent layout."

Page 4-11.  After Section 4.1.2.10 add:  "Section 4.1.2.11 Hassachusetts
Executive Order No. 193, Preservation of State-Owned Agricultural Land.
Executive Order No. 193 was issues in 1981 with the intent of reducing the
conversion of agricultural land or land suitable for agricultural development,
as defined for the U.S. Department of Agriculture, Soil Conservation
Service.  The Order specifies that state agencies attempt to mitigate against
the conversion of state-owned agricultural land.  Among the policies outlined
in the Order are: 1) state funds and federal grants administered by the state
shall not be used to encourage the conversion of agri-cultural land when
possible alternatives are available; and, 2) state agencies' actions shall
encourage the protection of state owned agricultural land by mitigating
against the conversion of state owned land to non-agricultural uses, and by
promoting soil and water conservation practices."

Page 4-38, Section 4.1.8.3-  Third full paragraph, second sentence changed
from "The dredging is projected to begin in 1989." to read "The dredging is
projected to begin in the fall of 1993, with a possible early start in the
fall of 1992."

Page 4-46, Section 4.2.1.  Second paragraph, after the first sentence which
ends "...Section 4.3.2 and 4.5.2 respectively}." followed by "It is
anticipated that any residuals activity at Spectacle Island will be preceded
by DPW use and therefore will not involve pier construction, which would be
subject to Sections 10 and 404 permitting by the U.S. Army Corps of
Engineers."


                                      7-1

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Page 1-71,  Section 4.3.2.6.  Second sentence,  changed from  "These are the same
as the NAAQS (Section 4.3.2.1) with two exceptions: the one hour standard for
ozone is 0.12 ug/nP and there is.no PM-10 standard." to read "These are the
same as the NAAQS (Section 4.3-2.1).  The DEQE will also be proposing a state
PM-10 standard in the near future."

Page 4-71,  Section 4.3.2.7.   Second paragraph, first sentence changed from
"The TELs are a 24-hour limit for non-carcinogenic pollutants and the AALs are
an annual average based on 1 x 10"6 health risk for carcinogenic pollutants."
to read "The TELs are a 24-hour limit and the AALs are an annual average based
on 1 x 10"° health risk for toxic pollutants."

Page 4-71,  Section 4.3.2.8.   Addition made to the end of the first sentence to
read "...and the DEQE."

Page 4-71,  Section 4.3.2.9.  First paragraph, first sentence changed from "The
DEQE has established ambient..." to read "The DEQE has established new
ambient...."

?age 4-71,-Section 4.3.2.9.   First paragraph, second sentence changed from
"These levels are listed below, based on annual averages for particulate and
gaseous total PCDD and PCDF." to read "The new particulate and gaseous dioxins
and furans annual guideline is 0.045 picograms per cubic meter and has been
revised to incorporate toxic equivalency factors (TEFs) based on the toxicity
of the 2,3,7,8-isomers of both dioxins and furans."

Page 4-81,  Section 4.3.6.4.  First paragraph, third sentence that reads "In
addition, the city of Revere is designated as not attaining the PM-10
standard." deleted.

Page 4-85,  Section 4.3.8.4.  First paragraph, second sentence changed from
"However, for PM-10, carbon monoxide,	" to read However, for carbon
monoxide,	"

Page 4-127, Section  4.5.3.2.  First paragraph, fourth  sentence  changed  from
"...therefore the allowable increase  in  the overall noise  levels may be
significantly less than  10 dBA, according to  the   DEQE guidelines."  to  read
"...and are not allowed, according  to the DEQE guidelines."

Page 4-163, Section  4.7.4.2.  First paragraph, last sentence "This  stand  is
not considered a wetland because  it is relatively  small and disturbed..."  is
deleted.

Page 4-184, Section  4.8.2.3.  Fourth  sentence changed  from "Recommended
criteria are the concentrations associated with a  range of incremental  cancer
risks	"  to read "Recommended criteria are  the  concentrations of the
chemical in water associated  with no  adverse  noncarcinogenic health effects
and with a  range of  cancer  risks	"

Page 4-184, Section  4.8.2.4.  Second  sentence changed  from "...and allowable
ambient  levels  (AALs)  are health-based guidance  levels" to read "...and
allowable ambient  limits (AALS) are health-based  guidelines	"

                                      7-2

-------
 Page  1-184,  Section  4.8.2.5.  Third paragraph, added  to  the end of  the
 paragraph  "The  Massachusetts  Drinking Water Standards and  guidelines are
 incorporated as groundwater standards for Class  I and II waters."

 Page  4-193,  Section  4.9.2.3-  Before the first sentence  add "(36 CFR 800)."

 Page  4-194,  Section  4.9.3.  End of the first sentence changed from  "...with
 the concurrence of the MWRA and DEQE." to read "...with  the concurrence of the
 MWRA  and DEQE;  a copy of  the  MOA can be found in Appendix  F of this document."

           (Appendix  F can be  found at the  end  of the text changes.)

 Page  4-194,  Section  4.9.3.  End of the second sentence changed from "...on
 National Register eligible property will be accounted for  in compliance with
 Section 106  of  the NHPA." to  read "...on National Register eligible property
 will  be taken into account in compliance with Section 106  of the NHPA."

 Page  5-2, Section 5.1.4.1.  Fourth sentence changed from "With the  addition of
 incinerator  ash  to a sludge-only landfill	" to read "With the addition of
 ash from the sludge  incinerator to a sludge-only landfill	"

 Page  5-32, Section 5.4.2. First item in the list, number  1, first sentence
 changed from "...Threshold Exposure Limits (TELs, these are equivalent to 24-
 hour  Allowable  Ambient Limits) and...." to read  "...Threshold Exposure Limits
 and...."

 Page  5-32, Section 5.4.2.  Third item in the list, number  3, first  sentence
 changed from "The total ambient air concentration (predicted incremental from
 the project  plus  the background ambient air concentration) was compared to the
 DEQE  and EPA guidelines listed above." to read   "The  total ambient  air
 concentration (predicted incremental from the project plus the background
 ambient air  concentration) for criteria pollutants was compared to  the EPA's
 SILs  and the NAAQS."

 Page  5-35, Section 5.4.5.1.   Last paragraph, second-to last sentence changed
 from  "These  levels are well below the standard (section 5.3.2.9)."  to read
 "These levels are well below  the standard (Section 4.3.2.9)."

 Page  5-45, Section 5.4.8.1.   Last sentence changed from "EOEA does  not regard
 these phosphoric acid emissions...." to read "EPA does not regard these
 phosphoric acid emissions...."


 Page 5-48, Section 5.4.8.2.  The second paragraph after the fourth  sentence
which ends "...exceedance occurred." followed by "The tetrachloroethylene
overland maximum concentration was also compared to the TEL and it  did not
exceed this guideline."

Page 5-48,  Section 5.4.8.2.   Second paragraph,  last sentence changed from
"...this one exceedance will not present permitting—." to read "...this one
exceedance will  not prevent permitting...."
                                     7-3

-------
Page 5-58, Section 5.5.3.2.  Second paragraph, second to last sentence changed
from "Concentrations of lead and mercury	" to read "Concentrations of lead,
cadmium and mercury	"

Page 5-60, Section 5.5.3.2.  First sentence of the page changed from "..could
cause violations of lead and mercury	" to read "could cause violations of
lead, cadmium and mercury..."

Page 5-84, Section 5.6.6.3.  First paragraph, first sentence changed from
"...on the barges and the tugboat engines."  to read "...on the barges and the
tugboat engines and the mitigation measures described in Section 5.6.5.3 are
recommended."

Page 5-84, Section 5.6.6.3.  Last sentence in second paragraph changed from
"At the other three receptors, only a effect is projected." to read "At the
other receptors only an insignificant effect is projected."

Page 5-93, Section 5.8.2.1.  Fourth full paragraph, last sentence changed from
"This area is too small to fall under the Jurisdiction of the Wetlands
Protection Act, and its loss would not be significant." to read "This area is
too small to fall under the jurisdiction of the Wetlands Protection Act, but
may be subject to Section 404 of the Clean Water Act."

Page 5-113, Section 5.11.2.  Second paragraph, second to last sentence changed
from "... Sections 5.3 traffic; 5.4, air quality and odors; 5.6, noise; 5.7,
visual." to read "... Sections 5.3 Traffic; 5.4, Air quality and Odors; 5.6,
Noise; 5.7, Visual."
                                      7-4

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       APPENDIX  F



MEMORANDUM OF AGREEMENT

-------
Advisory
Council On
Historic
Preservation
The Old Post Office Building
1100 Pennsylvania Avenue. NW. *809
V^ihington. DC 20004
  SEP  221968
 Ms. Kathleen K. Hull
 Historic Preservation Officer
 Environmental Protection Agency
 J.F. Kennedy Federal Building
 Boston, MX  02203-2211

 REF:  Cleanup of Boston Harbor

 Dear Ms. Hull:

 The enclosed Memorandum of Agreement for the  referenced project
 has been executed by the council.  By carrying out the terms of
 the Agreement, you will have fulfilled your responsibilities
 under Section 106 of the National Historic Preservation Act and
 the Council's regulations.  A copy of the Agreement has also been
 sent to the Massachusetts State Historic Preservation Officer.

 We appreciate your cooperation in reaching this  Agreement.
         Klima
     [£,  Eastern Division
       Project Review
  Enclosure

-------
                   MEMORANDUM OF AGREEMENT


     WHEREAS, the U.S. Environmental Protection Agency (EPA)
nas determined that construction of the Massachusetts Water
Resources Authority's Secondary Wastewater Treatment
Facilities on Deer Island will have an effect upon
properties which are eligible for inclusion in the National
Register of Historic Places; has determined that related
projects, described herein, may potentially have an effect
upon other eligible historical and archaeological resources;
and has consulted with the Massachusetts State Historic
Preservation Officer (SHPO) and the Advisory Council on
Historic Preservation (Council) pursuant to 36 CFR Part 800,
regulations implementing Section 106 of the National
Historic Preservation Act (16 U.S.C. 470f); and

     WHEREAS, the Massachusetts Division of Water Pollution
Control (DWPcj participated in the consultation and has been
invited to concur in this Memorandum of Agreement; and

     WHEREAS, the Massachusetts Water Resources Authority
(MWRA), the project proponent, participated in the consul-
tation and has been invited to concur in this Memorandum of
Agreement (MOA);

     NOW THEREFORE, EPA, the Massachusetts SHPO, and the
Council agree that the above undertakings shall be imple-
mented in accordance with the following stipulations in
order to take into account the effects on resources included
or eligible for inclusion in the National Register of
Historic Places.
                        STIPULATIONS

     EPA will ensure that the following measures are carried
out.
I.   Construction on Deer Island

     The properties located on Deer Island which are eligi-
ble for inclusion in the National Register of Historic
Places include:  Superintendent's House, New Resthaven
Cemetery, Hill Prison, Steam Pumping Station and Farmhouse.

a)   The Early Site Preparation (ESP) predesign report shall
identify activities which will occur adjacent to and/or in
close proximity to the Farmhouse, Steam Pumping Station,
Superintendent's House, Hill Prison or New Resthaven
Cemetery, and shall be submitted to the SHPO for review and

-------
comment.  At the 50% design and specification completion
point of the Early site Preparation design contract,  the
MWRA shall submit plans and specifications to the SRPO
specifying measures to be taken to ensure historical
resource protection during ESP construction activities.
The KWRA shall ensure that the agreed upon protection
measures are implemented prior to ESP construction
activities.

b)   The Site Preparation III predesign report developed by
the Lead Design Engineer shall address landscaping for the
New Resthaven Cemetery and be provided to the SHPO for
review and comment.  At the 30% design and specification
completion point of the appropriate design contract,  the
MWRA shall submit plans and specifications to the SHPO
specifying the landscaping plan for the New Resthaven
Cemetery property.  The MWRA shall ensure that the agreed
upon landscaping changes to the New Resthaven Cemetery
property are implemented.

c)   Prior to alteration of the Farmhouse, the MWRA shall
contact the Historic American Building Survey (HABS),
a division of. the National Park Service, to determine what
material shall be required to adequately document the
Farmhouse to assure a permanent record of its present
appearance and history.  The MWRA shall document the
Farmhouse in accordance with the HABS specifications, and
all documentation must be accepted by HABS prior to alter-
ation of the Farmhouse.  Three copies of this documentation
shall be made available: one copy to the SRPO for inclusion
in the Massachusetts Archives, one copy to the National Park
Service for inclusion in the Library of Congress, and one
copy for MWRA Archives.

d)   Prior to alteration of the Hill Prison, the MWRA shall
contact the Historic American Building Survey (HABS), a
division of the National Park Service, to determine what
material shall be required to adequately document the Hill
Prison to assure a permanent record of its present
appearance and history.  The MWRA shall document the Hill
Prison in accordance with the HABS specifications, and all
documentation must be accepted by HABS prior to alteration
of the Hill Prison.  Three copies of this documentation
shall be made available: one copy to the SHPO for inclusion
in the Massachusetts Archives, one copy to the National Park
Service for inclusion in the Library of Congress, and one
copy for the MWRA Archives.

e)   The Primary Treatment Plant Construction predesign
report developed by the Lead Design Engineer shall address
all rehabilitation measures to be performed to the Steam
Pumping Station and be provided to the SHPO for review and
comment.  At the 30% design and specification completion
point of the appropriate design contract,, the MWRA shall
                            - 2 -

-------
submit specifications to the SHPO identifying rehabilitating
measures for the Steam Pumping Station.  The MWRA shall
ensure that the agreed upon rehabilitation measures to the
Steam Pumping station be carried out in accordance with The
Secretary of the Interior's Standards for Rehabilitation''^
Guidelines for Rehabilitating Historic Buildings.	

     Prior to alteration of the equipment in the Steam
Pumping Station, the MWRA shall contact the Historic
American Engineering Record (HAERJ, a division of the
National Park Service, to determine what material shall be
required to adequately document equipment in the Steam
Pumping station to assure a permanent record of its present
appearance and history.  The  MWRA shall document the
equipment in the steam Pumping Station in accordance with
the HAER specifications, and all documentation must be
accepted by HAER prior to alteration.  Three copies of this
documentation shall be made available: one copy to the SHPO
for inclusion in the Massachusetts Archives, one copy to the
National Park Service for inclusion in the Library of
Congress, and one copy for MWRA Archives.

t)   The Site Preparation predesign report developed by the
Lead Design Engineer shall address moving and/or alteration
of the Superintendent's House.  The MWRA shall provide the
SHPO the predesign report for review and comment.
The predesign report shall contain, at a minimum, a site
plan, specifying plans for moving the Superintendent's House
to a new location, adjacent landscaping and interior modifi-
cations.  At the 30% design and specification completion
point of the appropriate design contract, the MWRA shall
submit plans and specifications to the SHPO specifying
alterations to the Superintendent's House.  Prior to moving
or altering the Superintendent's House, the MWRA shall
contact the Historic American Buildings Survey (HABS) to
determine what material shall be required to adequately
document the Superintendent's House's original setting and
context.  The MWRA shall document the Superintendent's
House's original setting and context in accordance with HABS
specifications and all documentation must be accepted by
HABS before the building is moved.

The MWRA shall move the Superintendent's House in accordance
with recommended approaches as specified in Department of
the Interior's Moving Historic Buildings, and in consul-
tation with the SHPO.  The work shall be performed by a
professional mover who has the capability to move historic
structures properly.  The SHPO shall reevaluate the property
after completion of rehabilitation and make recommendations
as to its further eligibility for inclusion in the National
Register.
                            - 3 -

-------
g)   The MWRA shall ensure that if any suspected historical
or archaeological resources are unearthed on Deer Island
during the construction phase of the project, the SHPO shall
be contacted prior to further alteration or removal of such
historical or archaeological resources.  The MWRA shall
ensure that historical or archaeological resource protection
and mitigation measures are developed for such historical  or
archaeological resources in consultation with the SHPO, and
such protection and mitigation measures agreed upon by the
MWRA and the SHPO are implemented prior to continuing
construction activities which would have detrimental  effects
on such resources.
II.  Off-island utility Supply

     Review of power, gas and water supply route alter-
natives shall be conducted by the MWRA with respect to
Section 106 requirements.  The MWRA shall submit copies of
the Off-Island Utility Supply report to EPA, DWPC and the
Massachusetts SHPO for their review.  The report shall
include detailed evaluation of alternative utility routes
with documentation of known historic and archaeological
resources, including historic shipwreck sites, which may be
affected by the installation and/or presence of the
utilities.  An evaluation of anticipated impacts to the
resources and recommendations for further survey and
construction mitigation measures shall also be included.

The MWRA shall ensure that potential adverse construction
effects on any historic/archaeological resources are
minimized or avoided through appropriate preliminary and
final design and construction specification.  If requested
by the SHPO, the MWRA shall submit plans and construction
specifications to the SHPO for review and determination of
effect. The SHPO shall determine the effect of the proposed
construction activities on eligible resources and shall
advise the MWRA as to the acceptability of the plans and
specifications or the need for design changes.  If a
determination of adverse effect is made, the MWRA shall
ensure that protection or mitigation measures are developed
in consultation with the SHPO, EPA and DWPC and that such
protection or mitigation measures agreed upon by all parties
are implemented prior to construction.


III. Marine Outfall Diffuser Construction

     Geotechnical/Geophysical surveys will be performed to
aid in determining the outfall diffuser location.  As part
of these surveys, remote reconnaissance (e.g. side-scan
sonar, magne tome try) will be performed to further define the
potential for underwater historical/archaeological resources
in the selected outfall diffuser location.  The MWRA shall
                            -  4  -

-------
ensure that once additional geotechnical/geophysical work
has accurately defined the outfall diffuser location, any
additional marine historical/archaeological surveys needed
to verify the existence of any'potentially significant
historical/archaeological resource will be conducted in the
defined outfall diffuser location.  The MWRA shall ensure
that the survey of the outfall diffuser area is conducted in
accordance with Secretary of the Interior's Professional
Qualification Standards (48 FR 44738-9), Secretary of the
Interior's Standarc
s and Guidelines for Identification (48
FR 44720-23) and National Park Marine Surveys NPS Bulletin
120 guidelines.  The MWRA shall ensure that the scope of
work for the marine historical/archaeological survey is
developed in consultation with the SHPO.  If the marine
survey verifies the existence of properties which may be
eligible for inclusion in the National Register of Historic
Places, the MWRA shall ensure that protection measures are
developed in consultation with the SHPO, EPA and DWPC, and
that such protection measures agreed upon by all parties are
implemented prior to outfall diffuser construction.


IV.  Fore River Staging Area Activities and Long Term
     Residuals Management

     The Fore River Staging Area (FRSA) comprises approxi-
mately 180 acres of land on the west bank of the Weymouth
Fore River in Quincy and Braintree, formerly owned by
General Dynamics for the purpose of shipbuilding and now
owned by the Massachusetts Water Resources Authority.
The following MWRA projects, which may be undertaken on
portions of the FRSA, are subject to this Memorandum of
Agreement.

     •    On-Shore Water Transportation Facilities

     •    Construction Staging and Materials Laydown Area

     •    Short Term Sludge Management

     •    Long Term Residuals Management System

     The MWRA is in the process of siting facilities  for
long term management of wastewater treatment residuals.
Although the FRSA is one site being considered for these
facilities, other sites are also being evaluated.   Resources
at the FRSA and at other locations may be affected by the
Long term Residuals Management System and are  subject to
this Memorandum of Agreement.

     The following measures shall be implemented for any
resources which may potentially be affected by the afore-
mentioned projects, to ensure that significant historical
and archaeological resources are accounted for-with respect
                             - 5 -

-------
to and in accordance with the requirements of Section 106 of
the National Historic Preservation Act and 36 CFR 800.

a)   The MWRA shall conduct historical resources surveys in
accordance with the Secretary of the Interior's Standards
and Guidelines for Archeology and Historic Preservation and
in consultation with the SHPO,' EPA and DWPC, for the purpose
of determining whether any resources meet the eligibility
criteria for inclusion in the National Register of Historic
Places.  The proposed scope of work for each survey shall be
submitted to the SHPO for review and approval prior to
implementation.  The MWRA shall ensure that these surveys
are undertaken in accordance with Secretary of the
Interior's Professional Qualification Standards (48 FR
44738-9), and Secretary of the Interior's Standards and
Guidelines for Identification (48 FR 44720-23).

     A written report describing the results of the survey
shall be submitted to the SHPO and EPA £or review as a basis
for applying the eligibility criteria.  The report shall
include the results of the documentary research, field
investigations and applied National Register criteria,
36 CFR Part 63; and the report shall contain recommendations
on the significance of identified resources and any other
specific information and plans requested by the SHPO.

b)   The SHPO shall review the historical resources  survey
reports submitted by the MWRA and shall advise  the MWRA and
EPA on the eligibility of the respective properties  and
their resources.

c)   If the surveys verify the existence of  resources  which,
in the opinion of the SHPO, may be eligible  for inclusion in
the National Register of Historic Places, the MWRA  shall
ensure that potential adverse construction  effects  on these
resources are minimized or avoided through  development and
evaluation of all feasible design alternatives,  taking into
account historical/archaeological resources, and appropriate
preliminary and final design and construction  specification
of the selected design alternative.   The  MWRA  shall submit
plans and construction specifications to  the Massachusetts
SHPO for review and determination of effect.

d)  The SHPO shall determine the effect of  the proposed
construction activities on eligible  resources  and advise the
the MWRA as to the  acceptability of  the plans  and specifi-
cations or the need  for design  changes.   If a determination
of adverse effect  is made,  the  MWRA shall ensure that
protection or mitigation  measures  are developed in consul-
tation with the SHPO, EPA and DWPC and that such protection
or mitigation measures  agreed upon by all parties are imple-
mented prior  to construction.
                             - 6 -

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V.   Review of Submitted Materials

     Within 30 days of receipt of material requiring review,
comment and/or approval by the SHPO, the SHPO shall notify
the MWRA in writing of its approval of said material or,  if
the material is not approved, of the specific deficiencies
in the material.  Failure by-the SHPO to respond within 30
days of receipt of any material or documents from MWRA shall
be deemed to constitute full approval of such documents
under the stipulations herein noted.
VI.  Resolution of Disputes

a)   Should the SHPO or Council object within 30 days to any
plans or specifications provided pursuant to this Memorandum
of Agreement, the agency official and MWRA shall consult
with the objecting party to resolve the objection.  If the
.agency official determines that the objection cannot be
resolved,' the agency official  and MWRA shall forward within
10 days all documention relevant to the dispute to the
Council.  Within 30 days after receipt of all pertinent
documentation, the Council's Executive Director will either:

     1.  refer the matter to the Chairman of the  Council
         pursuant to 36 CFR Part 800  6(b)(7); or

     2.  provide the agency official  with recommendations,
         which the agency official shall take into account
         in  reaching a final decision.

b)   At  any  time during implementation of the measures
stipulated in this Memorandum of Agreement,  should an
objection  to any such measure  be raised by  a local
government or a member of the  public, the agency  official
and MWRA shall take  the objection into account  and consult
as needed with the objecting party, the SHPO, or  the Council
to resolve the objection.


VII. Nomination  of Properties

      The MWRA intends  to nominate all appropriate properties
 for inclusion in the National Register upon project
 completion.
                              - 7 -

-------
     Execution of this Memorandum of Agreement and implemen-
tation of its terms evidence that EFA has afforded the
Council an opportunity to comment on the construction of
Secondary Wastewater Treatment Facilities on Deer Island and
its effect on the Superintendent's House, New Resthaven
Cemetery, Hill Prison, Steam Pumping Station and Farmhouse
properties and the potential,effects of this and related
construction activities on unknown historical and archaeo-
logical resources located on Deer Island, in the Outfall
Diffuser area, at the Fore River Staging Area and at
resources which may be impacted by the Long Term Residuals
Management System; and that EPA has taken into account the
effects of the undertakings on historic properties.
                             - 8 -

-------
EPA will ensure that the stipulations incorporated in this
MOA will be carried out by MWRA in compliance with 36 CFR
Part 800, regulations implementing Section 106 of the
National Historic Preservation Act (16 U.S.C. 470 f).
ADVISORY COUNCIL ON HIS'
BY:
                             PRESERVATION
                                     Date:
      Chairman
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION I
BY:
                                      ate
                                          ;  3/f
      Michael R. Deland
      Regional Administrator
MASSACHUSETTS STATE HISTORIC PRESERVATION OFFICER
BY:
                  \ a
      Valerie  A.  Talmage
      Executive Director rSHPO)
      Massachusetts Historical Commission
                                     Date:
 Concur:
 MASSACHUSETTS WATER RESOURCES AUTHORITY
 BY:
                                      Date:
       Paul F. Levy   /
       Executive Diretrcor
 MASSACHUSETTS DIVISION OF WATER POLLUTION CONTROL
 BY:
       Thomas C. McMahon
       Director
                             - 9  -

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7.2  TABLE CHANGES (Where indicated, see following pages.)

Page 4-76.  Table 4.3-5. MASN Monitor Locations and Monitored Pollutants.
                              (Line 6, deleted.)

          (Lines  9  and  13  -  "PM-10"  deleted  from Pollutants Monitored
                 for  Chelsea and Quincy Monitoring  Locations.)

Page 4-81.  Table 4.3-8. Rowe Quarry Representative Ambient Air Quality
Monitoring Data.

              (Line 3 - "PM-10" deleted from Pollutants Monitored
                     for the Chelsea Monitoring  Location.)

Page 4-83.  Table 4.3-9.  Stoughton Representative Ambient Air Quality
Monitoring Data.

              (Line 6 -"PM-10" deleted from Pollutants Monitored
                     for the Quincy Monitoring Location.)

Page 4-85.  Table 4.3-10.   Quincy FRSA Representative, Ambient Air Quality
Monitoring Data.

              (Line 6 -"PM-10" deleted from Pollutants Monitored
                     for the Quincy Monitoring Location.)

Page 5-37.  Table 5.4-2.  Constituents of Concern Exceeding Ten Percent of the
DEQE TEL (24-Hour AAL)  Guideline Based on the Worst-Case 24-Hour Maximum
Concentration at Each Site.

        (Last  line  corrected as indicated  at the end  of table  changes.)

Page 5-57.  Table 5.5-2.  Walpole MCI Predicted Concentrations on Stop River
Due to a Landfill Leak.

        (Corrected as indicated in bold at the end.of.table changes.)

Page C.2, Table C.1.   Walpole MCI Sensitive Receptors.

               (Line 2  Sullivan Stadium,  corrected to have an x
                          under Column 4, Traffic.)
                                     7-16

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               TABLE 5.4-2. CONSTITUENTS OF CONCERN EXCEEDING 10 PERCENT OF THE DEQE TEL
           GUIDELINE BASED ON THE WORST-CASE 24-HOUR MAXIMUM CONCENTRATION AT EACH SITE
Stoughten (150
(Percent of
Cmtltuenta of Concern
Amaonla
Cadalua (Bin.) (1)
CadBlm (MX.) (1)
ChreBlw VI (Bin.) (1)
airoalui VI (BU.) It)

Hydrogen Chloride
Hydrogen Fleurlde
Hydrogen Sulf Id*
Pentechloraplwnot
Phosphoric Acid
s|e Sulfurle Acid
Not
Dry Ceapost
M> 31
«1 NO
1 M
 11
00
6.8K-OI
!.7K*00
1.00E-02
2.70E-01
2.70OOO
OTf: 	
(1) BASED ON EPA KSIDUAIS CHARACTERIZATION (SECTION 3.1)

CAOHIUM CONCENTMTION IS IASEO ON 98.6 PfKENT KNOVAl EfMCIEtCT
AND HTDROCEN CHLORIDE IS IASED ON 90 PERCENT RENOVAl EFFICIENCY

ND - NOT DETECTED IN THE STACK EN ISS IONS

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TABLE 5.5-2.  UALPOLE MCI PREDICTED POLLUTANT CONCENTRATIONS  IN STOP  RIVER  DUE TO A LANDFILL LEAK


Metals
Arsenic
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Notes:

Assumed
Highest Background
Leachate Concentration
Concentra- in Stop River
tion, C, Impoundment CD
87(a) 5*
310(a) 1.5*
U20(a) 1.5
1,300(b) 2.5*
50(a) 0.1*
46(a) 5
30(b) 3*
All units in ug/1
* Concentration exceeds


Proposed EPA
Mass Fresh Fresh
Average Flow

EPA EPA Predicted Concentrations at
Fresh Fish Winter Street Bridge
Surface Water Acute Chronic Consumption 50% Leakage 10jS Leakage
(e) Standards Criteria*fJ Criteria*** Criteria In One Cell In One Cell
50
1
11
1
0.012
—
0.12

or is at limit
Duration of increased concentrations in


(a) Source: MDC, 1983
(b) Source: MWRA, ISPD

, VII, 1989
(c) "Lowest observed effect level" for

(d) Assuming hardness =
850(c)
0.50(d)
387(d)
7.9(d)
2.U
260
0.17(d)

of applicable
48(c) 0.0175 5.1« 5.0«
0.27(d) — 2.0« 1.6*
46(d) 3,433,000 2.2 1.7
0.3Kd) — 4.7« 3.0*
0.012 0.146 0.20« 0.12*
35 -- 5.1 5.0
0.12 - 3.1« 3.0*

water quality criteria
^% Leakage
In One Cell
5.0*
1.5*
1.6
2.7*
0.11*
5.0
3.0*


river equals duration of leak






pentavalent arsenic
16 mg/1 (measured by MWRA in
(e) Background concentration was assumed to be equal

(f) Sources: U.S. EPA,
1986

surface water at Site 5)
to one-half of the detection limit





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7.3  FIGURE CHANGES (Where indicated, see following pages.)

Page 3-36.  Figure 3.2-6.  Schematic of Cap and Liner Systems.

               (Natural liner changed from one foot to two feet
                  as  indicated at  the end of  figure  changes.)

Page 3-48.  Figure 3.4-3.  Walpole MCI Existing and Proposed Utilities.

                 (Existing water line changed as indicated at
                          the end  of  figure changes.)

Page 5-100.  Figure 5.9-1. Potential Exposure Pathways for Landfill Sites

         (Figure corrected as indicated at the  end of  figure changes.)
                                     7-19

-------
   <
                   ^vvvv"v>^/   /T°PsoilN«A •> v ^x v>v>v
                   "?/s\fs'\/s^.ts'^/s'?ls^/s^/s^./s"?/s'?/s^/s'?/s'\
                   /V>^>/\v:-v^^/^V^vMA-v-'>^'V^
                   •v^x'^N/Vx/X^xW^'k/k/v^
                   /^>/^/^>/^/^^_        /^y^>/^>/^>/^^/
                      : Filter Fabric
                    Sand Drainage Layer
         •^o^/^^cj Intermediate Soil' Cover^^.^.^pe>


                      Daily Soil

                        RESIDUALS
                                                  T
                                                   2'
                                                            I
                                                   r
                                                        =k
Leachate Pipe
                   Sand Drainage Layer
   LU
   cr
   LU
                    Sand Drainage Layer
                                  n
Source: MWRA, RMFP, Landfill, 1,1 988
                       in-Situ Soil
                                                  li
                                                       60 Mil Membrane
                                                 r-6"
                                                  2'
                                                 i
         FIGURE 3.2-6. SCHEMATIC OF CAP AND LINER SYSTEMS

-------
   SCALE IN METERS
1000      0      1000
    SCALE IN FEET
   FIGURE 3.4-3. WALPOLE -MCI EXISTING AND PROPOSED UTILITIES
LFGEKIP

PROPOSED SEWER
EXISTING WATER
EXISTING ELECTRICITY

-------
      Landfill
                                                                              EXPOSURE ROUtE
   Air Emissions  	  Inhalation of gases and particles



           Leachate  	   Direct Contact


                   I
deposition surface   rP'9;°J|°n
          runoff    tnrougn
                  groundwater

                  J	
                   Contaminated  I-	   Ingestlon of Water
                   Groundwater                                                _     ,  _,  .   ... ^ ,  .,
                  	|	  Dermal Contact/Inhalation
                   I                                                          when Bathing

                  discharge to
                  surface water


                 	1	   Ingestlon of Water
      Contaminated                                                            Dermal Contact/Inhalation when
      Surface Water   	   Bathing
     	1	   Dermal Contact during
          I                                                                   Recreational Use

         bioconcentration
          in fish

          J	
          Contaminated 	   Ingestion of Fish and Shellfish
          Fish & Shellfish
                        FIGURE 5.9-1  POTENTIAL EXPOSURE PATHWAYS FOR LANDFILL SITES

-------
     APPENDIX  A




HATER TRANSPORT MODEL

-------
                                  APPENDIX A
                               TRANSPORT MODEL
A.1  INTRODUCTION
A computer program was developed to calculate the distribution of
concentrations of a constituent introduced in an aquifer in order to simulate
a leak in the residuals landfill.  The aquifer is assumed to have uniform
properties and the flow is uniform along the longitudinal axis (x axis).  The
groundwater flow is determined from user-specified values of the regional
hydraulic gradient and the hydraulic conductivity or transmissivity of the
aquifer.  The constituent is assumed to be neutrally buoyant, which is a valid
approximation for most constituents at low concentrations.  Adsorption of the
solute to the soil matrix is accounted for through a user-specified
retardation factor.  This model can be used for initial evaluations of the
extent of a contaminant plume.

A.2  MODEL DEVELOPMENT

Advective transport of contaminants in an aquifer with undirectional flow (in
the x direction) can be described by the three-dimensional advection-
dispersion equation:

                  222
 3cA3cn3cn3cri3c.p              M»
where:   c is the concentration of contaminant (mg/L),

     A = =^ = — §- =   KPJ   is the effective pore velocity (ft/d),
         Rd   "  d    n  d
     u is the actual pore velocity (ft/d) in the x direction,

     q is the specific discharge (ft/d),

     n is the porosity of the soil,

     K is the hydraulic conductivity (ft/d),
     J is the regional hydraulic gradient in the x direction,
              Pb K
     R . = 1 + — — -  is the retardation factor,
      d         n
         p.  is the bulk density of the soil,

         Kd is the distribution coefficient,

     D* =  a * u is the dispersion coefficient in the i direction (ft2/d),

         i is the longitudinal (L or x), transverse (T or y), or vertical
         (V or z) direction,

         a. is the dispersivity in the i direction (ft), and

         X is the decay or degradation coefficient.
                                     A-1

-------
For initial conditions zero concentration  throughout  the  aquifer  is  usually
specified and for boundary conditions zero concentration  far  away from the
source and no flux at the aquifer surface  or  bottom is used.   Under  these
conditions the above equation (1) has a number  of analytical  solutions
depending on the nature of the contamination  source (Walton,  1984).

A.3  MODEL SOLUTION

Because the aquifer dimensions are very large compared to the dimension of the
source (a landfill cell), the solution for an instantaneous release  of mass  m
of contaminant from a point source at XQ,  yQ, ZQ is (Walton,  1984):
                   c(x,y,z,t) = —- .2
                                8 n372 /
Wv
         (x-ut-x )     (y-y)    (z-z )
where:    m =  -r™- is the equivalent mass of contaminant.
               nRd

While equation (2) is valid only for an instantaneous point source injected
into an infinite depth aquifer, it can be used to develop analytical solutions
for other contamination sources.  For example, in order to simulate a breach
in the liner of the landfill at the proposed Walpole-MCI Site, a continuous
box source of contamination was assumed to be released into a finite depth
aquifer.  The analytical solution for this special case can be derived by
integrating equation (2) over time and space and applying a number of image
sources with respect to the aquifer surface and bottom.  The computer program
developed for the MCI-Walpole landfill analysis is based on this analytical
solution.  A box of dimensions 25' x 25'  x 10' was assumed throughout the
analyses.  Other assumptions used in the surface water and groundwater
evaluations are outlined below.

A. 4  SURFACE WATER ASSUMPTIONS AND CALCULATIONS

The groundwater model was utilized to evaluate potential water quality impacts
to the Stop River and was developed using the following assumptions:

     •    The hydraulic conductivity was conservatively assumed to equal 5
          feet per day.  A complete discussion of the basis for this
          assumption is contained in Chapter 5 of this Final SEIS.  An average
          hydraulic gradient of 0.0178 was derived from the extensive
          observation well data provided by MWRA (MWRA, RMFP, FEIR, 1, 1989).

     •    Groundwater was assumed to travel in a straight line from the
          landfill to the Stop -River for a distance of approximately 2,500
          feet.  The average saturated thickness of the aquifer was estimated
          as fifty feet.

                                      A-2

-------
          Retardation and dispersion were the only processes assumed to affect
          the transport of contaminants.   No precipitation or permanent
          adsorption was assumed to occur; thus the total mass of pollutants
          in the system is conserved.  Retardation factors were derived from
          the literature and are listed in Table A.1 (Baes and Sharp, 1983).

     •    An aquifer porosity of 0.25 was chosen as a representative value for
          the soils found on-site.  The dispersivity values developed for the
          model were based on the length scale of groundwater flow and on
          existing field conditions.  These values are contained in Table A.2.

     •    The leachate concentrations used previously in the Draft SEIS were
          also used here.  The leachate flow used in the analysis corresponds
          to a total flow of 32,000 gallons per day, which was calculated as
          outlined in Section 5.5.2.2 of the Draft SEIS.

     •    In order to investigate the worst case scenario, a landfill failure
          of fifty percent was simulated throughout the analysis.  In
          addition, the duration of the landfill leak was assumed to be 10
          years, approximately one-half the active life of the entire
          landfill.  While a landfill leak is unlikely, an undetected fifty
          percent breach occurring over ten years is particularly improbable.

The distribution of contaminants across the plume was used to determine the
leachate pollutant mass loading to the Stop River.

Concentrations above background were calculated using the following equation:

                                   CSR  = WL

                                        QSR

Leachate concentrations (CL) were averaged over the width of the plume and
multiplied by the plume flowrate (QL) to determine the mass rate of pollutants
entering the river.  Stop River concentrations above background (CSR) were
derived from dividing the mass rate by the 7Q10 flow -(QSR)-

A.5  GROUNDWATER ASSUMPTIONS AND CALCULATIONS

The model inputs and assumptions are the same as in the surface water analysis
with the following exceptions:

          The hydraulic conductivity values used in the model were 1.9 ft/day
          and 2.4 ft/day for the analyses of Wellfields //1 and //2,
          respectively.  These values represent a weighted average of the
          values used in the MWRA model (MWRA, RMFP, FEIR, 1, 1989).

     •    The hydraulic gradient was estimated as 0.03 based on an analysis of
          groundwater contours.  Water level measurements also show that the
          average saturated thickness in the region near the private wells  is
          70 feet.
                                     A-3

-------
         TABLE A.I  RETARDATION FACTORS USED IN Halpole-MCI ANALYSIS
Metal
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Retardation Factor
45
18000
28
14000
650
37
18
700
Source:  Baes and Sharp, 1983.
                   TABLE A.2 DISPERSIVITY VALUES (in  feet)
Dispersivity
dx
"y
Z
Stop River
250
50
10
Wellfield #1
80
10
2
Wellfield 92
120
20
5
                                      A-4

-------
     •    Since the amount of dispersion depends on the distance travelled,
          dispersivity values were adjusted to reflect the reduced length
          scale of groundwater flow (Table A.2).

Although the model accounts for contaminant dispersions and retardation, it
assumes that the wells are centered along the path of contaminant transport.
It does not account for flow which could be lost to the Stop River or to any
other locations, and is therefore conservative.

A.6  TIME OF TRAVEL CALCULATIONS

In response to commentors on the Draft SEIS and as part of the expanded
technical evaluation of the MWRA-preferred plan, additional analyses of the
groundwater travel time have been prepared for this Final SEIS.  Following is
a discussion of the methods and assumptions and a summary of the additional
travel time estimates.

The groundwater time of travel between the landfill and the prison wells to
the west of the Stop River was estimated in the Draft SEIS.  As discussed  in
the Draft (p. 5-54), the time required for groundwater to travel from one
location to another is dependent upon the distance travelled (L) and the
groundwater velocity (V).  The velocity is a function.of the hydraulic
conductivity (K) and porosity (n) of the aquifer as well as the slope (dh/dx)
of the groundwater table.  Velocity of groundwater can be calculated using the
equation:
                                       K dh
                                   V = n dx


Travel time is calculated by dividing the distance travelled by the
groundwater velocity.  For the Draft SEIS analysis, groundwater elevations
measured at MWRA monitoring wells 13 and 2 (221.8 feet and 148.6 feet,
respectively) and the distance between the wells (approximately 4,270 feet)
was used to develop an average value of the water table slope.  A value of
0.25 was used in the equation for soil porosity.  The hydraulic conductivity
was determined based on a review of boring information, slug test data and
calibration of the Zone II groundwater model as shown, in the Draft EIR
(Volume 2,  page A-68).  A value of five feet per day was chosen as a
conservative average of the conductivities of the different soils along the
flow path.   With these numerical values, the travel time of groundwater from
the top of the landfill (MW-13) to the prison well field (MW-2) was calculated
to be approximately 30 years.

The above analysis assumes a conductivity of five feet per day along the
entire flow path.  A similar but more detailed approach is to superimpose  the
flow path onto the post calibration hydraulic conductivity field developed by
the MWRA model and presented in Appendix B of the Final EIR (Volume I).  The
effects of pumping can also be included by calculating the hydraulic gradient
which is induced by pumping conditions.  In this analysis, the gradient was
calculated using groundwater contours developed by the MWRA model under high
safe yield pumping rates as illustrated in Figure B-320 of the Final EIR.
Using the above equation, the hydraulic conductivity values for the different
                                     A-5

-------
 segments along  the  flow  path  can  be used  to calculate  the  travel  time  for each
 segment.  These times  can  then  be summed  to produce a  travel  time for  the
 entire path.  The advantage of  this approach  is that the effects  of  changing K
 values in different regions is  included.  For example, some comments have
 indicated that  slug tests  conducted at  the base of the hill (wells 7,  8 and
 10)  showed conductivities  of  2-20 ft/day.  Using 20 ft/day for segments in
 this area (with the other  conductivities  as per the original  model)  yielded a
 travel time of  approximately  137  years.   The  travel time calculated  using the
 original calibrated conductivity  field  was nearly 150  years.  Thus,  30 years
 appears to be a conservative  estimate of  the  time of travel of groundwater
 between the landfill and the  prison wells.

 A separate analysis was performed in order to check the assumed value  of
 hydraulic conductivity.  The  flow per unit width (Q1)  at any  section of an
 aquifer can be  expressed as:

                                    Q'  = IL

 in which I  represents  infiltration and  L  is the distance from the section to
 the  groundwater  divide.  By substituting  Q'=bKdh/dx, in which (b)  is the
 saturated thickness, the following expression is obtained:

                                  K=    IL
                                      b dh/dx

The saturated thickness (b) varies on site from 20 feet to 70 feet.  The
groundwater slope (dh/dx) calculated previously was again employed.  Estimates
of infiltration were derived from the runs of the HELP model and the Zone  II
model as shown on pages A-78 and A-79 of the DEIR volume 2.  Using the
distance (L) and the thickness (b) applicable at different sections along  the
flow path a range of conductivity values was determined.  At all sections,  the
K values were less than the five feet/day assumed previously.  A worst-case
scenario which assumed an average saturated thickness of 50 feet and an
infiltration of eight inches/year (the highest estimate provided for any on-
site area) over the entire site yielded a K of 11 feet/day.  The time of
travel for this worst case was found to be 15 years.  Based on the above
analysis and the available information five feet/day is a reasonable estimate
for the hydraulic conductivity.

The results presented above do not support the claims that higher conductivity
values should be used in the time of travel analyses.  While the prison
uellfield has conductivities approaching 85 feet/day, time of travel estimates
must account for the significant amount of low permeability soil between the
site and the wellfield.   There is no evidence that suggests that 85 feet/day
may be applicable for the entire travel distance from the landfill site to  the
prison wellfield.  In summary, the above analyses support the original
estimate of hydraulic conductivity and suggest that 30 years is a conservative
estimate for the groundwater time of travel.

Therefore, by using the  analysis as presented in the Draft SEIS, an estimate
was derived for the groundwater travel time between the landfill and the Stop
River.  Since the river  is adjacent to the prison wells, the same values of
hydraulic conductivity,  hydraulic gradient and porosity were used in the


                                     A-6

-------
analysis.  With these values, the groundwater travel time was estimated as
19 years.  A similar analysis was performed for the two private wellfields
which were included in the expanded technical evaluations.  However, in this
case the values of conductivity and gradient were adjusted to reflect the
soils and topography of the area .surrounding the wells and the adjusted values
are presented in section A.5 of this Final SEIS.  The groundwater travel time
between the landfill footprint and private wellfields 1 and 2 was estimated as
nine years and eleven years, respectively.  However, as noted in Sections 3.3.
and 3.4, the predicted time of travel of groundwater contaminants ranges from
hundreds to thousands of years due to the effects of retardation and
dispersion of the leachate contaminants.

A.7  ESTIMATES OF WELL SPACING

In order to estimate the spacing and number of observation wells required for
environmental monitoring, an analysis was performed to approximate the
distribution of contaminants in a leachate plume.  The computer program
outlined above was coupled with the following statistical approach.  The
transverse standard deviation of concentration distribution for an
instantaneous injection in a uniform groundwater flow can be determined using
the expression:
where  o™  is the transverse dispersivity and L is the length travelled.
Assuming  OT  = L/50, the standard deviation becomes:

                                   o = 0.2L

A spacing of three to four times the standard deviation will result in
detection levels between ten to thirty percent of the plume centerline
concentration.  For example, at L = 800 feet from the source, a spacing of 480
to 640 feet would be predicted.  The preliminary monitoring well confirmation
was approximated by measuring the distance from the observation well location
to the center of the landfill footprint.
                                     A-7

-------
              APPENDIX B




ALTERNATIVE LANDFILL CAPACITY SCENARIOS

-------
 8
 7-
 6-
 5-
 4-
 3-
 2-
                                                                                       4
                                                                                           *
                                                                                           X
                                           /
                                              /
                                                      i
                                                         t
                                                             t
                                                                 t
                                                                 X
                                                                        *
                                                                            4
                                                                                4
                                                                   1. 33 AVAILABIE CAPACITY
                                                                                             8 YEAR LIFE
                                                                                              9 YEAR LIFE
                                                                                              11 YEAR LIFE
19*6
                    2000
2006
2010
2011
2020
•3:1 MIX RATIO
  :1 MIX RATIO




    YEAR
                      1:1 MIX RATIO
             FIGURE B.I. LANDFILL LIFE AT 20% SOLIDS (WITH 25% HEAT DRIED PELLETS)

-------
7-
i 4-
o
1
1 3.
2-
m
0-
19
X
X
xxX/"
^X^ X^ ^-^*^* 1.33 AVAILABLE CAPACITY
-^^
95 2000 2005 2010 2015 20
MIX RATIO 	 91 MIX RATIO — — 	 1:1 MIX RATIO
                                                                       8 YEAR LIFE
                                                                       10 YEAR LIFE
                                                                       13 YEAR LIFE
                      YEAR




FIGURE B.2. LANDFILL LIFE AT 20% SOLIDS (NO HEAT DRIED PELLETS)

-------

1.3-
1.2-
1.1-
1 -
0.9-
0.8*-
0.7I-
0.6-
0.5 »-
0.4 >-
0.3»-
0.2-
0.1^
19
1.33 AVAILABLE CAPACITY S
/
/ /'
S s'' '' ^
X x'-^X
X X^T"^
Xx^X
S s' *'
//^^
/^

1 ^1
95 2000 2001 2010 2019 20
YEAR LIFE







20
^ — —3:1 MIX RATIO
             	2:1 MIX RATIO



                           YEAR



FIGURE BJ. LANDFILL LIFE AT 29% SOLIDS (WITH 25% HEAT DRIED PELLETS)
1:1 MIX RATIO

-------
              1.4
I
•I
*
n
>
r

      I
      1
                 1995
3:1 MIX
                                                                                                      2020
2:1 MIX RATIO


   YEAR
                                                                         •1:1 MIX RATIO
                             nGURE B.4. LANDFILL LIFE AT 29% SOLIDS (NO HEAT DRIED PELLETS)

-------
   APPENDIX C




COW4ENT LETTERS

-------
                        BRADY a MONAC. P.C.
                                ATTOANCTI AT t*W
luat M WMDT
eumnm «. XOMAC
   March 1.  1989
   Ma.  Marsla  Rolford
   MWRA Public Affair*
   Charlaatown Navy Yard
   100  First Avenue
   Beaten.  HA   02139

   CERTIFIED MAIL  - RETURN RECEIPT REQUESTED  P929623564


   RE:   Telephone  Conversation - MCI Walpele Site

   Dear Ma. Hoi ford:

   I write  with reference to our telephone conversation of February
   27,  1989 at approximately 12:35 PM wherein we diacuaaed the issue
   of siting a sludge dump at the NCI Walpele location.

   During our  conversation, which initially involved the use of
   chlorine by the MVRA at the Walpole site, you interned me that
   the  MWRA projected it would eoon be using sodium hyper chloride
   instead  of  chlorine as it is currently doing at the Deer Island
   facility.   Moreover, you intoned me that this chlorine has been
   known to cause  injury to humans, but that you did not expect it
   (chlorine)  to be used at the Walpele aits as it will not be used
   at the Dear Island site.                               !

   He then  went on to discuss the location of the sewer lines in
   proximity to the site.  Teu informed me that a person from the
   MWRA assigned to thia project spoke with Margaret Walker,
   Walpole'a acting town engineer, in the late aummer or early fall
   of 1988  about the location ot the sewer system.  According to
   you, Ms. Walker informed the MWRA that the sewer stopped at
   approximately Huntingten Avenue which is approximately 8000 feet
   from the intersection ot Main and winter Streets.  You also
   informed ne that Ms. Walker went on to say that the sewer line
   ends and that -the Town had no plans te extend the lines'.  I
   then made reference to • letter from John C. Rahn, a resident of
   Walpole, Massachusetts, which letter was dated December 28, 1988
   and  addressed to the Beard of Directors of the MWRA (copy,
   attached).   I informed you that Mr. Hahn confirmed sending this
   letter to the MWRA Board of Directors, Certified Mail. Return
   Receipt  Requested.  Seven members of the Board recieved this
   letter prior to its January 4, 1989 meeting (copies attached).
   In that  letter, Mr. Hahn verified with Mr. Wenger thet the
   additional  coat of two pumping stations and 10,500 feet of forced
Ma. Marsia Rolford
March 1. 1989
Page 2
main sewer were not part of the estimates which the MWRA  Included
in projecting the overall cost of the Rowes Quarry verses the
Walpole site.  According to Mr. Hahn, the conversation  took  place
between he and Mr. Wenger on December 27, 1988 at 4:15  p.m.   I
then asked you if it was true that Mr. Levy did not calculate
into the overall coat of constructing the MCI Site the  S3.000,000
figure which Mr. Wenger and Mr. Rahn discussed and which  Mr.
Wenger verified as the estimated cost to bring the sewer  lines up
to the site area.  You informed me that I was correct in  saying
Mr. Levy did not factor in the $2,000,000 coat.  I then stated to
you that Mr. Levy's representations to the Board of Directors of
January 4, 1989 "were incorrect for he failed to calculate the
$2.000,000 coat of running the sewer from its present location to
the site."  You replied "that's true."  Moreover, I went  on  to
say that the costs differential between the Rowea Quarry  site and
the Walpole site was not $5,000.000 but rather S3.000.000 because
of the $2.000,000 cost in sewer construction.  You stated that
was "correct" and you went on to say that Mr. bevy knew at the
January 4, 1989 Board Meeting that the $2,000.000 cost  were  not
factored into the estimate and that "the sewer was not  going to
the site".

Your statements to me are obviously in direct contradiction  to
the statements which Mr. Levy end the MWRA has publicly made
concerning the location of the sewer.  I refer specifically  ta
the articles  enclosed and Jerry Williams talk show.  When I
informed ybu of the same, you informed me that Mr. Levy relied
upon recommendations of the engineer (Black £ Veateh) and a
master plan implementation study done by SEA an engineering  firm
for the Town of Walpole which projected that the sewer  would be
located in that area by the year 1990.  I then reminded you  that
it waa you who had informed me that the MWRA peraon working  on
that particular site had personally contacted Ms. Walker  of  the
Walpole Engineering Department.

In light of our conversation it is readily apparent to  me that
Mr. Levy intentionally mislead the MWRA Board of Directors when
he failed to inform then that it would cost $2.000.000  to bring
the sewer line to the site and that the cost differential between
the Walpole site and the Rowes Quarry site was $5,000.000 when it
was in fact only $3,000.000.  Moreover, Mr. Levy has also
Intentionally misrepresented this fact in later public  statements
when he accused the Town of Walpole of changing it's plans so as
to not sewer the area once Walpole waa aited aa a sludge  landfill
facility.  This statement again Is incorrect for Mr. Levy, the
MWRA and Black and Veateh knew, for months prior to the January
4, 1989 Board meeting, that the town had no plans of extending

-------
                                                  OOO?-
                              3 Millbrook Avenue
                              Walpole, Massachusetts  02081
                              June 29, 1989

HAND DELIVERED
Comments to the EPA  EIS
Johnson Middle School
Walpole, Mass. 02081

DCar Agitated in the  EIS  concerning EOEA 5832, "a sizeable amount
of base analysis has been  compil ed" concerning the siting of
a sludge landfill.  The  EPA, however, fails to recognize that much
of the base analysis,  provided by the MWRA, is outdated, data has
been miscalculated and there are multiple data omissions.
     A more   realistic environmental representation would be found
in the documentation prepared by the Towns of Walpole and Norfolk,
which have been Ignored  in the  MEPA process, and now your own.
     The MCI Walpole site, proposed for sludge, dewatered. pelletized,
and grit and screenings  is entirely In a Zone III Aquifer.  Also,
seven acres of the site  have been designated as the Head of the
Neponset Sole Source Aquifer.   The MCI Bite should be immediately
withdrawn  from consideration on that fact alone.  Because it has not
been withdrawn, one can  conclude that  the considerable  amount of
base analysis is being used for political maneuvers only.  Further,
the MWRA continues to  change definitions,  and  data begins to look as
though  It is being made  to fit the site to fit the criteria.
     EPA correctly Identifies that "of  particular concern with
respect to the MCI landfill is the area of moderate and  high yield
aquifers immediately northwest of the Stop River impoundment.  EPA
identifies three wells in  this area.  Yet,  there has been no analysis
of what effect the landfill will have on these wells and their yield.
Monitoring wells planned after the landfill  Is constructed is
inappropriate.  Monitoring wells before the project may  more appro-
priately define Zone 2 .  What are the contingency plans should
wells be contaminated?  Where would this new source of water come
from?  What is the cost?  No one seems  to be concerned with  protecting
the multitude of private well sites within a one mile  radius of
the site.  Perhaps,  EPA  should examine  this  issue.A 1988 report
entitled "Private Well Contamination in Massachusetts  identifies
that private wells have been contaminated  In  one-third of Mass.
communities.  Is it any wonder that  landfills are the source of con-
tamination of the greatest number of private  residential wells? When
EPA states that "No water quality Impacts  are predicted at Spectacle
Island," why is this site not the priority site?  MWRA drilled 17 tests
wells on the MCI site during their "fact finding."  Nine were drilled
onsite, 8 offsite.  Shouldn't EPA require  a better study?  The MWRA
has publicly stated that the watershed  divide which passes through a
portion of the site is NOT a "priority  issue" for further study
until after the FEIR is prepared.  EPA  must make this a priority
and require MWRA to determine the exact location of the watershed
divide.  MWRA fails to recognize that the  site contains portions of
the Neponset Sole Source Aquifer.  Shouldn't  EPA put to rest the issue
of the actual divide between the Neponset  River Aquifer and the site?
Surely, even Rowe Quarry should be given greater consideration over
the MCI Walpole site.  Even by your  own adnission"even if the liner
system leaked, groundwater implications are not considered sig-
nificant because the concentrations  of  contaminants would be low
and groundwater in the area is not a significant resource."  What
proof do you provide that contaminants  would  be low?  Ground water
impact at the MCI Walpole site is however  a significant resource, to
the prisons, to private residents, to Southwood Community Hospital.
     EPA should make it their priority  to  promulgate regulations
which will regulate the disposal of  sludge based on sludge quality
and classify the MCI landfill site,  because of its close proximity
to the prison, because of the issue  of  ground water sensitivity,as
UNFIT for grit or screenings or any  form of sludge.
     EPA states " pollutant and odor emissions from a landfill are close
to the ground and therefore only the immediate vicinity is effected."
Can you imagine the prison riot at MCI  Walpole?  Is odor the same if
it is grit and screenings or pellets or dewatered sludge?  How exactly 1
EOEA going to require MWRA to provide a site  with no detectable odor?
will there be odor monitoring equipment onsite?  What is the cost?
     MWRA states that Boston Harbor  is  contaminated with pesticides,
PCBs, DDT, hydrocarbons, cadmium, mercury, lead and other heavy metals.
We know the impact to human health from exposure to mercury and lead.
Where is the human health impact from exposure to other toxic chemicals?

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                                                                                               Name
     EPA may learn during a search of medical  impacts that cadmium
is considered a "suspect" in causing Lou Gerrig's Disease, for
example.  It is logical that EPA will want to  requlate maximum annual
and cumulative pollutant loading rates for sludge products that would
be applied to agricultural land and maximum pollutant concentrations
for products applied to nonagrlcultural land.   Hopefully,  no one
in this state will be so ignorant to use Boston Harbor sludge as
fertilizer.
     Is it more a reality, than we are told, that the double liner
system MWRA proposes, will indeed leak?  Where la the supporting
data that will prove it will not leak?   Even  if it IB promised
not to leak, the NCI site is simply too small  for what is  to be
dumped there.  The EPA must clearly address this situation.
It appears more and more certain that should sludge be sited in
walpole now, we taxpayers and rate payers will be facing another
costly and lengthy process two to three years  down the road for
the siting of another landfill.
     EPA states that additional costs will be  Incurred since the
landfill site should include design and operation features such
as drainage structures, holding ponds,to collect drainage  from
surface run-off.  How much will that cost?
     We as tax payers are demanding that our voices be heard.
The MCI Valpole site does not make sense for a sludge dump.  It's
even the farthest site from the headworks where  grit and screenings
are produced.
     EPA states that "for landfills,  emission  estimates of odorous
pollutants are not readily available'.'  why not?
     While we all agree that Boston Harbor must  be  clean and free
of toxic wastes and chemicals, EPA must make the first step by
determining that sludge simply DOES NOT BELONG at MCI  WALPOLE.
                                Sincerely,

                                Carol S.  Hinkwltz
                                                                                               ADDRESS
                    EPA Comment Meeting  io«4f>U_

                                                     ,
                                              O003
Date
Concerni EPA  has  not ndted differences In levels of toxic
substances  reported by "private watch dog-agencies.

Enclosed Is the copy of the "Bonton Harbor Toxic Project*
•which eite  different toxic values. This further shows
the chance  of varying levels In the system and MWRA's
BojectedLevelB cannot be consistently attained.

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                          BtWCY*  LF-000 •**•   20515       .

                                          OooV      5

                              of tlje  Hnitea &tate0


                                        .lot
w» imeiiww •MUM

   oat nini
                          February 27, 1989
Governor Michael Dukakis
The state House
Governor's Office
Boston, W 02133

Daar Oovarnon

1 m writing to you about the decision taken by the Massachusetts
Miter Resources Authority to put a disposal  site Cor the Harbor
Project In the Itawn of Halpole close to the  line between Norfolk and
Halpole.  Ihsra are three serious problem with the HWtA decision.   It
Is mistaken in Us own term, because It underestimates the costs at
Kalpole while overestimating the cost of using Spectacle isUnli It
ignores broader questions Involving Improving state facilities, taut
particularly prison capacity) and because  of Its extiemly
controversial nature. It Jecpardlna our ability to tork together as a
congressional Delegation to bring desirable  federal funds to
Massachusetts for the Harbor cleanup,

it would be econcnlcally, envlromntally, and socially far preferable
for the atmnonuaalth to  take advantage of  the town of Halpole's
willingness to cooperate in an expansion of  the existing maximal
security Institution at  Cedar Junction: and  to use Spectacle Island —
already scheduled to be  used as a disposal site In conjunction with
the depression of the artery — for the sewage disposal project.

X write directly to you  because the rHIA obviously was not inclined to
a    attention to the question of prison facilities.  1 should add that
    lieve that, In addition, there Is strong evidence that ths MOM
miscalculated the true costs of the harbor pollution disposal site
being built in Halpole,  «nd overestimated  the cost of doing that at
Spectacle Island by leaving out the cost that will already be incurred
there by the use of that island In dealing with the Central Artery
project.

Jw example, given the Insistence by the Environmental Protection
MylnUtratlon that the Halpole site be a  back up for sludge, nwch  of
wh ch might be toxic, the state if It goes ahead with thlTplan mist
build in a contingency for dealing with the  potential pollution of  the
water supplies of Norfolk and Vblpole,  at  a  cost of millions.  Since
both town, now use tells for their uater.  if there was pollution of
their sources, there would be significant  cost in building an
«MrF  tL'ra^' i" a*"tlon'  "* plans  for the site at Halpole
call for the washing down of the site,  the washing of trucks, etc.,
                                                                                                   W/-29/W89   11'36  mm
                                                                                                                                   LF-480 «•«»   20515
                                                                                                                                                                      P.B3
• 11 of which would require a aouree of fresh water which is not now on
the site,  and so there Mould have to be construction of a water line
and facilities at the site, another contingency which must be provided
for if the fiscal planning la to be considered responsible deals with
the Improvement to th» roads and intersections that will be
necessitated by the significant increase  in truck traffic to Halpole
-- and of  course this has environmental considerations as wall because
of the additional pollution of the air from these trucks.  And there
may also need to bo a waatewater treatment plant  to tract the leachate
at the site before it can 90 Into the aewer.   And on the other hand,
much of the cost that the MOM has imputed to  Spectacle Island In this
process Is not genuine incremental cost because the funds will already
have to be provided whether ox not the sludge  disposal site Is put
there because of the Central Artery.

ta to federal financial contributions to  the Important project of
cleaning up the Harbor, as you know, one  of Of colleagues In th» House
has already expressed hia strong reservations  to  this mow* because of
the Impact of the WRA In his district.   Given the strong opposition
to the sludge site In ttalpole, and the legitimate basis which exists
for that opposition, I would also rind It hard to justify working hard
to get additional funds from a tight federal budget for a project
which will  have so negative an impact on  part  of  the «rea I represent.

I understand that the NUM. Hater Resources Authority la not entirely
under your  control.  But I balleve that if you, as the Chief Executive
of Massachusetts with the broad set of responsibilities for the
environment, prison facilities, economics and  th* quality of life of
•11 our cltlians made a strong raccmmendatlon  to  the MWRA, which has
on It sen* of your own appolnteea as wall aa others Who would be
amenable to your Influence, they would be very likely to cattily.  1
believe that a decision to use Spectacle  Island Cor the sludge
disposal, and to use the existing maximum security Institution at
Cedar Junction In Halpole as a basis for  prison expansion offers the
best possible solution to the current situation.
UF/pah
                                    FRANK

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                                          000^*
a June

 Pudarnl WA •"••tin* In  "•Ifl- r-»i.i.ll«i» •"««• "'  "-Ipol* "lie:

                    PM-r  the Uili-.li
rnreiit IT .

    A  The
oil
                             Into  our wal»i« by  K««'-n In Alv*n.
                                                        1
                s=,-^swsi •EJSIK.-.X.S  -5;:;
Imppenlnif.  Hut.  they «l«-1 happen!

    B   Then ••  ••• the  eerloua pipe  brfuWown In lh» <«i*r ai..l
.,...*.  ™»t«I   th.  H.RA  own.  »ae.ing  h-vy ""I" I'""' ""•« *"•'
h'aUh  condition,. Ornnled.  «h. plr«   •-» b.  «• y-"™ »M. - «
Lli»* ahow  that  plp«»  •»• ««'lnil  to lironk  mod I*"*  out iii»->  "*
inClro^nt.  And!  -h.n d..lln%-lt
hoalth hncnrdw.  B-TontiF !!»• <7S>. r«««r«  !•

So  m  hBOii. Miat »t!Hr«B« »h«  f«ol th«l.  In r»«llty prvhlraii <1o
 ""? r.!£rdl«.  off .h.t pm.lB., .r. .nn.  th.t rh., -Ill not.
    HiMit EPA «tiM» -hevB  All Mndriim VIII U»h. "ill Pt.ll»«> »h»
       of Th»lr Ar..  «o  nn« knni,^ ..n.-lljr -hnn but.  — i«n,.w th.t
 It  ill h.ppon  Plu« «•. hno. Ihul th« lln.rn th»t nlmll ..... "-I «••
 thf lindf 111- onl, ro«. «ith . l«.ir ««) y»-r Hinn-nt-i.. So «• kno-
 th»t "n dii  U.i ihr l-ndrill Ml. .ill h.  ta.felM  -"H wr^lin*
 oontMlnation Into and • round  U.v «r»a.

                      Sites  It   h-.* nn  aquifer:  •  n»»lrt»hl» '**»'-T
                     ..r   ,= rr <*, i-«;^i-^  -^^ «\
                      :  •  Ink".  '  Hl«lili>nd  UnHP   J.   •»"  •• •
  orron.l lm,,.;:  -nrt   l« ner.. ^  "-"'"^ •»; "'";,""•"'
 proxlalty  to It. Plua. aimy |.n..|.|.«  !••• allliin '•«« f«-t  or It.

 Studr  of tho Federal I.IIMH |ir»i»n« «n«  th^i»  lt»»»

     Tho K^tlan-Jr. B»..-.iM»* .ir.loi  BHI'WH rl.arl         .
 fodoral BP* ehonld prot^-l I ....... ih-i.H.I k»rp *-**••' Ln-lfllln
 fro» tho*.

     Publto Law I8»-K!.:< ••• .».-•  Hi I  !»•»  Ili^lmi llnil^r rt**nnp  •""•»
 not inlJ   oT..n,,p  Ik* hr.,,-r b... .  lh,»   .. I  -..t Pr-l-t  **«££'•
 •ooorat*..  anil  tnmirr    | . ,,r 1  r«  lh-i.ni.    rl I '•'•.• " '"'  '
  landfill  vhioh h*!.  "  rt ..... •    -..y...r  l-.'-rla an.l V"'? ,„ ^..'.J,;
  that .III  ha»a  .  htfl ..... .'r-  -I  ••'»•-  >n H. « » '- ' !"!? "","'""
 bolnf urontir  than  th» BI...IB.I..  n ..... m ->il» ..... « '•» "'r M "   '1|1"
                                                                               2.
                                                                                    •ALPOLB LANPF1LL SITE
Toohnioal Support Doouaont on Iwidrilling of Bonag«  aludge and tho
onooalng Fodarol tax o pot to tn Ing to  landfilla  ),  nost to • rlvor
that  IB part of tho eooorotoa t* wrong,  will not  ooot  tho '  Long
Tor*  HoBlth  *  ro«ulroBont.i  Plus, oneo  the Stop Rivor boooaoa
pollntod. tho pollution Bill MOB Into tho CharloB Rlvor and  thon
right book  Into tho Booton  Harbor.   It  IB Juot •  oat tar  of tloo.
^nd».  it Bill bo on ynlaiffol ooki M«J oroato •  HOB Sopor fund Blto.

    tho IOBO of U.S  CodofaS'o Chapter 3B. ( pal Id t ion provontton>,
roqulroo thot o landfill east onouro:           ;
•ator quality;  drinking Bator protootion; protootion to  Man and
•lldiifo in navigablo no tor; raerootional uoo  in and m tho Bator.
Plu». that  tho  Boat  Praotioablo  Control  Technology  Currently
Available aoot bo uood. Thlo la*; 'in  aooerdanoe with tho U.S.  Codo
of  federal Ragulailona 4f» I .. Protootion of   Bmrironpent >. ohowo
that  tho boot teohnology lot ., aoloot a  landfill alto that hoa tho
leaot probability of advo*oo aationa . Bhioh would hara our people
or  oar onviroaant;   that Id not valoablo to aqua tie aroaa;   ovoid
unioue habitat altoa;    '. .   -that  if  tho poBoibllity  of advoroo
offMta oslot  an alternative' ai|ie BhoOld  bo uoed: 'aitoo ahould
be  ioeated  ou t aide  publlo> Baton oapply  Intako-aroaa.  with both
Valiwlo  a  Norfolk  uoinAwl.«olIo;#ffof wMtor.   \hia  IB of ntaaat
lapoftanoo. •

•alootim  ofAiao of  a olto oattK; M  tho talpole flita Bhioh haa auoh
a  high arobabilty of falling ta ' ooaply/adhere to tho  lawe called
out In U.S  Codo 33. Publio  Law  10e-8&8.  BO  it«0*. U.S Code  42.
oot.. and  failo to  uao tho-advie4 roleaeed  by tho- Pedoral EPA and
•there oonoerned  with our.envlroliaent  oortolnly  io not  uolng the
Boot  Praotloablo  Control  Mohftology. . One. , of; the aajor factor a
1 aaOJM out in U.t Cod-. 33.

    pluo,  our Pnbllo HoaUn and fclaaji Air Lawa aaat bo  oonaldorod.
Aa,  with  tho  proilalty  tho . falpole  Blto |"-eto »»• Bouth-ood
Hoapttal  and  tho  two MCI'I   in, o.^b Junction with the  foot  that tho
aaterlal  that ohall  bo duaped >at,  tho oito ahall  oontain  -dleeaae
 oatrying   baotoria and   virwo ".  plua bo  a T highly undooiroablo
odot  " aatorlal.  ovary  tlaa   aHraokload of aatorial i a duaped the
Idlaaaaee  and  odora will bo   air carried  around- tho olto o  area.
.alao.  tho  highly  dangorooa Mthano   gaa  landfilla  oroato havo
joeuaed   oMploolono In   roftidonaoa killing  paapla.and forolng that
                                                                                gae -cetera  be plaood in tho poop lea hoaoa.   . Toe oertoinly  would
                                                                               /not '. want your  Bother or  child being  an  Inpatlent at tho nearby
                                                                               ,M|oap}tal where auoh a danger ouo«pnd it Ion ealata.

                                                                                    teviow  off tho Volpole ait* ahowa  that it la far  to dangerouo
                                                                                to pleoe a  aawage landflU ln,.rt.hat  it will not ooaply with our
                                                                                federal  Lava.  Standarde  end ' Knvlronaental  Ooale.  that  Ita aao
                                                                               'would  be  contradictory  io  the envlroaontol laprovoawnt  ootlbna
                                                                                ourrently being done  in oar nation.  It auat Aot bo need.
                                                                                a aach aafer alto Baleotien, auet be aad«.
                                                              I
                                                                     A.L. b»aaignani
                                                                                                           King
                                                                                                                    Norfolk. NaiiaaohuBOtta

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Name
                EPA  Meeting -Comment Period
                                     OOOC,
Address
                                                   LL~
Date
Concernt The MWRA will be violating  105 CMR *80.000
by disposing of medical wastes  flushed Into its system.

Medical wastes have been well documented  In the MNRA
sewer sjrsetm. The MWRA In proposing  to dump thin
medical waste as part of the screenings must be
subject to this regulation.
     Definition &80.0*0-"Waste  which because of Its char-
acteristics mayi cause, or significantly  contribute
to an Increase In mortality or  an Increase In  serious
irreverelblle or Incapacitating reversible illnessi
                        .•
or pose a substantial present potential hazard to
human health or the environment when Improperly
treated^ stored, transported, disposed of or otherwise
manged."
        Two such item are discarded  live  and attenuated
vaccines(ex. polio oral vacolne In sludge) and sharps
(ex. including but limited to all used and discarded
hypodermic needles and syringes)
        Disposal 480.200.B Sharpst
           1.disposed of by incineration... or
           2. rendered nonlnfectlous as  set  forthin
              105CMR UBO.IOO(P) and  processed  by
                                          page  2
               grinding or other effective method
               to eliminate the physical hazard of the
               sharps ...
     Inspection Authority- 1*80.UOO  (B)  boards of  health
...are authorised to enter, examine or  survey at  any
reasonable time such places as they consider necessary...
(C) ...board of health., shall have the authority to In-
itate proceedings to enforce this chapter without prolr
notice in those circumstances in which  the  board  of health
... determines that immediate proceedings are warrented.
SEE ATTACHED REGULATION
AND ARTICAL -FEDS TAKE ACTION ON  INFECTIOUS WASTE-

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                                           OCO?
                 EPA Comment Meeting
                                                             ~Jr
                                                                                                      EPA Comment Meeting  OOO8
name
AdB»ess-
Pate June.
Concern The MWRA's dumping of sludge at the Walpola
site will violate 33.13** of the Navigable Water Aot.

•Notwithstanding any other provision of this chapter
or any othar law. in any cass where the disposal
of sewage sludge resulting from the operation of
a treatment works as defined In section 1292 of this title
(Including the removal of in.place sewage sludge
from one location and its deposit at another location)
would result In any pollutant from sueh sewage
sludge entering the navigable waters, such disposal
Is prohibited .*.•

The EPA's report on the Walpole sitefOS Indicated
the possiblty of polluting The ground water and
the Stop River.(May 1989.)
                                                                                   Name
                                                                                   Address,
                                                                                    Date
                                                                                    Concern «»»RA will be violating Congressional bans
                                                                                    by planning to dump hatardous material In a landfill.

                                                                                    Congress passed legislation In Hovember 19» requiring
                                                                                    EPA to phase out  landfllling of  ha«ardous wastes.
                                                                                    See attached chart. Rote by May 8.1990 all remaining
                                                                                    hazardous wastes  are  banned.

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               EPA Content Meeting
*«••
                                     OOO?
Address
         
-------
              EPA Content Meeting

Name "Ziffle. N\ .
                                       00 "
DatejQilSL^l^ifM
Concerni In that all landfills leak, methane gas is

a risk for explosion.


Methane gas generated by bacterial decay, takes

the path of least resistance through permeable portions

of the landfill. In 198*. methane from the Lorton

landfill leaked into the next door District of

Columbia Prison, exploded and killed one inmate and  maimed a

second ( Washington Post, 1965 ). Methane concentrations

between 5-15JC are explosire.
                                            QOI3L
Jun
         19B9
made bv:
      fi to USEPft on the Draft Supplemental  EIS
I.
                                                                            3.
                                                                            4.
        John C.  Hahn
        691 Winter St.
        Malpole. MA  020BI


Figure 3.4-3 shows water service extending  down  Winter  St.  to the
Norfolk town 1 me and is incorrect.   The  water line  stops ȣout
30n feet down Winter St. from Route  1ft.   The  inability  of the MWRA
to accurately locate well defined  items such  as  utilities raises
q°e°"ons as to the accuracy of their zone  two .wetlands, and
water shed delineations, which are far more esoteric.

On page 5-103 it indicates that the  private and  public  wells in
the area would be most  impacted when the  landfill  'ea^s'.   ....
Monitoring wells may possibly detect the  failure of  the I""**'"
,n time to remediate  it.  The MWRA,  to the  best  of •* *"°r'"££;
has not developed any contingency  plans to  Provide water to both
public/private well users in both  Waipole and Norfolk.

On page 5-1O2 it is stated that "no  analytical data is available
on the quantity of VOC's  in grit and screenings".   H°w «" *he
assumption be made that "impacts are expected to be minimal  if
you have no  data on which to base  your Judgement'

By what chemical mechanism does solid waste  (tampons,wood, etc.*
transform  Into  "minor residuals" during its trip through the
SPwer system and why  should  the siting requirements be any  less
strict*  for  "minor  residuals"  with  regard  to distances from
wetlanrts.  zone  two area's,  and private wells'?

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                  EPA Cement Meeting
                                     QO/3
 Address
 Date
 Concerni Flexible membrane liners hare weaknossea.

 The following la a partial sundry of the National
 Sanitation Foundation study on -Development of
 Chemical Compatibility Criteria for Assessing Flexible
 Meabrane Liners'(FIB).

 The BPA  reqaires that FOB selection be baaed on
 evaluation of changee In physical properties resulting
 from Ineralon In the actual waste to be contained.

Enclosed la a study of six linen In twenty aolutions
at two temperatures and the following IB  a  summary.
     1. Low concentrations of some chemicals can
     cause more significant ehangssln PML physical
     properties than higher concentrations of other
     chemicals.
     2. Mot all materials are  suitable for service
     at 50  c.
     3. water Is  sometimes an  aggressive medium in Itself.
     especially in conjunction with an elevated temperature.
                                           page 2
     fe. Increasing the concentration of organic solvents
     In.water solution In general Increased the
     magnitude of the FML response.
     5. Weight change is a valuable indication of material
     change for all FHL's tested.
     6.The limitations of compatibility tables are that
     naterlals are usually rated qualitatively (good.
     fair, poor) and the test conditions used to
     determine resistance are not always detailed.

PKCg.i ed,utrst> Mnerm to be tested before using for a
particular waats but no liner has been mentioned
specifloflhr nor tested. It will be difficult to test
because what  is entering the system cannot be confojed.
Rota* enclosed MWRA May/June newsletter which indicates
33Jt of the flow in the sewer systemls from Inflow
and  infiltration.

Furthermore,compatibility cannot be determined sines
future chemlcayto be dumped in the landfill are mnknown.

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                                                                                                                 aoif
                                                                                             RECEIVED -EPA
                          4
               &           0011
I, ^^^T^^^^a^. r^r,
 . „_ -y£~^, f<*fja*&Za*-tJ <*<*>£•*<***-
BFWHttUJSI
BtVtBElUOJUl
                                                                         H*. Ann Podn-r
                                                                         U. :. .iPA
                                         WAIBQIUUniUIKH
                                                   JFK Frot*»«lon«l  Building
                                                   boa ton. 1A  42203


                                                   liaar Ha. Podn*y:

                                                      I uiah  '.o  thank you for for»«rdln| •• th» Or«ft 8u»pl«»»nt«l
                                                   Bnvtrcneantal lapaat St*t«>*nt.

                                                      -Is  Rodney. th» 4«ep«r I study landfill data. th« «or« norrlad
                                                   I  b.co."  th»  th.  HUM  I...  .Jd.  a  -.ry „••'»«»• •»«•  "
                                                   ..l.ctln*  th. Halpol*  HCI land  for If.  landfill ait
                                                   •hat.  If tha Balpola ait* ia uaad. In du. tin.  it •»«      .
                                                   ^itl=*n»  >f  :ur atala with an »»an «r*at*r d*«r** of probUM than

                                                   K* -jrr*nc:y hava.

                                                                ho«*T*r,
    Thar*  «.  o«*T*r, a ..rioo.  p.oblM at th. V.lpo 1. .it.  that
auat b* addr*aaad.  »• It "111 affoot not only tho r*ald*nta of tho
         -loff.ot  virtually o»*ry oitlaan in our  .tato uoing
                        oltl.on  of  on*  n.tl«  ^oornod  -itb
                                                       Thar*  !«
                                                              *aaad.  »•
                                                   «•*   t.-llloff.ot   virtually o»*ry
                                                   MM a  aariloo..  o^.ry
                                                        ..
pellut*  t«o Mjor fraah «at.r oourooo;  an  •^olfar  on It • oa.torn
bqrdar and tho Stop «i»or on If. oaotarn  bordor.

    Hatar. awoolally fro«ll mtor.  I. to. "1«*»»* *•

L.rr.\rjR.J&l..v.aLW
"Sll Jn-4fU:a  !"" and.  that landfill. •
Hatar Of That? »raa'. Thaaa  foot, owo froa>
om  EPA  Acanev.  fro.  ooiontlfio  «««?4«j"e""
Fadaral Con«r*ao and  fro* tho laadlnc aolantlf lo
oar natlonl   Pin. atopl* thing.  Ilk. tho Oprah T»
 tha probUaa tho  r .aidant a of Louisiana hayo
polluted  rlwr  oatar  of  tholr  .t.to.   C
oon.tant  bad odor.  oontMinatod fi.h  ••*••
probla*. mrrioo  aro valid.  ( ... eneloaad d.t. ).

    Baaad on  tho BPA otadloo. aot..  1. «olt.  •»P"«»t  "•*  * •
 landfill i. built  in V.lpolo. It i. only •  «.ttor of  ^J*,,
 It pollutoa  tho aqulfor a  mtar Laying  *•• ••••lo, .•' S5
 .1th  no drinking  mtar and.  pollntoo tho » -11. run'^ *f  •«•
 Charlo. «y.r. and faad.  pollution dlrootly »••»*"'•  *
 Harbor  polluting It In  th* BBM Mnnar  a. th. Cho.ap.ak
 •ottardaa Harbor uoro pollotod.
                                                                                                   ^
                                                                                                  *»•  •»»«•««»» •»
     Tat.  althar thaao landfill faot^problow .«a«-t
 .1.. na on* «anta to  Ml.lt to th*..  a. oon.ldorablo
 to  tha  HUM.  HIP*.  OIOI. . »11 .tat. a.gi.lo»or.. rtg
 Dukakla.  «htoh ahomd tho ha*arda building a' londflll bo
 water aouroa. Mould or oat., tba^.anpmd  it.i" •••of. .*•»<•»
                                                                                                        botmm t».

-------
 1-2H-M
 H«.  Ann Rodnoy.  EPA


 ?!fl'«i!!!"t*?d ?'  •*•>•••»"« ««•   ••rloa« *.tor  pollution
 ttw  HUM ai.ply  ana».r. br   atatln«  that   If •   "landfill*,)
 t>t  l.ak- or.  ohmild th.y. -  th.y  "111  cap  th..   .  Y.t

                        thgt *• cwe- «•«»••••   «• i«   «   t
         «  i    .** °r>  l°  "dTlM  "*"«  ll «•'•»» *o far tho
         p.epl. of  tt>*  .»•  aha   r.alov. their   niter  fro. u«ll9
                                                    to
      1   f*^*rr. •»•»«*""« «"t  . lmr«*n  «M obtain  dati uhloh
      out  th. .l*t.k.  It .ould  b. to build . landfill neat to t«o
 «at«r >oufe«a.  >or« dl»tvrblnc  that. If  our l*adln« oolentiflc
                                                     "
                  ——»-—  -—--» — ™» *ww»*k »rv  r. vavivvv  III.K  HJ1
 ----7	  •••  Contanlnato Th.tr Aroa'. tat.r. (.von out.ld.
 th.lrbord.ra>; that. *Uh o*.r B billion dollar, to mrk •Ith oar
 •tat. a  mu Mould  .«on oon.ld.r  building a  landfill b.tn.n 2


                       ild .a.t. tho oltlton. oonoy by  do.Unlnc a
       "- i"";v.:~  ••"tM'y t«  U«a advlea  ilv.n by oor nation'a
 	 •ol.ntlflo  organitatlono. And thon ••••  olaiaa a-hleh ara
 oontr.r, to th. f.otu.l ludflll .tadU.I    Mo. eM t". bo "?


    ^f??'?!1?*?^1- """* «"*"•• »t ta ««»r thm>   Tho BPA.   Th.
                 or aeione... orrlo. of Toohnoloiy Aai.acn.nt.  .ot

 iandflll im •ny^.tto^th.n^tho'onoa^to.tod^ " '*  "*' "** " "

 f^H."?!!1*.^"? lh*5 "*J "*** "onld b« »»t.III«ant onoogh to loarn
 fro. tho .l.tako. of other, or. to .t loa.t u>.  tho advloa of  our
 ••p.rta but. apparmtly it 1. not or will not.


                    for thrac.lT...  oon.traotlan of a.  landfill in
                    bad •latake.  •!!! «aaa._ aorloua da.M* to  tho

                  It.    *"*"
                                                               .
                 .                            Mlaotlon  at Valpola
         * "*!* •*** ••»••« ••» •«• «»t If It ahould bo  uaod. »111
           y?*^ ••rlo«"  hM««l»  to  th.  mt.r   .ooroe. on If.
           TfMuik you.
L«fT Ba.alcnanl


Norfolk^ 114
                                                                                                    RECEIVED-EPA

-------
/7





-------
14 Juno l«Bfl

Htotf Ann Rodney
U.S. RPA.  Re«lon  I
•QB-1PWC
JPR F»<1erftl
Beaton. HA
                                                    OOlfl

                                                 RECEIVED.EPA
                                                    r- :  , t•:
                                                    JMMM
D..r Ulan

    In .c,-«rd.n6.  «ith  IM SPA".
follouln*
                                        Tor c»«rnt.. 1 off* th-
          act.




 •hoits no  nea da»im. no  """*"«""   i her-fore.  >t» p«rror«nr»
 Undflll*  currentlf In  "*""""";,r;.J2Ine° of iJnrtMlln .turt^rt
 •ouiht by oar Comtr.Bf.
  th« Fodorol BPA.


  /euro ttal?.
  f jrfBlk? HA  020S6
                                                                                       14 JUMP
HI** Aim H-Hnny
U S KPA. H»«lon 1
                                                                                       JFR r^rtTui
                                                                                       Bootnn. HA
                                                                                       D««r
                                                                                                 Rorinor;
    Pxtontilve •tudlw  on l»nrlflllB  done hr  th*> P»Her«l  FP» h»fi
 foonS  "h"lT A?l "mlfllln  mil ft. Sh.l.  ••"il-t- th; •"»"  '"
 •nd  llut'M*  Their  Boundrl.^.  Thsl.  the  Bent  Rnowi T«ohnolo«
 "  rr«n»ly A*8il«hl« C«n Not lT.»ent l.midflllo Pro. Lo.htn* «lh«»her
 L "S  nr H"!! ihelher C.pped or Ho.. Th.l l.-ndfill. Ar. •l-'l
 UnnK»rnii9 To Pine* In or Around Drinking  »Bl»r or HavtlBblo
                                                                                           Thl. hno«l»d«e  !• »ho»m on ntudleii dono for *"•
                                                                                        the thr flr.s of  OeoBer»lef. < of Bo»ton. «»'"n  >'
                                                                                        Hlllor. » of Port NMhlnNton. HT  >. b» Federal BPA re !*••••
                                                                                        Jid.rli  H,«l.t«r .nd  b» .t.t..-nt9  -M- to  tj. Sabco.. »".«
                                                                                        H.turil P»Bourco..  Agrleolliirel Beje.reh  «nd •"'•'•••"^•"{'
                                                                                        un :>l«nre  and Toohnololr MOUBB   of Repr«»ent«tU«B by Federal
                                                                                        ppmnnell.  ( onel  >.
                                                                                              -      rindinM  cl..rlir  .ho.   th.l  the  •""
                                                                                               n of lh«  l.ndflll  the HHKA propoeeB to »»••• •*
                                                                                                -SJt.  In  H.lpol. Hasn.cbuBettB c.n not .eot the
                                                                                        •nri Lnwx rolled out  In O.S. Cede 33. oen not enooro the
                                                                                        H«lth prowJT.Sl  .nd other «o.l. -nd -tlP-1-tlon.
                                                                                        Public Le-  IPB-853.   5ho«.  thnt   if   •  JT"    JJ .lll*.  n
                                                                                        op-r«l.-d  at  the  H.lpole  Kite.  In do*  ttM,  It Will C.UBO an
                                                                                        llnlavful  Ant to b"  coa«ltted.

                                                                                                                              s

                                                                                                  «~'j;r2={s. •s^ss-s-  •
                                                                                                                                          .    .  .
                                                                                         1-n.llill   In th« »*lpol« C-Hnr .I.HiMon Stto.  PUjao B.O J^  thl«
                                                                                         ln.o,n,tt,,,, l. rtl^r,  ..<. the pnrtl-B reiiponttbU for ••!"*•»" «*"•
                                                                                         «n«iroapni.«l rr..l-c-Uon an-J Isane nf l.ndrill perolte. Th.nfc TOO.

                                                                                         Yoiirr t.rnly.
                                                                                         l.niry Hmnlr!n'iliI
                                                                                         IV Klni> .'.t .
                                                                                         P.I) ll.ix M I
                                                                                         Horfolk. HA  M"lV-i.

-------
                                                           001?
                            100
COASTAL ZONE

MANAGEMENT
                                            OKOS
                                 July 10, 1989
 Ann Rodney
 U.S. EPA Region I
 HQE-1900C
 JFK Federal Building
 Boston, Mas«achusett«  02203

 Dear M>. Rodney:






 which was  provided.

                                  Since:
                                  Steve Bllven
                                  Acting Director
  SB:JPS:ola
                                           RECEIVED-EPA

                                              !9ULU wo

                                          WATH QUALITY BRANCH
IMichael Deland (or current resident)                             I
j Environmental Protection Agency                                J
! Region 1, JFK Federal Building                                  i
{Boston, MA02203                                               '
! I have learned that it is still possible that sludge from the sewage treat-
I ment plant will be incinerated right on Deer Island. I know it is only a
j plan if other methods of sludge disposal, compost, pellets or land fill do
I not work. But still, for my sake, my family and neighbors I do not want
j sludge to be burned on Deer Island, Spectacle Island or anywhere.
[Even if air pollution problems can be solved with scrubbers or high
! temperature incineration and even if those technologies never break
Idown, carbon dioxide will always be produced and that will aggravate
I the conditions necessary for global wanning because of the green house
I effect. Sludge incineration is not a solution.
I So it is not simply a problem of NIBY (not in my back yard) but NOPE,
I (not on planet earth).
llf the Environmental Protection Agency's Job is to protect the environ-
I ment then methods other than sludge burning must be used. Just chang-
jing water pollution into air pollution is no solution.
                                 Sincerely,
                  TELEPHONE COMPLAINTS TO EPA
                  CAN BE MADE BY CALLING

-------
                          ROBKRT A. DnljRO
                             ATTORNBY-AT-LiAW
                             110 niCACH HTKICICr
                        REVinUC. MABMACinjBKTTM Oil SI
 RECEIVED-EPA
          JUL I B 1989
W4.TER QUALITY O
                                          July  7.  1989
    Ann Rodney
    U. S.  EPA, Region 1
    WQE -  1900C
    JFK Federal Building
    Bon ton,  HA  02203

    Dear Ms. Rodney:

                 A«  a former  Chairman  of  the  Winthrop  Board  of
    Selectmen and an  attorney in  the City  of  Revere, I viah  to go on
    record as being  oppoaed to incineration at  Deer  laland and
    land-filling at  Rove Quarry in  Maiden/Revere.

                 If  these aitea are choaen, one hundred  percent  of  the
    reaponaibllity for  resolving  the Greater  Beaten  leverage problem,
    aa veil  aa Boat  of  the re«ponaibi1ity  for the  clean-up of Boaton
    Harbor,  could be  borne by three or  four north  Shore  communities.
    The North Shore  haa  done  ita  ahare; and becauae  it haa done  ita
    ahare, there should  be no further  talk of incineration at Deer
    laland or the use of Rove Quarry aa a  land-fill.   Lip Service to
    the principle of  equitable distribution of  regional  responsibility
    is not enough.  Me  vant,  and  demand,  equity.

                 Relative to  Deer laland:  I  am nov  and  hive gone on
    record in the past  aa being atrongly  opposed to  incineration, not
    only at  Deer laland  but at any  site.   I have yet to  be convinced
    of the safety of  incineration and  feel that  the  people of Uinthrop
    have had enough  and  must  not  be subjected to any health  riak vhich
    could  be cauaed  by  this unproven technology.

                 Relative to  Rove Quarry:  In addition to the equity
    issue, other factors make it  an undesirable  aite - aueh  aa coat
    effectiveness, problems vith  wetland  regulation, the issue of
    tranaporting residuals to the Quarry;  and,  meat  importantly, the
    fact that Rove Quarry is  located in a  denaely-popuIated  area
    comprised of people  vhose veil-being  vould  be  threatened by  the
    sludge proposal.
             So, I call upon you to  atop  thia  inji
the sludge trail out of the North Shore and  into  <
di r ec tion.
                                       Very  t
                                                                                                                                           SV"'
RADinel

cc:  Winthrop Sun-Tranacript, Inc.
     193 Winthrop Street
     Winthrop, MA  021S2

     Revere Journal
     327 Broadvay
     Revere, HA  02151

     Vlnthrop/Revere Reporter
     325 Broadvay
     Revere. MA  021S1

     Daily Evening Item
     38 Exchange Street
     Lynn, HA  01901
     Bast Beaten Times-Free
     2 Lexington Street
     East Boaton, HA  02128
Leader
                                                                                                                      -2-

-------
                                                       oca"?
                                                the
                                              17")
8-30-89

Hz  Ann  Rodney
USEPA
Region  1
J.F K   Federal Building
Boston.  HA  02203

Dear  Hz  Rodney
     I  wish to  thank you and   your fellow EPA tewi  nenbers for
meeting given  in  Halpole  last night

     In accordance »lth the brief  diaouBeion you and I had   at the





date ia acceptable.

     In  the  Interln. «ould you kindly forward ne a  complete  listing
of the  BPA  peoplS  handling the  HURA harbor   cleanup project and
 their responsibilities  In It.

     Thanking you  in advance. I  en.


                 Respectfully  yours,
Larry  Basslgnani
17 Rind St.
P.O. Box 83
Norfolk. HA  02058
                                                                                                                                       17 Payson Street
                                                                                                                                       Hinthpop, HA  01252
                                                                                                                                       July b, 19B9
Mr. Michael Del and (or current resident)
Environmental Protection Agency
Region 1
JFK Federal Building
Boston, MA  02203

Dear Mr. Del and:

Ret  Deer Island Sewage Treatment Plant

I have learned that It la  still possible that  sludge from the
sewage treatment plant Mill be incinerated right on Deer
Island.  I know it is only a plan if other methods of sludge
disposal, compost, pellets or land (ill do not Mark.  But
still, for my sake, my family and neighbors I  do not want
sludge to be burned on Deer Island, Spectacle  Island or
anywhere•

Even if air pollution problems can be solved Mith scrubbers
or high temperature incineration and even if those
technologies never break down, carbon dioxide  Mill always b«
produced and that will aggravate the conditions necessary for
global warming because of  the green house effect.  Sludge
incineration is not a solution.

So It Is not simply a problem of NIBT  (not in  my back yard)
but NOPE,  (not on planet earth).

If the Environmental Protection Agency's Job is to protect
the environment then methods other than sludge burning must
be used.  Just changing water pollution into air pollution is
no solution.
                                                                                                        Very truly yours
                                                                                                        Edward F. Bomarsi
                                                                                  Jib
                           00^-7
                                                                                                                        001*
                                                                                                                                      0

-------
                                                                 O030
                                                    RECEIVED - E»A

                                                       5BIL13 1889

                                                   WATER QUALITY BRANCH
01 JULY 1989
Nr. Michael Daland
US BPA Region 1
JFK Building
WQB 1900C
Boston, Massachusetts 02203
Dear Hr. Deland:

I wish to register the following comments  concerning BPA 'a Environmental
Impact Statement  for long term residuals dated Hay. 1989.

I object to BPA'« suggesting laelnaratlon  •• • technology to process
sludge, even ae a back up measure.  Tour agency looses creditability by
tuggeating the Boat environmentally threatening technology available.
It la disturbing that no coneideratlon  le  given to  the escalating
concerns around global warning . r la Ing  sea levels,  or air pollution in
general, particularly by the agency charged with protecting the
environment.
In addition. I
Irresponsible,
•any chemicals
proposing that
treatment plan,
deaonatratea a
eontenpt .
               find your auggeation to incinerate on Deer Island to be
               it not reckless.   First,  the combined effect* of burning
               together ha* neither been studied, nor measured.  Second,
               such a facility be placed next  to a secondary wastewater
                a heat drying facility and a major International airport
               lack of concern for Wlnthrop residents, bordering on
Since BPA has not extended to Wlnthrop the courtesy of a local public
meeting, X intend that these consents  be  entered into the public record
in lieu of testimony.
                                       0030
                                                                                           af'
                                                                                         (SB)
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCV
                       WASHINGTON. D C 20*60
                                                                                                                    July 12. 1989
                                                                                                                                                         neg
                                                                                           MEMORANDUM

                                                                                           subject;  Boston Harbor

                                                                                           From:     William San lour and Hugh B. Kau
                                                                                                                                    «<
                                                                                           To:       William R. Rellly, Administrator
     The  U.S.   EPA  regional   office  In  Boston   and  the
Massachusetts Mater Resource Administration (MWRA) have come up
with a so-called plan to clean up the notorious Boston harbor.
We think  you should be  aware that  this plan  Is  contrary to
everything  this  agency  Is  supposed to  stand for.    EPA Is
supposed  to  reduce pollution.    instead,  this  plan  allows
polluters to continue to dump over a ton a day of toxic wastes
Into the Boston sewers.  The plan then calls for the people of
Massachusetts to pay over  six billion dollars to build sewage
treatment plants  which will transfer the toxic laden wastes  from
Boston harbor to  food supplies in Texas and Florida and to dumps
ln^suburban Boston which  will inevitably  pollute drinking water
supplies.

  *  The  largest  polluter  of the  Boston sewer system  Is the
Polaroid corporation.  Some  of  the other well known companies
which dump toxic chemicals and petroleum into the Boston sewer
and Boston harbor Include; Proctor k Gamble, Monsanto, Raytheon.
Gillette, Honeywell, TRW, Hewllt  Packard, General Electric, The
(1.9. Army,  GTE,  General  Motors, Exxon,  The  Boston  Globe, and
BASF.

     A federal court has ordered the State to stop dumping Its
sewage sludge Into the harbor,  under the Clean water Act, the
EPA Boston regional office  and the MWRA have the mandate  and the
authority   to  require  these   polluters   to   eliminate  or
significantly reduce their  toxic discharges.  If this were done,
the resultant sewage sludge would be free of toxic chemicals and
could  safely be used  as  fertilizer.   But  instead,  the  plan
allows the  polluters to  continue to pollute.  The federal and
state authorities  in Massachusetts apparently have no stomach

-------
for regulating  big corporations.

     As a result, their plan calls for over six billion dollars
worth of sewage treatment to produce a sludge contaminated with
toxic chemicals.  If  the authorities had done the Job they are
being paid by the taxpayers to do, that is regulating polluters.
the cost to the taxpayers  would be much less than the planned
six billion dollars.

     This sludge  is  too filthy to be  used  as fertilizer under
Massachusetts law.  It is too filthy for all of New England and
New York.  It falls  far short of the standards that EPA proposed
in February under section  405 of the  Clean Water Act.   The
reaction of these agencies to these  facts  Is shocking.   These
agencies, charged with  protecting the environment,  Ignore the
proposed  federal regulations  and  proceed  to shop  around for
states with weak environmental laws where they can market their
contaminated sludge as fertilizer. They have focused in on the
southeast and on  Texas and Florida in particular.

     This Is the  kind of irresponsible behavior one associates
with some of the  worst polluters.  It is Incomprehensible when
practiced by government environmental protection agencies.

     Furthermore, the plan provides that any sludge which cannot
be marketed (which  is likely to be most of it)  will be dumped
in  a landfill  the MHRA  is proposing  to  set up  in Walpole,
Massachusetts.  This has caused considerable consternation among
the  citizens of  Walpole and  adjacent  Norfolk.   They  have a
legitimate concern  about pollution of their groundwater, which
they depend on  for their drinking water, and  for nearby streams
and  lakes.

    ' However, the EPA regional office and the MWRA have not been
moved by the citizens concerns.   They may be too timid to stop
Polaroid  and  other  big  corporations  from  discharging  toxic
wastes but  they do have the courage to face down the citizens
of  Walpole  and Norfolk and  to dump Polaroid's  waste in  their
back yard.

     in  trying to con the public  into accepting the  landfill,
the environmental Impact statement prepared by the EPA regional
office contains such egregious statements  ast

     Escape of leachate to the soil beneath the  lined area
     should not  be  expected for a properly operated and
     maintained double-lined landfill that is capped after
      filling of each cell.

     The occurrence of  an undetected and thus, unrepaired,
      leak in the  proposed Walpole MCI landfill liner system
     would  be  unlikely.
     ...there would be sufficient time for such  a  leak to
     be detected and corrective action to be  taken.

     ...any  leak  which did  occur in  the  landfill  liner
     could be quickly repaired...

     A properly designed and executed monitoring plan would
     detect  any  landfill  leaks  in  sufficient  time  to
     remediate  any  groundwater   contamination   before
     significant Impacts occurred...

     Our experience and.  knowledge of landfills  goes back more
than a decade.  Mr.  Sanjour was formerly Chief of the Hazardous
waste  Assessment  and  Technology  Branch where  he  supervised
studies of the damages done by hazardous waste disposal and the
technology for disposing of  hazardous wastes.   Mr.  Kaufman is
a senior hazardous waste management specialist and former chief
investigator  of hazardous sites.   Both  of  us have  written
articles and have given expert testimony in Congress and in the
courts on this subject.

     we have heard  lies, like those quoted above, many times by
landfill promoters  trying to con a gullible public.  Every year
seems to bring a new crop  of  hustlers  for  the latest in state-
of-the-art landfills,  "guaranteed not  to  leak", only  to have
their  landfills end up on the "Superfund" list or undergoing
"corrective action" a few years later,  we are chagrined to see
EPA engaged  in this con.

     Neither  EPA  nor  the Congress of the United States shares
the Boston EPA regional office's high opinion  of  the reliability
of landfill  technology.   As  you know, congress  has such a low
opinion of landfills that they passed legislation which greatly
restricts their use.   In  passing that  legislation, the House
Report   contains    the  following  admonition   for   you,  the
Administrator of EPA:

     The  committee reiterates  Its intention  that land
     disposal be used  principally as a last resort.

          The following factors  are to be considered by
     the Administrator in  determining whether one or more
     methods of land  disposal may  not be protective of
     human health and  the  environment:...

     the design and management uncertainties  Involving the
      long-term  inability of  liners and leachate collection
     systems to prevent water migration  from  the facility.

     the  uncertainties   associated   with   ground  water
     monitoring,...

-------
     The philosophy of both the  Hazardous and  Solid  Hastes
Amendments of 1984 and  section 405 of the clean  Water  Act  Is
that you cannot  rely on "gimmicks11 such as liners and leachate
collection systems and monitoring systems to protect groundwater
from the toxic wastes dumped In the  ground.  Rather the waste
itself must be rendered Incapable of polluting the groundwater
before it is dumped.

     EPA was supposed to have issued sludge management standards
under section  405 more than ten years ago.  They were only first
proposed last  February.  It will be many more years before they
are finalized.  The proposed Walpole  landfill does not meet the
proposed EPA standards but the  EPA  regional office  can  ignore
that too because the standards aren't final.

     The citizens  of Walpole. and  Norfolk, Massachusetts  are,
therefore,  the victims  of EPA'8 failure  to live up to  it's
responsibilities  in two  respects;  it's  failure  to require
Boston's industrial polluters to meet reasonable pre-treatment
standards,  and it's failure  to issue sewage  sludge regulations
under section  405.

     They  are  not the  only   victims.    Every  taxpayer  in
Massachusetts  is subsidizing the industrial polluters and  they
may have to pay millions more to clean up  the Walpole landfill
In  the  very  likely event  that  it  leaks  and  pollutes the
groundwater.   The  people of Texas  and Florida  may also  be
victims  if  contaminated  Boston sludge Is used as fertilizer  in
their states.

     He  have always assumed that It  Is EPA's job  to prevent
pollution,  not to pass  It on  and spread  It around.  He are
confident you  feel the same  way and will not allow this  absurd
plan to  progress any further.


cc: wm.  R.  Diamond (WH-585). section 405 docket.
    Ann  Rodney,  EPA Region I, comments on Draft  Supplemental
               Environmental Impact Statement.
                                                   53.3V
                                                                      COM. PDMIN.
                                                                                               TEL No.
                                                                                                                              CA
                                                                                                             617 353  3405 Jun 29.89  IS'lS  P.01
                    Friend* of fbc Bonton Rotor bland*. Inc.
                              .  ?.O.Bo«90X»
                              •BoMon.»"A 02114
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                                • *   I   	I —    -«f_
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-------
           TEL No.  .  617 353 M05 Jun 29.89 15-17 P.02     COM ODMIN
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-------
                                           ~*A~~f~l-JA
  MOUei Or aiMKHMTATIVIt

  •TATK NOW*! OO*TOH Otlll

VICC CHAIMMAM. PUBLIC BCRVICC
                                    June 27,  198*
He. Owynn lute
Chief of Environmental (valuation Section
Bnvlronmental Protection Agency
JFK Building
Cambridge Street - 19th Floor
Boeton, HA

Dear Me. total
     As tta State bepreeentetlvo from Vlnthrop end on behalf of my
community.  I ••  compelled to voice my eitrrae dleaatlafactlon with
jour recommendation to  place Deer loland ee the eltlng Hat for elodge
Incineration.  To recommend Deer la land la oafelr and imjnat treeteent
to our community which had eaee  been eliminated from the eltlng  Hat.
only to  leara no*,  that  It  baa  been pieced  back  on the Hot.   The
poailbla  altInf «' eludge dlepoeal  on Deer Inland  le onmeleome.  The
nathod of eludge  dlapeoal by  Incineration la appalling.   Ho* can ea
agency each  ee  the Environmental  Protection  Agency,  one which le
devoted to the praaervetlon and protection of oar one  and only pro-
clou* environment poealbly cenelder burning eludgoT  It la well doea-
•ented that  whet lev  effacte  we   do  know  ebont  Idelneretlon ere
dengeroaa and harofal  to  any  the leeat.  The feet that  there ere eo
many  unknown fectora    Involved  la  thle   proceae  le  even  more
frightening.

     not  only have yen pat forth on  unacceptable elndgo elte recommen-
datloa and eludge dlepoael method,  but  you nave net even alloved the
voice of  my manualty to be heard ea tbln  leeue.  I em Inceneed et the
echedullng of tonight'! hearing which  happene to fell on the MM
evening that the Maea. Water Reeourcee Authority  le beating n town
eeetlng In Wlnthrop on thle and other leauee.

     I epeab for  ny  coeaunlty when  I eey  that I em adamantly appeeed
to  your  recommendation  end   to  your  echednllng  of thle  Important
hearing.I etead  firm In  my commltmeat  to  prevent  elodge dlepeeel and
aapeclally eludg* dlapoaal by Incineration  on Deer lalend.  I will
continue  to oppoee  you ea tbla  matter until much  time  on victory le
oura.
                                    Sincerely,
                                                            tik
                                                                                            IMPORTANTi
                                                                                                                     TO  MHOM IT MAY CONCERN.
                                                                         Did you  know that the (WRA) Masa Mater  Resource Aaaoelatlon

                                                                    IB  planning  to ««11   PELLETIZED (dried) HUMAH SLUDGE to cities

                                                                    and towns?

                                                                         It is ny understanding  that the  WRA has sent  out letters to

                                                                    cities and towns attempting to create a market for this sludge.

                                                                    Imagine this stuff being spread over lawns,  parks  and ball  play-

                                                                    ing fields that you  and your children will Inhale  as It peraeatos

                                                                    the air.

                                                                         Milwaukee has narkated  such a  product  for yean under the trade

                                                                    naae  •MILORQAJ«ITE"  and since the  attached articles have  appeared

                                                                    In the news  Media sales have dropped drastically.

                                                                         •HXLORGAJIXTB' IS SUSP2CTED OF  PERHAPS  BE INC A  CAUSE OP AUTO-

                                                                    TROPHIC IATERAL SCLEROSIS or better known  as "Lou  Cnhrig's disease."

                                                                      y With  the help of the -ItnA- 1 ami  personally waging a  one nan

                                                                    battle to keep the WRA from marketing HUHAN SLUDGE. If you are a

                                                                    family person* and care about our  chlldrens health I urge you to

                                                                    get Involved In any  way you can.

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               EPA Draft SEIS Public Hearing, June 27,1989
          Long-Term Residuals Mangement for Metropolitan Boston
                             STATEMENT
                                   of
                        Samuel R. Maloof, Ph.D.


     My name is Dr. Samuel R. Maloof and I have been a consultant in the
 •ludge management area for the past ten years. For coastal cities like Boston,
 land disposal of sewage sludge poses certain health risks and economic disad-
 vantages compared to ocean disposal of sludge. While the present practice of
 ocean "dumping" of sludge is banned by the recent federal legislation passed
 in 1988,  it has yet to be demonstrated thafWide Area Ocean Dispersal of
 Electron-Treated Sludge -  an innovative sludge management plan advanced
 by High Voltage Engineering Corporation a few yean ago but totally ignored
 by the EPA and MWRA would "unreasonably degrade the marine environ-
 ment .
    Implementation of a sludge disposal alternative based solely on land dis-
 posal, such as composting/heat drying with landfilling or in combination
 with incineration, over the objections of the communities involved is neither
 a practical nor a politically sound decision. The more intense public oppo-
 sition to such alternatives, compared to ocean disposal of sludge, is  indeed
 supported by adverse environmental and economic considerations which the
 MWRA should seriously consider before reaching its final decision
    Now, I  would  like to comment briefly on the sludge management plan
 adopted by the MWRA Board and the changes in said plan suggested by
, the EPA. Th. MWRA  ha. chosen to produce and market competed and
• heat-dned  (pelletized) sludge.  However  the EPA, with justification, seri-
i ously questions the marketibility of these products because of 1) increased
 competition from other producers of these same products, and 2) the level of
 trace contaminants (heavy metals, etc.) in these products. Consequently, the
 EPA is requesting the MWRA to consider two back-up alternatives  More-
 over, my own research and that of professor M.  de Bertoldi at the University
 of Pisa in Italy have shown  that composted sludge may not be pathogen-free
 and should  be further disinfected prior to its handling and use.
    The EPA has suggested that the MWRA consider the following two al-
 ternative residuals management plans:  the combination of heat drying and
composting of sludge with  landfilling;  or  the less desirable alternative of
combining heat drying and composting with landfilling at Walpole MCI and
incineration at Spectacle Island. Neither of these alternatives is economi-
cal or practical. Landfilling of composted/heat-dried sludge makes no eco-
nomic sense, after having spent hundreds of millions of dollars to produce
these products. Incineration of sludge is uneconomical, unreliable (consider-
able downtime due to unskilled operators), and can adversely impact the air
quality. Furthermore, disposal of the toxic ash could be a problem.1
    In view of the above considerations, I would recommend  instead  that
MWRA consider as its back-up sludge management disposal alternative the
plan: "Wide-Area Ocean Dispersal of Electron-Treated Sludge".   Properly
researched and managed it may be a more acceptable practice for long-term
municipal sludge management than land application, and could provide a
valuable source of nutrition for planktonic life forms essential for the pro-
duction of commercially  important fish.  It is interesting to note  that the
EPA views sewage sludge as a waste when disposed of in the ocean, but as
a resource when applied on land. Properly applied in the ocean, it could be
beneficial to marine life as some limited scientific studies have  shown.
    In summary, I wish to reiterate that while the public is generally opposed
to the ocean disposal of sludge, it is much more opposed to their disposal on
land or in the atmosphere, both of which are closer to their living environ-
ment. Properly managed ocean dispersal of electron-treated  sludge would
have several benefits:  the conservation of scarce land resources; the protec-
tion of groundwater, the minimization of human health risks; reduced water
and sewer charges to the 43 cities and towns; and the potential  for ocean
 productivity enhancement.
    •Contrary to what m staled on page 6, not all of the metals in sludge will exit with the
 exhaust aih (flyuh). My own thermodynarnic calculations indicate that the metals lead,
 cadmium and sine in digested iludge will be converted to oxide* on incineration and will
 be contained either in the flyuh ot the aih. Mercury will be carried off in the gas dream
 a* gaseous mercury.

                                    2

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                                                              O/-23
                                  July 14,  1989
Ms. Ann Rodney
U.S. EPA Region I
NQB-1900C
JFK Federal Building
Boston, HA 02203

Dear Anni

    enclosed ate consent* to the EPA'a 6BI8  Report dated Hay 1989
regarding Long-Term Residuals Management  for Metropolitan Boston.
One aet of contents are lion Mr. John Squibb, Assistant
Superintendent of Revere Public Works Department.  Mr. Squibb la
also a H.B.P.A. Regional Task Force Nesber for  the City of Revere.
Mr. Paul cacclola. Acting city Engineer for  the city of Revere, Is
responsible for the updated designations  of  newly constructed
dwellings on the enclosed aerial photograph. These figures were
supplied by Mr. Frank Strlngl, Director of Planning and CoadUinlty
Development foe the City of Revere.  I have  also Included my own aet
of commenta.

    All of us, along with the many citliens  of  Revere, agree that
the Harbor needs to be cleaned up.  Although Revere has been an MHRA
selected candidate to serve as a landfill as part of, the Harbor
Clean-Up Plan, It has Buffered long before the  site selection
process Incepted.  Our beach, renowned as the first public beach In
Alter lea. has already been a recipient of  sludge.  Our children have
all too often been banned from awlmming in our  water because of high
readings of pollution levels, a fact which has  truly sickened many
of us, especially being a coaatal community.

    He not only have water pollution, but we also have noise
pollution froa air traffic at Logan Airport. Me have air pollution
fros air plane fuel emissions, the RESCO  Incineration plant and
traffic fton constantly travelled major roadways.  Revere hosts
three HBTA stations, plus parking facilities, to neighboring cities
and towns.  Revere also entertains many people  froa outside our city
with the Wonderland Dog Track.  Should a  community comprised of only
six square miles be responsible for so much  and yet still be asked
for more?  we have already overburdended  ourselves as far as
regional responsibility.
    Our enclosed comments encompass the environmental, coat,
transporting and technical problems we feel EPA should address.  We
all want the Harbor cleaned up  but. at the same time, we want to
ensure that it Is done properly.  We maintain our strong conclusion
that Rowe Quarry la an inproper site for such a proposal.

                                  Sincerely yours.
                                  Denlse Salem!,  President
                                  Revere Citizens Anti-sludge Comm.
                                  N.B.P.A.  Regional  Task Porce Member
Enclosure

cc:  Steven Angelo, Representative
     William M. Bulger, Senate President
     George V. Cole 1 la. Mayor of Revere
     Michael Deland, Regional Administrator of  the  EPA
     John DeVlllara, chairman HWRA Borad of Directors
     Francis Doris, Senator
     Michael Dukakis, Governor
     Raymond L. Flynn, Mayor of Boston
     Maura Hennlgan Casey, Boston city Councillor
     Edward Kennedy, U.S. Senator
     John Kerry, U.S. Senator
     George Keverlan, House Speaker
     Paul P. Levy,  Executive Director HWRA
     Edward J. Markey, Congressman
     Nicholas Mavroulea,  congressman
     William Relnsteln, Representative
     Alfred Saggesae, Representative
     The  Revere Journal
     The  Revere Reporter

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own SIMIDIEV, RE.
     Michael R- Deland,
     "eqional Administrator
     U.S.  EPA, Region 1
     JFK Federal Building
     Boston. HA 02201
                                              July IB, 1989
                                          Hetropolitan Bo.ton
     Dear Mr. Delandi
                                                sr.-sss:
has provided E
and concern, b
Supplementary EIS
                           Usco-menta.
                               by BPH i
                                             from time to time,  and
                                            la requested those view.

       «n«tnation 01 •  ?»*•-	—	               M.,BI

           The H-RA ha. .subsequent to the^^-^StS*  ""'
       •oved to eliminate e™£B5|;*"9lO** fully supported by Qulncy. la
              support. EPA'. c.l
              and
                                                      ate agencies.
                                                     further
                                                                                utilxation of product on hand and  to be produced prior to 1992.

                                                                                    The continued call for a strong pretreatnent program la




                                                                                hv thB MWRA   in thla regard, the assumption*  about the removal
                                                                                efficient of a2condary treataent for acld-baae neutrala and non-
                                                                                or aeii-volStile Srg.Jilc. presented in Table 3.1-2 are considered
                                                                                unrealistic.
                                                                                                                                           have
                                                                                     For  econoaiic and operational reaaona
                                                                                         ^n^^f^
                                                                                          hS.?""ed alud.  The high cost •«

                                                                                                                .
                                                                                            in  nWRA program for marketing and  dlatrlbution of heat-
                                                                                       dred JlluSgS produH would be needl.a.ly '««"*«"« EI>lk
                                                                                       requlationa.  Therefore we disagree that inclusion of       .
                                                                                       in2in«atlon aa a backup technology ia necessary  or appropriate.
                                                                                         npoatinq at Quincv

                                                                                                                                                   he
alarm..


r..to^,°^u!ncr.n- BralnSe. B. ^rev^ee'E.^ ro. this
p?op2riy9inntSeBre^thp..t.Abut ijno-^i.^J- socioeco^ic

             The  statement in the DSEIS concerning absence or
          t elans for  the shipyard ignores the existence or tne
vore River Development Task Porce. involving Quiney. Braintree.
Ind Heymo^th! which  waa establlahed by the MWRA at Quincy a
tnaiatenle I Article  VI. HHRA-Qulncy HOU). and Qulncy a P""""
for beneficial redevelopment given expression in Article VII.
HOU.

     The assumption  made that properties in the vicinity will not
lamm value, aa a reault of residuals processing activity, based
on historic industrial exposure,  is also unwarranted.  That
Sxposu" hS.ceaSed  leffectively  in 1983-8*. sub.f "".My
diminished earlier), ha.ardou.  waatea have been or are being
remediated, and it is equally tenable to assume values diminished
.arUer".v. Seen restored,  'unles. EPA can buttress its
assumption it should be deleted.

-------
     EPA dismisses the  traffic impacts of composting at the PRSA
(see. e.g..  Table 6.2-1 and p. 6-81.  However, the adverse
conditions along the  preferred truck route are not adequately
mitigable through the measures proposed in the DSEIS. and no
other measures are feasible.  The addition of even a relatively
small amount of truck traffic at severely congeated intersections
will exacerbate an already difficult altuation.  No other
feasible, less-impacting, routes exist.  Contrary to EPA a
assumption,  there are no plans to continue rail haulage of bulk
materials after the conclusion of the Interim Sludge Project, and
Braintree has expressed strong objection to rail haulage.

     The DSEIS properly notes that  the areas around the PRSA are
by far the most densely populated,  with the greatest number of
sensitive receptors,  of all the areaa under consideration (or, in
fact, ever under consideration) for aludge treatment.  It alao
properTynotes and describes the numerous existing major sources
of contamination and  the several proposals (notably Clean Harbors
and Boston Edlaonl for  establishment of major new sources.  Yet
the public health implications of this situation are dismissed
(s. 5.9.6. p. 5-108)  on the limited basis of absence of predicted
exceedances of certain  standards or guidalinea.  Instead, EPA
should either assume  that on a comparative baais the gulncy-
Bralntree area should rank very poorly in comparison to other
aites on a public healtb baais, or  conduct comparative public
health surveys of the potentially exposed populations.

     For these reasons  Oulncy strongly objects and takes
exception to EPA'a determination that the FRSA la an acceptable
aite for composting of  sewage sludge.

     The general issues discussed below, although of concern to
the City, are considered of less significance than those above.

incineration at Stoughton

     There has been a showing of attainment,  in most eases by
wide margina, of air quality standards and criteria with
incineration at Stoughton.  Despite this, EPA has through •
aeries of very conservative assumptions created a concern for
water quality inpacta in two surface watera near the Stoughton
site, sttributed to potential  incinerator emissions.  The matter
is academic in thie Instance at thia time becauae  (1) the MHRA
has renounced incineration and  (2)  Incineration la neither needed
nor coat-effective aa a backup  technology.  However, the
methodology applied and the result  generated  deaerve careful
acrutlny because of implications  for other alting decisions, in
this region and elsewhere.  Quincy  understands the forthcoming
MHRA public Health Risk Assessment  will  Independently examine
this specific case, but alao suggests  the regulatory authorities
convene  an ad-hoc task group to critically review the methodology
and criteria which were applied.
Equitable Dtatribution of Regional Responsibility

     EPA adopted (p. 2-111 a very Halted definition of this
criteria, as followsi 'The extent to which candidate site
communities already host major permanent wastewater treatment
facilities'.  We believe strongly that this is far too narrow  a
definition, and avoids cooing to grips with a very complex
problen.  'Equitable distribution* should take into account  the
presence of public facilities (or private facilities meeting a
public peed aa an alternative to public facilities) providing
regional benefits or service, the local impact!e) of which are
(on balance! adverse or negative, regardless of the categories of
service, the nature of ownership or responsibility, or the types
of adverse impacts.  Without question, practical  implementation
of this concept will be very dlfficulti but nearly every  siting
decision must address the issue.

Elimination of Long-Term Privatization as an Option

     Quiney disagrees with the determination (p.  2-7)  that
•privatisation* is not • viable  long-tern option  for  residuals
management by the MHRA.  To the contrary, we believe  that »g*"CY
should puraua a parallel assessment of its viability  and  utility
through the same general process aa led to the current Interim
Sludge Processing program.  Only In that way can  a  fair
assessment be made of the applicability to the MHRA needs of this
growing management technique.
 Assumption that a Taking of Property II
 at the Stoughton (or Howe Quarry!  site
                                     Mould  be  Required
     The MMRA acquired the Qulncy  Shipyard  from its private owner
 over strenuous local objection  .   While  every real  estate
 situation and tranaactlon ia unique, there  ia little In the
 record to suggest that private  owners would not be  amenable to
 reasonable offers or are idealogically opposed to MHRA ownership.
 It  is certainly appropriate, and within  its mandate, for the MHRA
 to  aggressively pursue that approach.  It is certainly premature
 if  not erroneous to raise the 'taking' issue as a concern in the
 content of 'timely implementation'.

 Molae and Oder as Environmental Criteria

     It ia noted that noise and odor were, not listed as
 environmental criteria (p. 2-11).  although  they are both
 considered.  In some detail, elsewhere in the report.

                                 nts are offered with respect to
      The  following  specific
 certain Items  in the  SDEIS.

 Extent of Dewaterina  (p.  3-1U

      The  MHRA  Intent  to dewater sludge to not less than 25%
 solids should  be reflected in the BIS at p.  3-11 and elsewhere  in
 calculations dependent on assumed dewatered  cake aolida.

-------
Egg-shaped Digesters  IP.  3-2»

     MHRA has indicated that deaign of residuals processing
facilities on Deer  Island will consider the use of egg-shaped
digesters.  This  should be confirmed, and the discussion in the
FSEIS revised accordingly.

Boston Ed 1 son/Hevinouth site  ID. 4-33)

     BECo tentative plans for the Meymouth 'Energy Park' envision
a 100-MH generating unit  as the first of as many as four such
units at that aite.  Therefore the potential generating capacity
should be shown as  1200 MM.

Noise

     The discussion on p. 4-123 states that noise increments are
less objectionable  in a high-noise environment than in a low-
noise environment.  Ho foundation for this assertion is
referenced.  It is  well-established that a 3-S dB(A) noise
increment Is readily  detected, regardleaa of the threshold, by
most observers.  Therefore,  EPA should confine its evaluation to
that of changes in  noise  levels.

     Table 9.C-S  obviously  suffers from a printing error.  It
also presents rather  old  data on equipment noise, which should be
updated.

MHRA - Qulncv MOII (P. 4-204)

     The terms are  not* accurately reported.

     Thank you for  this  opportunity to comment on behalf of the
City of Oulncy.

                                  Respectfully.
Mayor NeCauley
J.A. HacRitchle,  Esq.
commr. Cotton
David Smith
Councillor McCrath
Councillor DeCristofaro
Councillor Cheney
Paul Levy, Exec.  Dir.,  HHRA
Eric Buerhena,  HHRA
Cwen Ruta, US EPA
Richard Kotelly,  US EPA
Kathleen Hull,  US EPA
                                                                                                              COMMISSIONRR
                                                                                                                        F AGRICULTURE
                                                                                                                       r ii mix i/Ht7
                                                                                                                       AIISI1N II KAS7H7II -niJI4l.l74ir.
                                                                                                         July IB. 1989
                                                                              Ha. Ann Rodney
                                                                              Hater Management Division
                                                                              U. S. EPA. Region  I
                                                                              JFK Federal Bldg., Room 19OOC
                                                                              Boston. Haas.  02203

                                                                              Dear Ma. Rodney <

                                                                                   X have just learned about the Environmental Protection
                                                                              Agency* a Draft Supplemental  Environmental impact statement -Long
                                                                              «*" ««*"J' "•"•<»"•«"* *°r Metropolitan Boston," issued In
                                                                              May. 1989.  I wlah to register a few brief comment* on it.
                                   David  Standley, P.B.
                                   Consultant to the City of Quincy

                                     Steven  Llpman, DEP
                                     C. J. O'Leary, DEP
                                     Peter Koff. Esq.
                                     David Graber
                                     Donna O'Sullivan
 T»».^         5'i>4'5 °*tn" draft Supplemental Environmental
 Impact Statement makee it clear that Boa ton 'a aludge would be
 marketed as  an agricultural fertilizer in Teicae not because of
 Its high quality and not because Texas ie asking  for it  but
 because EPA  believes that it can get away with marketlna it in
 Texas without objection.  The Environmental Impact statement
 Ifll-Hir-"1*^'11" »oly»xi«num l«vela may not Meet Massachusetts
 standards, the mercury levels may not meet Vermont standards,  and
 the cadmium  levels may not meet Maine standards.  You acknowledge
 that  ...the prelected concentrations of ... copper and  cadmium
 (for Teliae)  could cause its use to be control leSrind its
 application  on land may require prior approval of the states'
 environmental  agencies."  Vet still you state that -the  best
 outlook for  [Massachusetts Hater Resources Administration]  sludge
 product land application may be in Florida and Texas."   EPA
 appears to be  shopping around for states with less strlnqent
?h^r?:"StaI^t^d'5?9 ?° take the Problems of other sS"a.
That is beneath the dignity of EPA.


we wlllCln.?"?U^ r>?..tl!at lr.the BoBtOB "I"*** comes to Texas.
we will insist  that it be monitored to make sure that it meets
2»n*°SPi!"V    cadmium standards,  as well as standards for other
™2fr"Td2".T       ? at the ™a8 D-P-rtment of Agriculture promote
sustainable, environmentally sensitive agriculture.   That

-------
                                                                                                                                                      0134*
Ms. Ann Rodney
July 18, 1989
Page 2
includes wastewater reuse and sludge reuse.  The biggest problems
we encounter In encouraging beneficial rauae are when sludge  la
not properly treated and when sludge ia not properly applied.
Sludge that ia toxic enough to be rejected in Massachusetts,
Vermont and Maine cannot be shipped to Tanas and be willingly
accepted.  Nor should It be.  The waste must be pretreated at the
industrial plants, resulting In a municipal sludge that Is aafe
to use agriculturally.  Your Environmental Impact Statement Is
flawed because It does not adequately address that alternative.
                          Best regards
JH:gkl
                       DEPARTMENT OF THE ARMY
                     NCW INCIAMO DIVISION CORPS Of CNCMICHS
                            «M TRAPf 10 MMO
                      WAITHAM MASSACHUSfIISOlM4«l«g
                                                                                                                  July 19. 1989
CENEO-OD-R
Ann Rodney, Program Assistant
U.S. Environmental Protection  Agency
Region 1
John P. Kennedy Building.  WQE-1900C
Boston, Massachusetts  02201

Dear Ha. Rodneyi

    lie liuvu reviewed  Lliu Muy  1909 Draft Supplemental
Environmental Impact Statement regarding the long term residuals
management for metropolitan Boston and provide the attached
comments.

    If you have any questions, please call Peter Kube at  (6171
647-8493.

                                   Sincerely,
                                                                                                                         Vmam  P/
                                                                                                                         Chief, Regulatory Branch
                                                                                                                         Operations  Division
                                                                                       Enclosure

-------
July 12. WW

oc OTIZBTS THOUGHTS
c,

                                          0

                                                              128
                                                                                                                                                                                 Oltt
                                                                                                                                 IMG HE SITIHC or A HAZARDOUS HASTE ncmnAint
                                                                                                      nnt, •» I thnk you foe  Ukii« the tta. to wad thi« "l«tter".  I will begin
                                                                                                      K .Utlli rlSttT,! l^t that I don't belUM NuMhcuMtU ihould tav* *ny put
                                                                                                      In citing a haurdaui «ut« incinerator.
V» fact UiM I cMlda In Qulney end dun Haitore went* wy «uch to build •
MUM inelneratar In Ewt Braintree «u the direct cause of ey  penonel liweetlgatlon
Int. the fact, eumuriln* hetaidou* wst. lncl~r.tlon.  » initial deelre «. to
help fight the eltlng of such en Incinerator  In ey ceemailty, but the (•ft* *•*
hevc been learned resulted in a broader atataecnt.  Vila Incinerator SHDUU) HOT BE
SITED MnWEBE IN TOE SDOE.
                                                                                                      dean Harbors argues that HMsachuaetta axparta 601 of ita hasardous waste
                                                                                                      therefore needs this incinerator.  They will argue that an October,  1989 -—-—
                                                                                                      deadline favors their plan,  then October cca.es I doubt vary such that all 50 stataa
                                                                                                      are going to have a plan in place (unless it's to sand their waste to  Ot in
                                                                                                      Iftuuurtuietts for incineration), and logic would  lead ae to believe It will notbe
                                                                                                      the warat problaa in the world if Hassachusetts la cautious and l~J«"  "P» "•**»"»
                                                                                                      and studying further what alternatives eilst". Mssachusetts cannot afford to Juap
                                                                                                      on the incinerator band wagon in the adstakcn belief that turned le gone".
                                                                                                      Incineration has a certain appeal in its ability  to aato haurdous HUM
                                                                                                      vanish into the air.  Incineration la proaotad aa • aiapla end chev.-
                                                                                                      solution to the disposal of the vast quantities of hazardous wastes produced i
                                                                                                      U U totaftdrtnTthsValr aa a landfill in the sky".  Hssardoua waste aust be kept
                                                                                                      out rf tnTalr. water and aoll. Disposal of wasta of any kind, particularly hatardoui
                                                                                                      and nuclear wasta is not a problaa with a ready or easy eolutIon.....that  is the
                                                                                                      danaar of incineration, it la too easy to view incineration as a solution.
                                                                                                       telner.it* ton.1 cur. any of our probleaa, but  it doe. «* Rr-tly to lha
                                                                                                      biggest problem that aan has, or aver will have,  wa are destroying thesnviro    t
                                                                                                      iBanwhich wedm! foe life Itself.  Incineration onl* hastens ita deaiae.
                                                                                                       Society aust face this difficult problaa and wrestle with  it.  There are no easy
                                                                                                       solutions and wa aust not be arrogant enough to pretend wa have found one in tna
                                                                                                       inclnsratlon of edlllona of tons of  toxic wasta aeterlals.

                                                                                                       that  broadened ay perspective fro* being opppead to siting a toxic f-tataei
                                                                                                       in East Braintrae to being opposed to siting a toxic wasU incinerator anywhai
                                                                                                       fiysiai
                                                                                                                 ;ts7  facts, such as the followingi

                                                                                                            .Metal, ara not dastroyd byl«einar.tion._•«««««J« • •?-».«•»•_
    _T63ian* Croup,  thTair in East Braintrae already contain, five heavy a»
 DUAL TOiataamSsSTATE OUIDEUHES FOB WAT is ALLOWABLE.   Arsenic, cadatua.
 anddKaaiiai^raVs high os the air saturation  in Southern California, considered to
 be the want air in the  country.  Anlaony, araenlc, berylliua, «>dl>M>^'^UBL||)
        -   -                  y, aBlybdenua, nickel, aaleniua, tin. vanartliai, ma


                                                              thaaa  idantlf lad in
                                                                                                       ..,, .r,  icao, ••e^iMiiii, aercury
                                                                                                       •ins ara released in .tack gases

                                                                                                       Other  fbxins era craatad when hasardous wasta la burned.
                                                                                                       an EM study of eight hasardoue wasta Incinerators were -
                                                                                                       tatrachlorothylene. napthslene, foraaldehyde, phosgene. *-—-- -~--
                                                                                                                   r~~ of Ihe snst toxic subeUncaa known to endem acienco.
                                                                                                               are not a single dwalcal but an entire family consisting of 75 different
                                                                                                              . Via aaaunt of chlorine attached datandnes the toxic potential of the
                                                                                                       plaWM COTtileUel

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ONE CITIZEN'S THOUGHTS REGARDING 1KB SITINC OF A HAZARDOUS WASTE INCINEXATOB
                                                                                                       CHE CITIZEH'S THMGHTS REGARDIMC THE SITING OF A HAZARDOUS HASTE INCINERATOR
	tilting dloiln.   Dloiin la  Ilka • cheelcal "key" that fits Into *Vn>teln receptors"
In our body enabling It  to enter nany parts of the body. Making ua vulnerable to
dloxln's harmful effects Including, but not United to, cancer, birth defects,
reproductive failure, and ionune systeo disorders,  further, dloxln is fat soluble
end is passed on through the  food chain and stored In fat cells of each organlsn.
One dloxin, tetraehlorodlhenzo-p-dlOKln (TCDD) Is the deadliest substance ever
produced. It* Unlclty has been coopered to plutonlua.  The EPA's procedures for
handling these two naterUls  are the sane.

Controls - lectors controlling dio«in and furan formation are not fully understood and
therefore it My be loposslble to eliminate their foraatlon. Incineration creates
and releases these hazardous  chemicals.  Dioxlns are considered so toxic that a safe
level of exposure  cannot be determined.

The Incinerator One EM report states....the complexity of the incineration process,
the differences In Incinerator designs, and the difficulties In Monitoring changing
operating conditions oske the accurate prediction of absolute Incineration perforamce
an essentially ianosslbU — •• M
EM requires destruction and renewal efficiencies (DRE'a) of 99.91 of son
waste and 99.999?! for such Iteas as KB'i.  DKE'a are detendned during a
                                                                        i hazardous
	          _	                                  _      -tine-only
"trial burn" under carefully "controlled conditions.  According to en EPA report the
trial burn Method provides only a snapshot of the Incinerator's efficiency during
the trial bum.   The EPA Science Adviaory Board expressed concern on this issue as
follows	"Research on the performance has occurred only under optinel burn
             conditions and sampling has,  on occasion, been discontinued during
             upset conditions which take place with unknown frequency.   Bwn
             relatively short-ten operation of Incinerators in upset conditions
             can greatly Increase the total incinerator emitted loadings to the
No Incinerator con produce a totally "clean burn" but if we assume that it is
possible for dean Harbors to produce a 99.9X clean burn there Is still .11, or .001,
of these toxins  escaping Into the environment on which we depend for life Itself.

Naasachusatta produces 200,000 TONS of ouch toxic waste each year.  CleanJtarbors
will burn 45,000 TONS of hazardous waste each year.  Won't the other 155.000 TONS
eventuslly be burned at CUT  It has been reported that this Incinerator vill have
tha capacity to handle 90,000,000 TONS of hazardous waste.

        45,000 TONS of Mate x .001 • 45 TONS or 90,000 pounds escaping each year.
       200,000 TONS of waste x .001 - 200 TONS or 400,000 pounds escaping each year.
    90,000,000 TONS of Mate x .001 - 90,000 TONS or 180,000,000 pounds of toxins
       entering the air and environment each year.

Con anyone honestly say this is not going to have • hacardous effect on health?

Let's for the Moment give aeon Harbors every benefit of the doubt and assuas that
they can construct  an Incinerator that is 99.99Z clean burning.- Using the figures
above, they would translate to 4.S TONS or 9.000 pounds escaping each year.
20 TONS or 40,000 pounds escaping each year. or. 9,000 TONS or 18.000.000 pounds
                              This Is not any MOM acceptable.  Can you Imagine
                              •thing you cannot even see with the naked eye?
 of toxins airborne each year
 how such 9,000 pounds is of
 PLEASE, MASSACHUSETTS CANNOT AFFORD A HAZARDOUS BASTE INCINERATED SITED ANYUHERE.

 We have becase a society to concerned with air pollution caused by cigarette

 please continue
 SMOKING (each one a tiny incinerator) end so worried about the passive smoke that
 cigarettes create...now can we possibly consider incinerating hazardous waste?
 Everywhere you go today little non-soaking signs have sprung up in our atteapt to
 banish ankers and create "safe" ereaa where people can be protected from cigarette)
 enoke.  why don't we realise that a hazardous waste incinerator, ANY INCINERATOR,
 MAKES SMOKERS OF US ALL. without, I Might add, any of these little "safe" areas
 we create with our non-snaking signs.

 Disposal of waste, including hazardous waste and nuclear wast* is not a problem with
 a ready or easy answer.  That fact Is one society oust accept and wrestle with.
 Clean Harbors argues that Massachusetts exports 60£ of its hazardous waste and
 therefore needs this Incinerator.  They argue that an October 1989 federal deadline
 favors their plan.  I don't believe that  when October cones all 50 states are going
 to have a plan for disposing of hazardous waste in place (unless it's to send their
 waste to CH In Massachusetts for incineration).  Logic leads ne to believe it will
 not be the worst problen in the world if  Massachusetts saya..'W are atlll studying
 the alternatives.1*
Massachusetts cannot afford toJuxp on the  incinerator band wagon believing that
what you see does not exist.  There la too ouch proof  of excactly what dangers d
                ~m BM» ""n nal •** !•'• IBM** *4> ••_!•» •»	*	 ._.•__   •_u.l_^.	a. 1 —
                                                                                                                                                                    elae.
                                                                                                                                                                                     do
                                                                                                                                                                          Incineration
eiiat.   Burned le not "gone" it'a Just dunplng it so	   	
does not cure any of our problem, as I stated  earlier, our choice  la going to be
a aore difficult one to Make and involve a higher level of creative thinking.

According to May S. 1989 "The Klpllnger Washington Letter" a coaprehensive new clean
air act is expected to be voted by Congress.  Even the President  is expected to push
for action against aaog, acid rain, carbon nonoiide and toxic air pollutants.  In
addition, tougher enisslon rules will be added  for cars and trucks  nearly everywhere
in the country.   Mil we instead decide to incinerator

I'M sura no one has any idea what the effect of incineration ta on  the ozone leva!
and resulting greenhouse effect Most of the world la now concerned  with.   Will we
In Massachusetts decide to incinerate?  Obviously. I hope the answer to the question
will be to!

There are
trend
                                                                                                            are agencies, Greenpeace end HASSPIRC, 'anong then that ore concerned by the
                                                                                                            toward incineration.  Many thoughtful and  intelligent  people on concerned i
                                                                                                      ways to solve the problems of waste disposal, particularly aa the problen relates)
                                                                                                                           Other ways sinply have  to be found and  put to use.
                                                                                  with
to hazardous waste.
                                                                                                       In closing, I wish to thank you for taking the  tine  to read this.   My hope ia that
                                                                                                       you will seriously consider the facts presented here and  if necessary avail youraelf
                                                                                                       of other Materials available regarding the dangers of  incineration.  It does sound
                                                                                                       like a staple and easy solution	but IT  IS  NOT.  He all oust breath the air, or
                                                                                                       rather the air we choose to produce.  If trees  in northern New Hanpshlre and Canada
                                                                                                       are being killed by acid rain produced In the old-west it Is difficult to Ignore
                                                                                                       what adding More pollutants (and More dangerous ones)  to  the air will do to all life.
                                                                                                            truly.     sj
34 Harrison Street
Ojuincy MA 02169

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                                                                      QIS1
                             • * •' « i MOffTMEAST
                                   July 19.  1989
                                                     Ref.  736000
Ha. Owen 8.  But*
Water Henagement Dlvlelon
U.S. IP*. Region On*
JFK Federal  lulldloi
Boston, Haeaachuaetta  0220)
          •I:
              Draft  Supplemental Environmental lopsct  Statement  (SEIS)
              tons Term Realduala Hanageaent for Metropolitan Boston
Dear Ha. Rntai
     TVM Northeeatt  Normandoeu Engineers, Inc.  represents the City of
Revere regarding tho Haaachuaetta Vater Riaourcea Authority's (HHtA)
proposed aItlag of the reelduala landfill it the Row* Quarry.   Since
November of 1987. we have reviewed all of th* documents pobltahed by the
MTU pertaining to realduale management and filed commente on behalf of
tha City to the HEPA Unit of tho Executive Office of Environmental
Affaire.  Ve are today filing comments on the 8BI8 prepared by  EPA on
behalf of the City of  Revere.

     It la th*  paeltlan of the City that th* selection of the Row*
Quarry alto failed to  meet the basic eelectloB criteria eatabllihed by
the NAU for a  reeldasle landfill.  Tha land use aarroundlng the alto la
that of • densely esttled urban realdeatlal neighborhood with highway
commercial actlvltlee  and the propoaed landfill IB Inappropriate an the
haala of goad engineering, public health and urban planning standards.

     Our commute OB the SHIS ere organised to follow tho format
aatabllabed la  that  document on a page by page reference.

General
     no Council on CnvtroaaMital Quality (CEQ) atandarda  (CFR 40
Rec. 1302. Iff) arc the principal guideline* for evaluating tho adequacy
of an environmental lopaet  atetenent.  Ve believe that by  producing  a
•piggyback- 8118 ohlch dreva ao hravlly upon the hVRA'a om technical
atudlea for realduala oanageeent, F.PA haa accepted may of the aano
fnndanental •anagenent aaaunptlona and failed to produce on Independent
analyale of the problro.
                                                                     ^^-*>
Me. Oven 8. Bute
July 19. I9M
Page 2
     Ve questIon whether. In feet, e complete  range of  alternatives ban
been examined end whether the enelynle In the  RF.IS has  been rigorous
eonslatent with CEQ Quality etenderd*.  Theee  etsnderds require that:

          "Environments! Impect statrmiints shall enrve  ee  the means of
           assessing thai envlrnnm»ntal Impset  of proposed  egsney
           actions, rather than Justifying decisions  alreerty made."
                                                   (40  era Sec.  1102.2g)

Ve do not find basis for tha atatrmrnt on page 2-8 that tho EPA
"...critically evaluated the process by which  the HUM  developed and
•erecBed Ite candidate options for residuals management."   The entire
dlacuealoa of realduala management and landfill elternetlvee rsnds aa •
mere recitation of HwllA'o own analysis and conclusions. In this regard.
we raise two examples for your consideration aa examples of how the SEIS
failed to esemlne rigorously the HVRA'a conclusions.

     rtrat. IB both the HHRA'a Pratt Report OB Uodfllllnn
Alternative* (1988) and tho EPA'e SB IS. the alternetlv* of lendfUllag
reeldnala IB caomarclal lamdfllls la not addressed although tbla la tho
current HMU method for dlepaeet. The Stone and Vebstsr report Interim
Blodae Dlspoaal 8t*dv (198J) determined thet were more  than • doaen
loadfllla and eight Incinerators within • ulna atat*  ragloa that
expreesed • capacity and willingness to accept reeldaal* or *ludg*
produced by KVRA. Tble coastItntes an acceptable No Action alternative
bat the EPA failed to Include tbla In the 5EIS.

     Second, th* original criteria aetebllahed by tho IMRA for candidate
•It* ••lection for landfills required a minimum sis*  of 100 acre* and
adequate buffering from surrounding  lend unee. The Row* Quarry should
have been rejected Immediately on this banla.   Instead, tho HMU changed
Its crlterle to Include eltee leaa than the minimum elae If adequate
capacity existed due to specific topographic  features ench as a quarry.
Aa we will see below, tb* EPA1a analyala of total capacity requirementa
for reelduels end elodge'products until the yeer  2020 lesde It to the

-------
Ha. OH«O 8. Rnto
July I*. I*B*
•ana >
cone IMIon that Rouo Quarry doaa not  huva advquat* capacity and a a*cond
landfill or laclnarator nlll ba rwnilrad.  Tharafor*, th* anltablllty of
tho Ron* Quarry alto faIla to noat both th* olnlono ala* and tb*
capacity roqulrooaota aatabllahad by  th* HVRA.  Hont»r* In tb* SEI8 la
thla laaua ackoo>l*d«*d and thor«i|hly  uonload.
     2-1:      V* oot* that EPA placaa particular oophaala OB
"Idmtlfylag unoltl|abla coaotralnta" or unaccaptabl* alt* condition*
In acroonlni tbo altarnatlva altaa  propoaad  for rmlduala oaoagooant
facllltloa.  Vboro tbor* ar* V*aoptl«* or  loconpotlbl* land oaa." and
"phyaleal and land-no laataraa that could Holt tb* attalnoMt of air
quality objoetloaa," proaonably tho EPA mold rocoauMnd that a alto bo
rojoetad.  Aa dlacoaaad latar In Chapter 4.  th* propoaod landfill at tho
ROM* Qaarty alto baa MM potontlal  for baconln, a odor aulaanco and la
anrroondod by Ineonpatlblo land uaaa vlthlo  tb* I hlloMtor parloatar.
Tot, tb* IBIS doaa not ackoonlodt*  that thaao conatralnto ailat at tbo
ROM Quarry alto a«ao thoo(h tho *¥ld*nc* la pr*aant*d.

     I-lli     Aecordlni to tho IBIS, tha EPA placad an onphaala on
confllcto botoowi th* propoaad landfill and ailatlng or propoaad
land we aa mil aa th* nunber of hnoan ••poaur* patbuaya preaant at th*
alt*.  noiMvar, In AppandU C, Tabl* C-I aatltlad Ron* Ou*rr» 8*naltl»*
Racaoteia. tharo are approntaatoly  10 adjacent racaptora (achoola, a
our a log bone, reaMwicm, apertaant houaoa, trallar park, etc.) vlthln I
hllonoter for tihleb public health la noted aa a potential concern by
IPA.  One oumtlooa how loportant • criteria public health can ba In tho
EPA'a analyal* If they find ROHO Quarry to be "envlronuentally
accaptable for a landfill	" («-6) |lmn the Intent I ty of the
aeaaltlve rocaptora In the vicinity of the alto.
 Hm. Owen S  Rut*
 July 19. 191*
      4
      2-IS:      While admittedly low* Quarry  li an  active loduatrlal
 ion.. It lm an hlatorlcal land uao which la pre-ealutln« and
 iBcaupatlble with aorroundlot luid uae which  urn primarily raaldeotlal
 •ad blihway caonorcUI.  «• believe that far  too arch eephaela baa boon
 placad on tbla fact by both th. DMA and tha  EPA and too llttU oo tb.
 lattar.   !• oar opinion, tha Row* Quarry could not  conply with tha
 Haaaachuaatta lit* AaeUonent Crltarla for landfllle iihlcb la  Indicative
 o( ban poor • choice thla alt* la for tba propoaad  project.

 Description of Alt*rnatl»M
      J-*ti      It ll tnteroatln. to noto that Hollo too population of
 Valpolo 11*0001 la atatod on tha pravloua pat*, tbo population of
 Naldao (H.4I4) Md Revere (39.112) ara oot.  HM BEI8 aboold provide
 tha aooa data baae oo aacb cooeunlty or olto dlacnaaad to eeable tbo
 render to draw an Inforaed opinion aa to tho validity of th* cooclualona
 !• tho docuoaat.   Nor* to tho point In ouch • dlacuaaloo la the,
 population  within • soon of tapact of tbo propoaad landfill.
     taaldenta Hltblo On* Mil* of  th
               Maiden/Revere
Population
II, IU
Malpole
1,400
While  It  I* correct to atat* that Hnldan and Revere ar* "botb d«ta*ly
populated urban c commitlaa."  It la noro to tho point to atato that tho
ROM* Qaarry alto uaa perhaps tbo ooat danaoly populated caadldato alta
on tbo HMU llat of potantlal  landlllla.  Furtbar  analyala of
daoographlca on thla alto lodlcota that tboro ara  ooro than 2,100
chlldron  and ovur 2,000 raaldanta 6S jfaara  of a|a  or oldor vlthln ana
•II* of tbo Row* Quarry alta.  Typically, pooplo In thaa* cohort (roup*
•ro coooldarad to bo particularly aunaltlvo to  anvlronoantal or public
boaltb rlah.  Tb* BEIB ralla to dlacuaa thla laauo to any dagr*o for
oltbar tbla alt* or toy of tbo othara **aluatod.

-------
Ha. OH.O 8. Ruta
July 19. !9Bt
P.g. S
     *-li      Tba BEIS point, oat th.t th* HVU la r.oulr.d  to  obtain
"all aacaaaary fadaral paralta and •pptevalii hovavar.  It  la  not
roaalrad to conply tilth all atata Ian. and ragnlatlona  bacauaa It vaa
latandad to ba an lad.pwd.nt public mtlty."  If tbli  la  th. caaa. th.
SEI8 ibould addrata Iron Hhlch lava of lha CoanoniMaUh th. IRIRa la
aaanpt.  Th* HMU baa publicly takui th. po.ltloo that  It  la  uo^it fron
th* Bit* *aalannant Crlt.rla for Solid Vaat. facllltlaa yat currant DGQE
policy dooa U fact raqulra alt* aialgnnant far iludg.  and raalduala
golag to landfllla Iron publicly om«l uaatwatar tr.ito.nt facllttlaa.

     ••Si      * ravlov of tb* land vaa aap of lha Malpola rci alta
(flfura 4.1-1) laada ua to tba conclu.lon tbat lha all* la baat
eharact*rll*d aa vaeaat/ondavalopad or Inatltatlonal not "prtoarlly
raaldmtlal..." vlthln on. oil*.  Tharafora, tbla alta  baa adaquata
buffarliuj Iron adjacaat raaldancaa.

     *-9i      mil* local aonlni In Valpola claaalflaa tb* alta aa
rural or raaldanllal.  th* cornet d.*lgn.tlon aboald h* Inatltutlonal
aUca It ouuad by tha Counomiaalih of Raaaachuaalta.
     4-llt      tlaur* ».!•» Sena Quar
On* Hll* of lha an. la  Incorroct and prejudicial.  Najoc portloa* of
tba aarremMlIng aroa ara labalad vacant/und.*alopud vhaa In fact tha
appropriate claaalflcatlon la racr.allon/parke/coaaamlIon land (Mount
•uod Park to tba nortnveit and Rwaoncy Narib aCEC to th. aoutheaal of
tba alto) or raaldaatlal (rranklln Park mlghborhond to tha northaaat
aad vaat of Sroadvay Strael In Nald.n).

     *-lii      Tha  reallinoeat of Rout* One la an active DM hl|hvay
laprovonunt project Hhlch la currently In the daalgn at.ga-.  It la
Incornct to t.n It a "propoaar a. tho SEIS and MIR* docunonta
contlaaa to do.  Our aaalvala of the 01V plan* Indicate* that
approalMlaly Ian acre*  or 20X of th. ROM Quarry .It. will b* taken (or
Hi  Oven 8. Rut*
July 19. I9M
Pag* *
tho n illjiMint of lout* DM.  TM*  repra..nla  • alanlfleant clung* IB
tin "projected baaollno condition"  far  th.  nlta  which tb* SEIS fell. to
addroae.  Eacavatlon of the quarry  wall on  the we.t.rn *ld* ol the .It.
during construction of th. lout* On*  re-.llga.wnt »«» reoova •
elgnlfleaat topographic vlaual buffer which ehlelde. to • Italted
••tut. alagl* family reeldencaa •l«t|  Rennrdy Drive.  Vlth thin weet.rn
••II ronovod, theae reeld.ec.. «lll leak etralgtit aeroaa Rout* On* Into
the landfill.  Th* dlacuB.ion la unction S.7.J should bo correct** to
rofloct thin  feet.
      Redevelop***! Of tb* ROW* Qn*rrV •«• •• • plamiad «">»
development  (mlied realdentiel. commercial or olflc. nee.) to • propaeal
Mdo by th*  ommra *nd on* which h«« r*e*lMd nthoilntlc ••pnort of
both Mldn  MM! tow*.  Th* SEIS •boald at l*nt not* thl* ptopoMl
• lac* It h«* th* pot«itl*l to china* th* vary r**«m *t«t*d by both th*
EPA and th*  MflU for th* ••Itiblllty of tb* lit* u • landfill:   tbit
 1*. tb* lit* I* an "*ctl** Indntrl*! •on*."
      Tho dUco**lo»o> lad «.. d*mlopB*nt !• In* vicinity of th*
 quarry (Soetlon ».!.».3) la l.*d*o,«t*.  H* aro*  lafonod by public
 officiate ID Haldwi and favor* that, vlthln ono-ball •!!• of  tba alt*.
 thor* baa bam alanlfleant convaraloa to raaldantlal  land oao In racont
 y*ara.  O**r tuo-hondrod aalt* of •nltl-faolly cln*t*r^ torn heoa*a
 ha** b*m althar conatntctod. approved or analtlna approval.

      »-7Ji     !• Saetlon «.].». th. REIS d*flmia tho air quality atody
 ar*a of concern aa on*-hllon«t*r p.rlo.t.r aronwl  landfill  altaa.
 Homvar. In Sactlon ».i.J on paa* »-!•». th*  atody araa for d.t.ralnln|
 potaatlal public haaltb  lopacta  la  d.flnvd aa a  two-hlloMt*r parloatar
 around  landfill altaa.  Th« dlatlnctlon ..««• contradictory and
 Illogical.   In addition, only NilldlnM thraa atorlaa or hlgh.r ara
 conaldarad to ba apnaltlv*  r.e.ptor.  yat noiloua landfill odor, aro

-------
Mo. Owen S.  Buta
July l«. l*8«
Page i
characterised as being "eloeer  to tin ground."  At the Ron* Quarry,  two
story single foully residences  ring the perlMtsr on three ildee  SO  to
100 feet above the cite.   Mill* they My not couply Kith the EPA'u
definition, the feet le that all of theo commute sensitive receptors
liven their •levatlea.

     »-l*«i    In section ».».!. the  land use In the vicinity of  Rate
Quarry la character lied n "highly  Induatrlal and cauMrclal In
nature	*  Our analyela of aerial photos, the (RGB oep. windshield
narveye and the land use nap contained  In the 8EIS leeda as to the
conclusion that the surrounding area  la prlMrlly reeldentlal In  natere
• lib cawwerclel actlvltlai adjacent to  the highway network.  In fact.
the SBIB previously characterised the area •• danaely populated on
J-4».  nia characterisation la Inaccurate and not Internally consistent
•Ith prevlaua portlena of the 8EI8.
     4-USi    The 8118 la vague regarding the euwber of raaldancaa
having direct vlem Into the 'euarry and the propeaed landfill.  The
Oreneda Rlghlanda cawplei cooalata of thirteen apartamit balldlnga of
which eight are blgh'rlae structures (night floors each) and five ere
 low rlan.  Thorn are »lt mite and approslMtoly 1000 reaIdeate.
Several hundred other ranldencwa have view* In the general vicinity of
 the proposed  landfill.  The Town Line Eatates Trailer Park consists of
 approilMtely thirty nnblle hones to the northwest of the qearry.  Thla
 neighborhood  has direct line of alght Into the proposed landfill acroas
 •onto One.

      4-IB)i     In neveral  location!, the MIS acknowledge! that
 "Populations  particularly aanaltlve to health  Inpacta (are) the young,
 elderly and chronically III...."  In light of thla,  It  la difficult to
 accept, ouch  lass wndnrstanri, as we observed earlier, how the EPA
He. Ouen 8. Rute
July I*. I*S«
Page 8
conld Inter COM to the conclusion that "The Bawe Quarry  otto la
onvlrMumtslly acceptable..." («-») a I nee Table C.2  Hate  eard than
fifty nonslllvn receptors In closo proilnlly to thn propound landfill.
On 4-187. the SEI8 no tee that them arn II achaola. two nuralng howe*
with apartamta for the elderly and II churchea anew  of which provide
day care facllltlea.

     4-20J:    Oncn again,  the 8EI8 la  Internelly  Inconalateot end
Inaccurate. On thin pege. the Bowe Querry nlte le  charactarlned aa being
located ID "• naderately developed aree" when  In  fact the area Is
densely developed.  While tbn HIS ecknowledgea that  approclwetely 140
residences are within  1000  (oat of the  site, there la no dlncuanlon of
the aubject of partial taking or  thn  Inpect OB the •unlclpulltlee of the
nubntontlal decline  In property valuaa  ahonld  the landfill bo
conetracted.  la  falling to addreee till*  laaue. the SCI8 (alia to
conply with the requlroMntn of HEP*  that  thn  economic lepacta of the
propoeed altematlVM  bo thoroughly evaluated.
      J.J:       la evaluating tbo available capacity at Bawe Quarry for
"taaldaala sod landfill Ing of sludge products, the SEI8 coactudoa that
 the alto doaa oat provide "reliable capacity far the fall project
 planing period (H9J-20IO)."  Thla leads one again to amstlaa tbo
 validity for aelectlng thla nlta In the first placa alnco It bss failed
 from tbe outsat to e»et the bsslc selection crlteila.  If the  EPA was la
 fact critically evaluating the HHRA'e alts selection analysis, aa It
 contends on 1-1. then the Bowe Querry site should heve been rejected at
 tbla point If not earlier.  He beve previously noted that tho  alto
 failed to neat tho bsslc sUe criteria of 100 acres and was only
 Included far further analysis because of Its supposed superior cspsclty

-------
            But*
Its. Owen S
Jaly I*.
Pa«* t
by virtue of Ita bain, a daap quarry.   Balhsr than d..ll«. «lth this
f la* in the IMtt'o daclsloa o*kl.(. tho SKIS oovss on to tho
unbelt..*., conclulo. that  T..r.toro. an «Mltlon.l  l.ndflll or
Incinerator imuld bo neod«l." a 'Cull and lair" (CEQ)  critical
•valuation of tha IMU'a analysis by the CPA should  lesd to the
conclusion that tha alto selection process MS Monad as It pertalna tn
thin alto.
     5-»:      The list of significant crU.rls lor .vslootlng land us.
Inpactn soon* iihnlly Inadaqnato and not cuoalntant tilth tradltloo.l
crltarla of coKstn I. urban pl—l-B •Ml-.to. I- « ••»•« ••"'"S.
public facility siting nvaluatlao In noro typically, but not nulualvely,
coMoined mth th* conslstnncy of th. proposed action .1th adjacent land
MO and the possibility of disrupting neighborhoods or con-unity
cohesion   Caopatlbtllty tilth local sanlng Is • good osasaro of the
offoct. of *h. prop~*d acUo. on Isnd ... .lth«*i a ll.ltod one.  Th.
BEIB note* that  conflicts nil.  local  land as. policy fill conatltM. •
significant tapact bat quickly  glo.se. avar thl.  by noting that th. WU
In asnupt  fro. thoao concarna.   Induced  Isnd nan  chsngaa reanltlng fron
landfill ailing In the Tan of  ta..bury. Nosoachusott.  la r.furancnd but
not  o»pl*taod. leaving tha raadsr of  th. BIIS to gu.ss  st tho
algnlflcanca of tho reference.   II  lh. nnssbniy ..peileac.  U
 •Ignlf leant enough » nentlan.  thao the BUS should .laborst. on  thl*  an
 tha cosnunltlo. of Walpola. Haldan and l.varn can ban.U*  from tnean
 lassons.   If the EM ha* res.oo to bellsvs that  landfill a It Ing In •
 densely •ettled residential aras ulll prvote decline and canvaraloa to
 non-raaldentl*l nans, than  the BE» abould *ddr*ss thl. Issue
 •ab.tutlv.ly.

       S-20:     Tb* BEIB doss not sddros* uh.r. Ihe liner. d.lly end
  |.t.roedl*t. eovnr. and cap oat.rl.l -III be cooing Iron'and ban thl.
  affect, tbs traffic dl.cu..loo.  according to our snslysls of this
  .ItMtlon. aultablo Undflll oatarl.l I. In very .hort ..pply In ^tern
  Ha.aachus.tl*.  Th. SEIS doe. not .dd.... this  Issue .Uhough  It Is
                                                                                                         Us. Oven S.  Rot*
                                                                                                         July  19. I»M
                                                                                                         Pag*  10
                                                                                                         particularly rnlnvsnt to th* fusibility of using the ROM Quarry olte
                                                                                                         for the reeldoelo landfill.  Will* th* r..ldunl. thaoaalvae "111 be
                                                                                                         tranaported on • flicd rant* for the duration of the landfill*! llfo.
                                                                                                         the landfill aaterlala maid need to b* solicited fro* vatloim eoarcea
                                                                                                         •nd transported over routes vhleh Mould vary.  Ve question vhy Mo ROM
                                                                                                         Quarry will hove oaly tua additional truck trips por day over tho
                                                                                                         Valpole HCI alto l« Scenario One vhra tho foraer has oo covor notarlals
                                                                                                         an alto,   la Bconorloo I.I ond ». tho Increase In tho nunbor  of trlpo at
                                                                                                         •ova Quarry versos Valpola HCI lo algolfIcantly groat.r than  Scanarlo
                                                                                                               S-UJt    In dl.cusslng tho significant nocioocononiic Inpact
                                                                                                          criteria, tho SBIS uses • vague, generalised and canclaolanary taoo
                                                                                                          •bleb (laoaon ooor oubatontlvo  lonnaa of property value decline ond
                                                                                                          Inpact OB •alclpnl ta« base.  While ocknowlodBlnt that tboro will be
                                                                                                          -DMlous ef facto generated by the f sell It lee*  toadlos to o decline In
                                                                                                          roil property *alae. tho HIS dlaolssas thin subject on tho folloving
                                                                                                          pasa.  While, odnlttodly. tho lane Quarry operation ho* proved to bo a
                                                                                                          burden to residents in tho adjacent nolchbornoads. this lo In no my
                                                                                                          Justification for forcing these cltlsens to accept yet another
                                                                                                              •Irabln  land nse at this alto.
                                                                                                               J-II4:    To oar kao»lad(>.  tho NUM's coasnltanta have appralaad
                                                                                                          tho Ram Quarry sit* at  Itn  hl.hast  and brat ••• and ostsbllshud • value
                                                                                                          ef Il6.00a.000.  Therefore,  the SEIS ehould otate quite positively that
                                                                                                          "aipanalon or  radevelopnent  of th* quarry nlto by private developers
                                                                                                          mill ho an Important tarn revanu*  soarco for tha Cities of Maiden and
                                                                                                          •avare."
                                                                                                          accepted alternetlves

                                                                                                                6-2:       Pravlons •actions of tho UI8 heve ochnowlodtod that the
                                                                                                           landfill vlll craata nonloua odors In tho vicinity.  Therefore It la
                                                                                                           both Inconsistent Mid Inaccurate to state that tharo Mill bo BO odor
                                                                                                                                                                                /if

-------
He. Omn 8.  tat*
July I*. 1989
Pete II
MM NORTHEAST
lopact.  Deiplte conclentlom operitlou. It IB nil eetebllehed that
lend! I lie ere eoareet of odorooe evlHlone.  n« EPA would aever eccept
eucb beld ••••rtlom In eavlrooMntil lepttt eveJeetloae or pernlt
eppllcttlae* cybeltted by rneaitelel lindflll coBnmlei.
     •-•t      Aciln.  no feel  It  le aneceepteblo to ueert
elgnlflceat air...looecte are  anticipated, there are no expected
pathwaya for public healtk lapacta* «he* the UIB ••• prevleealy
ecknoHledaed the concern! that do e*lat bacraie of the prealolty of
eenaltlva receptor* anrroandlng the Rove Quarry alia.  Pleaee refer to
pafee 4-187. 4-103. J-lll, Table  C-l for dlacuaalon of the potential
•patnvtya," "aanaltlva receptor*," that la people In the vicinity of the
• Ita.
Conclusion

     V* believe that the IM'a  BKIS  falla to eonply with the aplrlt of
the National Imironaeatal frotectlo* Act and the CCQ atandarda.  Mile
there 1* • preponderance of evidence contained In the 8118 about the
•naeltablllty of the Rove Quarry,  the KM** cone lot Ion* read like a
Justification of the NMU'a declaim* to d*t*.  The conclualon that tbl*
•Ita !• nvtromantally accaptable I* not, ia our opinion, "auppertad by
evidence tbat the aiency ha* aade  the aece**ary aavlronaaatil analyala."
(GEQ)
Hi. OHM 8.  Rut*
July 19, 1989
     12
                                                                                 Mo reouaat that the Final 8EIS Incorporate our *uf«e*tlona noted
                                                                            above and that the (PA rlaproaely reeaenlne It* aeeunptlone and
                                                                            cancliulOM ** they pertain to thn aulteblllty of the lorn Quarry alto.
                                                                            Thank you for your consideration.
                                                                                                                Sincerely,

                                                                                                                TMI NORTHEAST
                                                                                                                MMKAMDEAU CNCINUR8,  INC.
                                                                                                                Sham H. Donovan
                                                                                                                Seolor Planar
                                                                            IHD/afc

                                                                            cc. •oaorabla Ooorte V.  Collet*

                                                                            attacbu*ot

-------
                                                             OIT3
                  MCGREGOR. SHEA « DOUNER
                        MIIMMTI u um f e
                     10 TWHONI Sl«f CT-SMIE 100
                     BO6ION IUSS*CHUSCIfSoaMO
                          itiii nt rm
                                                       MUM II tMtUf H
                                                       KICRJ nuiM/ICM
                             July 19. 1989
Ha* • amn smaJMIBSBy
Hater Management Division
U.S. BPA,  Region I
JFB Federal Building
Boston. MA  02201

BBi  Draft Supplemental Environmental  Impact Statement -
     Long-Tera Residuals Maaageaant  for Metropolitan Boston -
     May 1989

Dear Ms. Rodneyi

     On behalf of  the  Selectmen  of the .Town on  Hlnthrop,  this
letter provides oar legal  comments on the above-referenced Draft
Supplemental Environmental lapact Statement (DSBIS).   Hlnthrop-a
technical comments  on  this docuaant are  filed  under  separate
cover by  the Town'a  technical expert. 8. David Crabar.   One  of
the purposes of thla DSBIS la to provide an Independent review  of
the  Draft  Bnvlronaantal  lapact Report  (DEIR)  and  long-term
Realduala  Management  Facilities  Plan  (RHPP)  prepared  by the
Maaaachuaatts Hater Resources Authority (MHHA).

     In this DSBIS BPA  has opined that the RNPP -should be based
on  construction  and  flexible  use of  dual  sludge-processing
technologies-  (p.  2-5).   The has la  for  thla  opinion la  BPA'a
belief that HHRA'e preferred alternative of beneficial reuse and
recycling  technologies  may  not  be  reliable  enough  from   a
marketability  perspective, thereby  necessitating a  contingency
plan for  sludge disposal.   Thia would Include  combustion and  an
aah  landfill  in  addition  to  coapoalng   heat   drying and
pallatising, and  landfllllng.   BPA  in  ita  analyals of  these
technologies,  considered  a nuabar of different  sites including
Deer Island.
MCGREGOR. SHEA « DOUNER
       He believe, as we  have stated many tlmea in  the paat, that
  varloua aapecte of  the  environmental review for thla project le
  flawed because  the review  has been  illegally  segmented.   Thla
  DSGIS offere further evidence of the problems which result from a
  segmented environmental  review.

       The Town of  Hlnthrop has  long bean on record  opposing the
      •ntatlon  of  waatewater  treatment  facilities  aitlng  from
  residuals management  feeilitiea  eitlng reviews.   Thle objection
  datee back to our Cirat  legal and technical comments on the Joint
  EPA/NMRA   Supplementel  Draft   BIS/BIR  entitled  Siting  of
  Haatawater  Treatment  Facllltlea  In  BOBton Harbor   in  commenta
  dated March  1985  and subaaquent  commanta  for  the Final  EIR and
  BIS.   In those commanta, we argued againat the  eaaertlon thet the
  choice of sludge management options will not drive the selection
  of a eitlng alternative.  Aa we maintain in those  documents, the
  sludge  management  solution  choices  could drive  the  aitlng
  decision  and we  believe that screening  criteria  used  in  the
  environmental review  processes  Ignore  the significant  impecta
  that could occur la the  aitlng of aludge management facllltlea.

       Thin issue was  further reiterated in Mr. Crabar'a February
  S. 1986 comments  on the  Environmental  Notification  Form  on the
  HMFP.   The  concern centered  on  the siting of  the wastewater
  treatment  faeilitiea  proposed  eitiag of elodge  management
  facllltlea  and  thee  land  required to  fulfill  commitments  for
  environmental mltlgatlvm maaeurea on a relatively email parcel of
  land.  Segmented environmental  reviews  prevent  the comprehensive
  review  of   environmental   impacta  and   facilities  planning
  necesaitated by  the massive undertaking of the  harbor cleanup.

       BPA  proposes  a couple  of alternatives in  thin  DSBIS that
  includes  combustion  on  Deer laland.    This again  trlggara  the
  segmentation argument since there  is little diacuaslon  in this
  document on how  potential reslduala management  facilities will be
  Integrated into the facilities  plan for the wastewater treatment
  facilities.

       Subsequent   to  the  environmental   review  process  for  the
  waatewater  treatment  feeilitiea  on   Deer Island,  the  MHRA
  undertook  a  faeilitiea  planning  process which  eaaentlally
  determined  how  the  numerous  pieces  of  this  plant would  fit
  together  from en  engineering  and alto  layout point of  view.
  During the faeilitiea planning process, MHRA determined that they
  could accelerate  the construction  and operation of  the primary
  and  some secondary  treatment  faeilitiea.   Thla proposal  wee
  thoroughly  reviewed  by  all  partlee to the matter before  the
  Federal  Court  including  BPA,  and  the subsequent  negotlatlona
  culminated  In a new compliance  schedule which waa  agreed to by
  all  partiea and  adopted by  the Court.   All  parties are  now
  reliant on thla  plan and mandated court achedule.

-------
MCGREGOR. SHEA & OOLINER
          The proposal by BPA. at this late data,  to potentially
site residuals management facilities at Deer Island *"«•""•  th"
facilities  plan  and  schedule.    Me  believe  that  thie  U  a
conaequenca of  a aegmanted review.   EPA  haa ahown  no  evidence
that   the  facllltlea  planning   process   on Deer  »•»••*"••
conaldared  or  how any  potential construction  or-  engineering
confllctr»ould be reaolved.   Furthermore, there la no discussion
en ho. auch a propoaal Impacts upon «—"""""*• "".Ijj!;?,
for mltlgatlva  meaeurea  aa a  reault  of the environmental review
processes  and  the MWRA/Minthrop  February  1988  Memorandum  of
Understanding.

     Thua. we urge BPA to drop thla unwise alternative,   Further
comments  of a  technical nature  critiquing  the  DSEIS  is  filed
under aaparata cover by 8. David  Crabar.

     Thank you  for the opportunity to provide theeo comments.

                              Sincerely,
                                Marian N. Dollne
                                Ralph R.  millmmr
                                Environmental Planning Director


         obart I. HMnan. ChalrMn. vinthrop Board of Solaetam
        Richard r. DlHento. Hlnthrop Seloctattn
        Richard H. Banga, Mlnthrop Selectman
        Virginia L. MUder. Hlnthrop Dlr.  of Co—unity Development
        Brneat I. Hardy. Jr.. wlnthrop RCC
        Brnllle DlMento. FPCAC/Hlnthrop
        Narr Keller. Chairman. Hlnthrop Conservation Com.l*slon
        Thomaa B. Rallly. Jr.. MVRA Board of Olrectora
        Kathleen Hearn. RUM
        Brie Buehrena, Mm*
        Dan O'Brien. HUM
        Narcla Holford, HUM
        Steven C. Unman, DBF
        Gwan Ruta,  EPA
        Marilyn Notch, MVRA
        David Standley, Qulncy Conaultant
        S. David Grabar. Mlnthrop Conaultant
   td. DSEIS. rrw
                                                                                                                           July 19. 1989
Ma. Ann Rodney
U.S. Environmental Protection Agency
Region 1
HOE-I900C
JPR Federal Building
Boaton. HA  02203

Rei  Commenta of the Town of Walpole to  BPA Draft Supplemental
     Environmental Impact Statement for  tho HMRA'a Long-Ten
     Reaiduala Management for Metropolitan  Boaton

Dear Ma. Rodneyi

   . This letter eontalna tho comments of the Town of Halpolo to
thai Hay 1989 Draft Supplemental environmental Impact Statement
(•DEBIS'I published by the U.S. Environmental Protection Agency
foctthe HMRA'a bong-Tana Reaiduala Management for Metropolitan
Boston.

    On April 28, 1989, tho Town of Walpole  filed oatenaivo
comments with tho HEPA Unit on tho Draft Environmental Impact
Report prepared by the MMRA for thla aame project.  The Town's
comments on the DEIR, a copy of which I  am  enclosing for your
review, provided a detailed analyala of  the Town'a concerna
regarding the aitlng of a minor realduala landfill at the Malpole
MCI alto.  Accordingly, those commenta aro  hereby Incorporated by
reference in the Town's commente to the  DSEIS.

    Aa dlacuaaed more fully within, the  Town aubmlta these
comments, its firat opportunity to participate in the BPA'a
environmental Impact analyala, with great concern that EPA has
already concluded that the Halpole MCI alto la environmentally
acceptable and that any further review of alternatlvee has become
unproductive and unnecessary.  In thia regard,  the Town requests

-------
Ml. Ann Rodney
July 19. 1989
Page 3
that EPA comply fully with 40 CPR SlS01.4(a) by aaioaalng and
considering aach of th« Town-a cojewnta contained herein and In
the April IB, 1989 aubalaelon, and by apeclfIcally responding to
the point* ralaed.                              r    v~    *
    Theae coeiMnta Her* prepared by the following
Halpole technical end legal ataffi

         1)   Michael S. Greco, Esq.
              Gregory P. Blalech.1, Baq.
              Special Environmental Couniel
              Hill a  Barlow
              One International Place
              Boaton, MA 02109

         2)   Leonard Kopelawn, C«q.
              John M. Giorgio. Baq.
              Tom Counsel
              Ropelean and Paige, P.C.
              11  Franklin Street
              Boaton, MA 02110

         3}   Kr.  Halter Mullca
              Senior  Hydrooeologlat and Principal
              Mr.  Daniel renno
              Senior  Hydrogeoloqlet
              Mr.  Dean Slocue
              Eavlroiunntal Planner
              IBP,  inc.
              6 Maple Street, P.O. BOB 110
              Morthboiough, M  OIS32
era of the
                                Ha. Ann Rodney
                                July 19,  1989
                                Page 3
4)   Janee A. Pappaa,  P.B.
     Director
     Bnvlromeantal Department
     Kliaball Chaao
     One Gate Street
     P.O. Bo> 511
     Portsmouth, H.N.  03801
                                                                   Very truly youra
                                                                   Gregory'P. Blaleek1
                                cct Board of Selectmen
                                    Halpole Citltena Advtaory Committee
                                    Mr. Jaeaa Herrlaei. • Adailnlatrator,  Town of Nalpole
                                    Hon. Edward H. Kennedy
                                    Hon. John Kerry
                                    Hon. Barney Prank
                                    Men. Arthur Lewie
                                    Hon. Prancla Woodward
                                    Mr. John OeVlllare,  secretary of Environmental Affaire
                                    Mr. Stephen Devia, Director,  MBPA Unit
                                    Mr. Daniel Graenbetm,  Coamlaaloner. DEQS
                                    Mr. Paul Levy. Execetlve Director, MMRA
                                    Ha. Marilyn Morrla.  Adejlnlatrator, Town of Norfolk
                                    Judith Kapuaclnakl,  Esq.
                                    Michael Greco, Eaq.
                                    John w. Giorgio, Eaq.
                                    Mr. Halter Mullca
                                    Mr. Javea A. Pappaa, P.B.
                                                                                     BIAL/PV4

-------
                            S. David Graber
                               Contulint Engineer
                                                                                U.S Environmental Protection Aaency. Region I
                                                                                                                                               -Z-
I !• Lira Reid

1617) 34141390
102072
QneTMfsftyJ /1 tyUfAwlIIC / NNCtUMCBl EnfllVvWff1le|
      WMST Quahlr Unuccnwil Punning
 CiwinRmentel Aiutyils/Mo« '">• the new facilltiea ahould  be  a  primary focua
                                                                                of the PSKIS. Covering of the thickeners  (with off-gaa treatment)
                                                                                end maintenance of appropriate hydraulic  loadings (including well
                                                                                oxygenated  makeup  Mater  sources),  neceasary  pretreatment  of
                                                                                digester  gas  prior  to utllicatlon. and design  of  flarea  for
                                                                                complete combuction should be among the measures addressed.
                                                                                                   HEAT DBYINO AT DEER ISLAND
                                                                                The D6EI8 auggeata the acceptability of beat  drying alone at Deer
                                                                                lalaad (I.e.,  without incineration I. Alternatlvea   involving such
                                                                                heat drying at Deer laland  were considered by MHRA.  and screened
                                                                                out earlier  in  the  ResiduaIa  Management   Facilities  Planning
                                                                                process. < Although the  DSE1S  mar be retaining  heat drying alone
                                                                                at  Dear laland for cone latency with  ita  assertions  tnet  neat
                                                                                drying/incineration at Deer laland  would  be acceptable,  it la
                                                                                difficult to underatand  how  retention  of   thia   alternative la
                                                                                Justified or represents  anything  other than a  step baekwarda in
                                                                                the  planning  process.  If  EPA  disagrees   with   the   reasoning
                                                                                employed by  HWRA  in  eliminating  the  Deer Island heat-drying
                                                                                options,  then it should state  the baala for  Ita disagreement.  Aa
                                                                                noted] in  Winthrop'a HEPA comments of November 29.  1808.  Winthrop
                                                                                concurs fully with HNRA's deletion of the Deer laland heat-drying
                                                                                optlona.  and believes an even atronger ease may  be  made  for  ao
                                                                                doing.   A  copy  of Hlnthrop'a November 28. 1988 HEPA comments la
                                                                                attached  to  the   present  comments.  (Although   not   appended.
                                                                                Hlnthrop'a  HEPA  comments  of  November   29.   198T    are  elao
                                                                                Incorporated,   by  reference.I  The  FSKIB    should  specifically
                                                                                address the combined rationale of MMHA and Hlnthrop  for deletion
                                                                                of the  Deer Island heat-drying options.
        Thickening of raw primary and secondary sludge,   anaerobic diges-
        tion,  thickening of dinested aludge. and digester gas utilisation
        are being planned for Hear Island in conjunction  with  all other
        alternatives. DSEI8 Section S.4 (Air Quality and.  Odors) provides
        a  brief paragraph (on page 6-48)  regarding  Deer  Island  odors
        which  concludea without  supporting Information  that "air quality
        impacta from digestion facilities should be Insignificant".
                                                                                1.  'Deer  Island Odor Monitoring  Report".  Prepared
                                                                                   Odor Science A Engineering.  January 1989.
                                                                                                       for  HMBA by
                                                                                2. Note particularly  the  fate  of alternatives such aa H8-01  and
                                                                                  18-02  in HURA'a  'Candidate Optlona Evaluation - Vol. II •• Site-
                                                                                  Specific Evaluation/Second-Level Screening*. October 1888.

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(1.8 Environments!  Protection Agency. Region I
Julr 16.  1968
                                                            -3-
Addltlonal details th«t would  have  to  be considered  to address
impacts end associated  mitigation  are noted here in tha context
of  heat-drying  alone,  but  they  pertain  also  to   any  other
additional  residual* processing  (e.g..  incineration) on  Dear
Island.  Those  details   include!  land  area  requirements  nnd
availability (particularly as they are in conflict with secondary
treatment  plant construction  requirements),  baseline traffic
conditions   and projected  traffic  impacts',   baseline   noise
environment and noise  impacts, air quality baseline  and Inpscts.
utility  needs  (water, gas. electric  power),   visual   Impacts'.
equitable  distribution.  Integrated   planning   nnd  cumulative
impacts  of  sludge processing  and liquid processing  (secondary
treatment) facilities. Our accompanying  November  28.   1888 HEPA
comments  Indicate  the  details that we believe would  have to be
addressed in these and other areas.
                       •OnOEMCT BACKUP
Mlnthrop'a April  2ft.   1888  HEPA  comments  on  MVRA'o Residuals
Management  reel!1ties  Plsn   included  suggestions on the backup
role of composting and  compost  landfilllng  na well es chemical
fixation. Those comments are not repeated  here,  considering  the
change in piana that haa occurred  reletive  to  pelletIcing  va.
composting in the interest  of avoiding  compost odor impacts et
FRSA. He do  suggest  as s  minimum  that  planning  provide  for
reserve area for  composting   and/or chemical fixation at FKSA as
part of the backup plan. That  would leave  open  the practicality
of  future  assessment  of  those  technologies  baaed  on future
mitigation  technology.  It  would  alao  be  useful,  for future
reference, to include compost  quantity projections la Section  3.1
(note particularly p.   3-11)   corresponding  to  the  higher feed
solids  content   of  26*  (vs.  18*  In  the  VSCIS)  considered
conservative by HHRA (February 1888 DKIM Vol. III.  App.  A):  the
 t.  KRIS  pagan  5-16  A  30  are  deficient  in not  considering
    operating traffie impacts  on  Hlnthrop; nor Is traffic due to
    additional construction workers considered.

 2.  The limited discussion at DSBIS  page  6-81  Is  defieient; it
    falls to consider visual impacts of residual*  facilities  from
    those key Hlnthrop vantage  points  at  which  other treatment
    facilities would generally be hidden by the Deer Island boras.
I).6 Environmental Protection Agency.  Region I
July 18. 1868
                                                               -4-
hlgher  feed solids  significantly  reduces  compost  production.
amendment requirements, nnd  facility aree requirements.

DSE16 Sections S.I.2.  ft.1.4.2.   6.1.ft.   6.I.S.  and  6.3 provide
useful,  albeit pessimistic,   perspective  on  beneficial  reuse.
Section 6.1.6  seema unreasonable in Implying n possible need for
landfllling so much of the finished product.  DSEIS Section 6.3 Is
useful to the extent  that   it is directed to better aecurlng the
expected success of HHRA'a beneficial reuse  plena.  However, the
thrust seems at times unreasonable in  expecting  assurances thnt
go beyond  prudent expectations for a beneficial reuse program of
this type.  Clearly  there   ere  challenges  involved.  Challenge
involves uncertainty. It in  much preferred to have the uncertain-
ty, such ns It  in.  associated  with  a beneficial reuse program
that applies the product directly to the land rather than puts it
there (or in  water)  ultimately but through the circuitous route
of the more fragile atmosphere.  The uncertainty should lie with a
functional challenge to be overcome  rather  than  ecological and
public health uncertainties.

It is nlao noted thnt the potential beneflte  of  avoiding aludge
Incineration  are  conaiderable  in  terms  of  reduced  landfill
requirements nnd  the nanocleted impacta of traffic, etc., on the
host community. By successfully limiting the landfill capacity to
minor  reaidualn.  the  total   landfill  requirement  1*  n small
fraction of thnt required for  ash disposal.
                 INCINERATION AIR ODAblTT IMPACTS
The DSGIS presents   (Table   6.4-2)  a  comparison  of incinerator
emission concentrations with the  corresponding  DEQB  AAL'n. The)
name tabulation  includes comparative data for the  composting end
hest-drylng  technologies.   Me  have  stated in prevloue comments
that DEUI guidelines and standards  do  not  provide  en adequate
basis for  determining the  safety to public health of Incinerator
air emissions. However, for the  moment  we  will  consider those
comparisons. Immediately noticeable la the much greater contribu-
tion of incineration nir emissions than that of the composting or
heat-drying technologies.   For  the  eonatltuenta  and technology
mixes considered, heat drying  has  tha  leaat  total emlaaiona.
composting  has   total emissions about two to five times that of
heat drying, and Incineration has total emissions on the order of
30 to 60  times   that of   heat  drying  (11  to 16 times that of
      sting). If   a  wider range of pollutants were considered, the

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U.S Environmental Protection Agency,
July IB. 1969
                                    Region  1
                                                             -8-
differences   between  Incineration  and  the  other   processing
technologies would probably  be  larger still (note, psge 6-6T).

A comparison should also be  presented of the comparative rates of
greenhouse gas emissions (carbon dioxlds. methane, etc.) from the
aame technology misea.

The comparison  of incinerator  emissions with the DEQI AAL'a does
not  consider  combined  effecta of  the mixture of air toxics. In
even  the  simplest  way. One very simple  means  of  considering
mixture effects has been uaed  for  many  yeera  for occupational
exposure to sir toxics, and  is  expressed ss follows:1-'

     'When  two  or  more hesardous substances arm present.
     their combined  effect,  rather than  that  of  either
     Individually should be  given  primary  consideration. In
     the absence of information to the contrary, the effeeta
     «f different b.r»ran  should  he considered aa additive.
              * ~ the aum of  the following fractions.

                               C.
                            •TLV;

     exceeds unity, thsn the threshold  limit of  the mixture
     should be considered as being exceeded. C indicates the
     observed   atmospheric   concentration  and   TLV   the
     corresponding threshold limit.

     Exceptions to the above rule mar  be mads when therm Is
     good  reason to believe  that  the   chief  effects of the
     different  harmful  aubstsnces are  not in  fact  additive
     but   independent,   ss  when  purely  local  effecta  on
     different  organs   of  the  body  are  produced  by the
     various components  of the mixture.'

 The percent of AAL vslues given In Table 6.4-2. when converted to
 fractiona  (divided by   100).  ere directly analogous to the C/TLV
 ratios in  the  above  relation. Thus,  when the sum  of  percent of
TLV2
 1. American  Conference  of  Governmental  Industrial  Hygieniats
    (ACOIIO. 1982.  IndjULtrAal	Ventilation - Manual of Recommended
    Practice. ITth Edition. I9B2. Section 2.

 2. Aleo see. e.g.. AOOIH.  'Threshold  Limit  Vslues  for Chemical
    Substances and Physical Agents  in  the  Work  Environment with
    Intended Changes for  1983-8V.  Appendla C - matures.
                                                                                      U.S environmental  Protection Agency.  Keglon 1
                                                                                      July 16.  ISWU
                                                                                                                                                    -6-
                                                                                      AAL values exceeds lOOft. the AGUIH-type mixture criteria would  be
                                                                                      violated In the absence of information that the  effecta  are not
                                                                                      additive.  On that basin.  the  Incineration  totals for the  three
                                                                                      at tea IStoughton (ISO ft steckl. Spectacle  Island.  Deer Island]
                                                                                      tabulated in Table 6.4-2 range from bib to 631 (with  beer Island
                                                                                      being highest), ell in excess of IOO». The  composting  and  heat-
                                                                                      drying totals are. on the other hand, well below lout for all the
                                                                                      aites for which those technologies are tabulated (Table 6.4-21.

                                                                                      The  mixed  totala  become higher still when the dioxln and  furan
                                                                                      pereentagea.  calculated from  the  concentrationa  and  criteria
                                                                                      given in the DSE1S. are  added for each aite. Here aignificantly.
                                                                                      the mixed totals could be substantially higher if  the  DSEIS did
                                                                                      not  limit  consideration  to  those  parameters  that  exceed  ID
                                                                                      percent of the AAL (note pagea  6-32  and 6-3S). It does  not take
                                                                                      many  10-percent  valuea  out of the  large  number  of  potential
                                                                                      chemicals to quickly add algnlflcantlr to the totals.

                                                                                      Having employed the  comparisons  shown in Table 6.4-2  in attemp-
                                                                                      ting to demonstrate the public-health safety of incineration, the
                                                                                      burden  of proof ahould be on EPA to  demonstrate  which  of the
                                                                                      tabulated  chemicals  should  not be  considered to  be  at   least
                                                                                      additive.

                                                                                      Bynerglstlc interactions between carcinogens arm not  addressed  in
                                                                                      the USE18 application of the DEQB AAL's. despite the  acknowledged
                                                                                      presence of carcinogens  in the incinerator emissions.1 Synerglam
                                                                                      was addressed  in Ninthrop's HEPA comments of November 20.  1967  on
                                                                                      ttte  Residuals  Management  Facilities  Plan. Excerpts  (under  the
                                                                                      heeding of Incinerator Air Emissions) from  that  comment  letter
                                                                                      are attached,  and made e part of the  present  comment  eubmlttal.
                                                                                      Included In those comments is s qualified analysis   (Table   1 end
                                                                                      associated text,  which built upon a  1963 EPA analysis!  regarding
                                                                                      the possible increase in cancer incidence caused  by  Incineration
                                                                                      on beer Island, as counterpoint to the type of analysis presented
                                                                                      in earlier aaaassments and  more  recently  in the  subject  USKIS.
                                                                                      Adjustments may be made to the November 20.   1961   analysis  baaed
                                                                                      on more recent information. However,  it is difficult  for  us  to
                                                                                      I  Such as  beryllium, nickel, dloxlns.  furans  as reported in the
                                                                                         Air Emissions Derivation Report. Others,  projected by  HHMA to
                                                                                         be present in the emissions (Air Emissions Derivation Report).
                                                                                         have h.en dropped In  the  DKKI6   (e.g..  vinyl chloride, etc.)
                                                                                         presumably because they are below  1UK of  the  DkClE  TEL (24-hr
                                                                                         AAL):  such  deletions  ignore the possibility of synerglatlo
                                                                                         effects.

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U.5 Environmental Protection Agency. Region I
Julr IB. 1988
                                                             -7-
      thoaa  adjuatmaata   because  of  the  absence  of  reported
parameters  (or  their diffusion  over  nuMroua  EPA  and  MUHA
planning documents).  Nevertheless, e very crude adjustment may be
Mde based on  the 0.83   Ib/hr  non-methane  hydrocarbons (NMHC)
controlled  emission   rat*  reported  in  Table 4-20 of  the  Air
Emissions Derivation  Report  (cited  on  USEIS  page  b-30). Ualng
that MMHC emission rate  and  the  total  stack gas emission rate
used earlier 16.84 m'/e).  a   stack concentration of 3.68 ppm NHHC
la calculated.  Using  other variables  aa Indicated In the Table 1
analyaia and the linearity of the associated mathematics, one can
calculate  an  Increased   cancer  Incidence  of about 3  per  IOU
mapoaed  population.1  This   la   In   sharp   contraat   to  the
tmpllcatlona of the OSEIS.

It  ahould  alao  be  recalled that  in  ita  Draft  Responses  to
Commenta oa Bit*  Screening  and Candidate Options Identification.
February  1886.  HHRA  acknowledged  that  there  Is  a  lack  of
available data to  thoroughly address  the  major  concerns that
ei 1st about Incineration.  Does  EPA believe) otherwise, and if ao
MhyT

The DGE1B analyala ia baaed  largely oa data derived  in  the  Air
Rmlaalona Derivation  Report  (cited oa DEKI8  pago  6-30). Section
4.3  (pp.  4-bT  to  102)  of that report pertains. That  section
eoaaiata off page after page  of as.sumpUoii>  regarding incinerator
emissions,  exemplifying   the general  lack  of  data   on  such
emiaalona. Boms organic compounds are Ignored (or are the subject
of grosa aaaumptloaal presumably because no  data  were available
for them (aee.  e.g.,  Air  Emissions Derivation Report Tables 4-31.
32. 3S. 36. * 37).

Asbeatoa ia not considered  in the  D6EI8. presumably because it
•as not considered in  the  Air  Emissions Derivation Report. The
latter Mated (p. 4-62; elao aee Table 4-2211

     "Ho  emissions  data for asbestos  from  sewage  sludge
     incinerators  could   bo  obtained.  Because there la no
     reason to auapect significant quantities of asbestos in
     the  incoming sludge.... emissions of asbestos Hill  be
     negligible also.'
1.  Other  reasonable  adjustments  to  the  analysis,   such  ss a
   revised carcinogen  potency  slope  for  dloxln.  would  still
   result in unacceptable cancer risk projections.
                                                                                 U.S Environmental Protection Agency. Region  I
                                                                                 July IS. 1889
                                                                                                                                                -8-
                                                                                 However, emerging data auggeats that  asbestos  ia  widespread in
                                                                                 municipal  wastewatera and sludge.1'*

                                                                                 All  of  the   projected  phosphoric  acid  emiaalona  exceed DEQE
                                                                                 criteria (Table  6.4-11.  The DbKlS downplaya this by stating: "EPA
                                                                                 does not regard  these phosphoric acid  emiaalona  aa unacceptable
                                                                                 because they  are not  regulated  under  federal law. and although
                                                                                 they could potentially  cause  eye  or  upper  respiratory tract
                                                                                 irritation in sensitive populations,  they  would  not  cause any
                                                                                 severe environmental or public health impacta". This questionable
                                                                                 viewpoint  ahould  be considered in the context of the calculation
                                                                                 of the phosphoric  acid  emission  rate,  which  was baaed on the
                                                                                 unaubatantiated    sssumptlon  of  6*  conversion  of   phosphorus
                                                                                 pentoxlde   (PjOs)  to  phosphoric  acid (Air Emissions Derivation
                                                                                 Report, p. 4-64). If that conversion la 10*.  then  the criterion
                                                                                 •iceedance la doubled. If  IS*  it is tripled, and BO on. Clearly
                                                                                 this can not  be  paaaed off ao lightly.

                                                                                 Also, is   the page  6-46  characterisation  of  acceptability to
                                                                                 "EOEA" of   the phosphoric acid exceedance correct, or ahould this
                                                                                 refer  to   "EPA"7  If  "EOEA"  la  Intended,  than on  what  EOEA
                                                                                 communication doea the D8EI8 baae this?

                                                                                 Interactive aourcea at Deer  Island  arm  addressed on page 6-48.
                                                                                 The  analysis  ia  severely limited by the lack of adequate baseline
                                                                                 date  (Section  4.3.10  and  Table  6.4-7) for the  Dear  Island/
                                                                                 Nlnthrop area:

                                                                                    - The  role of Logan Airport aa an existing  major  aource (ia
                                                                                      either  the technical or common sense) ia not conaldered.

                                                                                    - Ambient air quality ia characterised  by  reference  to sic
                                                                                      HASH monitors aa far aa IO kilometers from  the  sit*. {The
                                                                                       attached November 29. 1988 HEPA comments, pagea 7*8. give
                                                                                      Mlnthrop'a prevlously-expreaaed and  atI11-current  view oa
                                                                                       thla significant Inadequacy.]

                                                                                    - The   DSEI8  (page  4-77)  states  that  no  data exist  for
                                                                                       background levels of toxic air  pollutants  in  the region.
                                                                                       However, such data ahould have been obtained aa part of the
                                                                                  1  Pitt. Robert.  "Asbestos as  an Urban  Area  Pollutant". Journal
                                                                                    Water Pollution Control Federation.  November 1988.
                                                                                  2.  "Asbestos  detected '  in   towns'
                                                                                     (attached).
                                                                                                                      sludge".   New   York  Times

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U.8 Environmental Protection Agency.  Region  I
July 18. 1988
                                                          -9-
      DSEIB  «f fort  In order to  properly  project  Incineration
      impaeta.

The analysis  of cumulative effects of  the Deer  Island wastewater
and residuals facilities Is lacking la  aeveral respects)

   -  It  does  net  consider  Bleed or  arnerglstlo  Isipacta of
      pertinent toxicants.

   -  It addresses only over-water concentrations of tetrachloro-
      ethylene;   maximum   on-lond concentrations   should   be
      considered at pertinent receptor  locatlona.
-  It does not consider toxic pollutant omissions
   plant utilisation of digester gas.
                                                     fro* power-
Along related llnea.   the  "study   area"  for  determining public
health Impacts Is not clear,  being referred to variously as three
kilometers (e.g., p.  4-164} and three Biles (e.g.. p. 4-191). Nor
Is  It clear what uae la siade of that study arae In the analyses.
The Inclusion of only a BBS 11 fraction of the Mlnthrop population
in the atudy srea (p.  4-1911  is questionable;  Me  have commented
previously on tha need for s  larger review dlatanco.

In light of the above,  it Mould appear that the  DSKIS assertions
regarding the aafety  and acceptability of incineration  should be
either retracted, or  demonstrated  with  the  aid  of  much batter
date and analyses.
                      ASH LANDFILL UACHATS
The DSIIB focuses on incinerator  ash for its analyses of laachate
iBpacta. because of the greater concentration of toxicants in ash
than in the other aludge  materials that HHHA might landfill. The
discussion of potential surface water  quality  lapacta  from ash
landfllling at the Halpole MCI la deficient In numerous respects.

rirat.   based  on  the   assumptions  stated  In  the  DSKIS.   the
predicted Stop  River  concentrations  In  Table  b.5-2  for 'bo*
Leakage  In  One  Cell" appear to be erroneous. The leachete flow
(«!,) Is seld on pane 5-63  to be based on 875 gallons per day plus
41*  inches  par  year of rainfall over one 10-acre landfill cell.
That  gives average leachate flow ratea of:  0.0237  cfa  at  60V
leakage.  0.004T4  cfs   at 10*   leakage, and 0.0004T4 cfa at  IX
                                                                                     U S environmental Protection Agency. Kegion I
                                                                                     July 18. IU8V
                                                                                                                                                   -10-
leakage. Substituting those valuea into the mixing  equation (page
5-bbl along tilth  UJK of 14.« cfs (page 6-561. UB - USH - U|..  and
valuea of C^ and Cg troB  Table  !> b-ii. does give results for IOX
and IX leakage agreeing fairly  well with the Table 5.5-2 valuea.
However, the values for SOX leakage should be changed to: Araenic
- b.l Pg/L. Cadmium - 2.0 Mg/L. ChromluB - 2.2  Pg/L.  Lead - 4.6
Mg/L.  Mercury - 0.20 Mg/L. SelenluB - b.l  Mg/L.   Silver  -  3.0
Mg/L. The higher values In Table  b.b-2  correspond approximately
to those which would occur if the value of (h, waa 10  tlaea higher
(about 0.237 cfa). corresponding  to   1OOX  leakage from all five
landfill cells.  The necessary corrections should be  made, or thai
procedure giving the box valuea clarified.

Second, although it is  conservative   to  assume)  Stop River beck-
ground water quality to bo one half of the detection  limit (Cg in
Table  b.b-2)  from  the  standpoint   of  calculating   a  higher
predicted concentration after mixing with leachate, it alao gives
the  iBpreasion  thst  the  water  quality  criteria   are already
exceeded for the five asterisked Cg veluea and are  merely further
exceeded  as  a  reault of leachate addition. Our carrying out of
the computations for Co = 0 and conditiona otherwise  the  same aa
assumed in the OSK1S shows that the number  of  exceedaneoa would
Inereaae from none without the landfill  leachate  (obvloualy) to
two  exceedaneea  for  the  IX  leakage  acenarlo   (araenic  and
mercury),   three  exceedancea  for  the  1OX  leakage   scenario
(arsenic,  lead,  and mercury), and  four  exceodances  (arsenic.
cadmium, load, and mercury) for the bOX leakage acenarlo.
                                                                                          the  assumption  of  average  flow  conditions   for  this
                                                                                  analysia  aeena completely inappropriate. The average   atreemflow
                                                                                  la a statistic which la  atrongly determined by flood flown which
                                                                                  occur a relatively  small  percent of the time. Furthermore,  whom
                                                                                  the average streemflow exists it conaista predominantly of  direct
                                                                                  aurface runoff, not groundwater  as  assumed  on DSCIS  page 6-66.
                                                                                  The  significance  of  this  la  dlscusaed  below   In approximate
                                                                                  quantitative terms.

                                                                                  Although more preciae. project-specific methoda are available,  am
                                                                                  order-of-magnitude  eatlmate  of  the differencea between average
                                                                                  atreamflow and unregulated 7-day. 10-year low  streamflow   can  be
                                                                                  obtained  from regional regression equations published  by   USOS*
                                                                                  The equations are ss follows:
                                                                                  I  C. Q. Johnson. "A Proposed Streamflow Data Program  for Central
                                                                                     New  England".  U.S.  Geological  Survey.   Open-rile   Report.
                                                                                     Beaton. Mass.. 1B7O.

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U.8 Environmental Protection Agency.
July 18.  1B8U
                                    Region I
                                                            -11-
     t»a = 0.38IA»-»V°

     HTO . 0.00103A'
IB which:
     •---—-
 nation from landfill  leachate alone Increases aignlficantly.  The
 number of   eaceedances  would  Increase  (from  none  without  the
 landfill)  to four eiceedances for the DSKlS'a I* leakage scenario
 (arsenic,  cadmium, lead, and mercury),  to  five  e.ceedancee  for
 the  DSKlS'a  10*   leakage  scenario  (araenlc.  «d"»"7i ..Uf*i
 mercury,   and ailver). to si. e.ceedancea  for  the  ObklS  a   6O*
 leakage scenario (arsenic,  cadmium, chromium, lead, mercury,  and
 ailver).
 As noted on USE 18 page  6-62.  the  leachate
 baaed on ash from primary  sludge, and the analysed
 be  eipected  to  be  greater  tor ash from combined  primary  ana
 secondary sludge.

 The Howe Uuarry/Rumnry Marshes analysis  (pp.  6-60  to   631  may be
 subject to •»oma of the  same criticisms  aa the Wai pole/Stop River

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0.8 Environmental Protection Agency.  Region 1
July IB. 1888
-13-
analyala. However this cannot ba determined  fro*  tha information
praaentad. because tha basis for the background pollutant concen-
trations la not given. That  Information  (measured  va. assumed)
should b« provided  quantitatively  for  each  parameter  ao that
Independent review can be conducted.

In  tha  modified  results  for  the Stop River given above,  tha
eaceedancea (at 60ft leakage) are.  with one exception, eaceedances
of freshwater acute criteria or Naaaachusetts Standard! for which
the low-flow River concentrations are clearly applicable. The one
exception la for  arsenic,  which only violates the  Man consump-
tion criterion; it could be argued that • flow higher than the 7-
day. 10-year low flow  should  be uaed in thla case  but certainly
aot as high aa the  average flow (similar considerations apply to
other parameters with  the  10* and Ik leakage scenarios I. State-
ments  made on DSEI8 page 6-84 are incorrect -  there  would  be
eiceedancea of acyie.  criteria and/or Massachusetts  Standards for
cadmium, lead, mercury, and ailver with the  IOX and/or It leakage
acenarloa. Also, the statement at  the end of page 5-94 regarding
the Insignificance of the eaceedancea ia questionable  and should
ba aubatantlatad. The same applies to the statement  at tha end of
page 6-1O3 regarding Impacts from consuming  contaminated flah.

The  DSBI8  also  convera the Impression (e.g., at page 5-95 with
respect to Rumnar . Harshesl  that • certain  number of eaceedances
is acceptable: "Only two compounds could eaceed  chronic criteria
and thla ia not considered  significant.' Even  one sufficiently
severe eaceedance  can  have  a  serious  ecological  impact  Tha
specific eaceedancea should be Individually  eddreaaed in a manner
reflecting appropriate aciantifle evaluation.

In reporting  the analysis of leaehate impacts on Halpole ground-
water,  it la atated  (DSBIS  p.   6-64) that  background concentra-
tions  of chromium and lead in  the  groundwater  already  eaceed
water  quality  criteria.   Does  this  refer to the  measured  or
assumed groundwater  quality? If measured, then what ia the water
presently used for  and  la  that  use aafe? If assumed, then the
analysis would be subject to  the  same  related  criticism given
above for the Stop River analysis.
                           U.S environmental Protection Agency, hellion 1
                           July ie. iu«a
                                                                                        -14-
                                                         N01SK
                           Very  little (and Inadequate) information Is preaanted  regarding
                           noise impacta In Hlnthrop  due  to  construction and operation of
                           additional  residuals facilities (beyond those proposed by  HHHA.
                           e.g..  incineration)  at  bear  Island.  Tha  following  comments
                           briefly review the USEIS  noise  assessment  methodology, briefly
                           state what we believe to ba its inadequacies, end  than  go   Into
                           some detail in substantiating our opinion.

                           The DSBIS (pages 6-BT to 68) states that the realduala processing
                           activity noise would be  attenuated  31  dHA  more than the noise
                           from  the  secondary  treatment  plant,  and baaea that on e  tha
                           following considerations: (I) that the  center  of  the residuals
                           processing area la 2.600 feet further from Point Shirley than the
                           center  of  the  eeeondary  treatment  plant;  (2)  the resulting
                           diffarentlel noise attenuation  of  31 dBA la baaed on hemispher-
                           ical divergence and 'eaceaa attenuation"; and (3) excess attenua-
                           tion ia assumed to be 1 dBA per 100 feet.

                           In the comments that follow,  we will present arguments to refute
                           each of tha  three  DSKIS baaea mentioned above. Specifically, we
                           will  argue:  (1)  that  the  distance between the center of  the
                           reaiduals processing area and canter of secondary treatment nolae
                           aourcaa  la  significantly  leas than 2.6OO feet;  (2)  that  the
                           resulting differential noiae attenuation la very  much  lesa  than
                           the 31 dBA figure:  and  (3) that the eaceaa attenuation la over-
                           predicted In the DSKIS. with the actual figure being as little aa
                           6 to 10 percent of the values assumed in the DSKIS.

                           Accepting momentarily  tha 2.600 feet figure, one can deduce  that
                           the difference in divergence attenuation at the  neareat Hlnthrop
                           realdence Is 6 dUA  based  on  respective distances for secondary
                           and reaiduala facilities of 2.600 feet and 6.000  feet,  and  that
                           eacess attenuation la considered to  account  for  26  dBA (2.6OO
                           feet a I dBA per 100 feet) of the 31 dBA difference.

                           The  assumption  of  1  dBA  per 10O feet eaceaa attenuation  and
                           resulting 25 dBA difference are gross overestimates, aa dlaeuaaed
                           below. There is only one certain (always present)  fore)  of noise
                           attenuation  other  than  divergence,  and  that  ia  atmospheric
                           abaorption.  In  fact  the  Secondary  Treatment  Facilities  EIR
                           concluded  that eacess anomalous attenuation (beyond  atmospheric
                           abaorptionI should ha neglected for nolae projections appropriate
                           to a project of thia magnitude and duration.

-------
U.S Environmental Protection Agency. Region  I
July 18. 1989
-16-
Ecress attenuation usually refere to attenuation  to  addition to
that  resulting  tram  divergence  and   atmospheric  absorption.
althouch  the  authors  of  tha  aubjact  bbKIS  apparently  lump
ataoapnerlo   absorption  Into  excess  attenuation.  Tha   bSKlS
terminology Hill be uaad In thaaa coaaenta.

Atmospheric  absorption and  eicess attenuation  ara  frequency -
dapandent. In order  to  praaant a concrete) coapsrlmon. two sound
apactra will be  cone Ida red  la tha following consMnta. The, drat
Is a dlesel sound spec trust representative of  construction nolaa.
as uaed ID tha Secondary  Treatment Facilities Plan1 and given as
follows:
                Octave Band Cantor frequency - Us

  31.6   63   126   250   600   1000   2000   4000   8000   -*-

         Tft    84    88    82    80     T7     70     66     86

Tha above apaotniai corraapoads   to 86  dBA.  and can bo adjusted
upwards  or  downwards  to  other dBA  values  at the  reference
dlataaoa.

Tha aeoond is • sound spectrum  representative of plla driving. as
used la the BIH for the Deer Island Pier Facilities2 and given mm
f ollowa:
                Octavo Band Center Frequency - H»

  31.6   93   126   260   600    1000   2000   4000   8OOO

   104  106    89    88    43    86     8T     80     83
1. Power  Plant  Construction  Holse  Ouldo.  Prepared  by  Bolt.
   Baranek  a  Newman   Inc.  lor  Eaplra  Btate  Electric  Energy
   Basesrch Corporation. Hay l»77 - check.

2. Figure  A-B  of   'Noise   froa   Construction   Equipment  and
   Operatloaa,  Butiding Equipment, and HOB* Appliances".
   for^tha U.S.  IPA  by bolt.  Beranak  and H.-an? fU
                     U.S fcnvlronaental Protection Agency. Meiilon I
                     July 18. 1BMH
                                                -16-
                                          nolaa  was
                                                   *
                     A thorouch evaluation  of  atmospheric  absorption  of
                     carried out as  part  of the Secondary Traataant Faollltlos  Plan*
                     The ataoapherlc absorption values uaed In the Facilities Plan  and
                     aa-reed upon as representing appropriately conservative values  ara
                     as follows ldb/100 a):
                       31.6   63
  Octavo Band Center Frequency - Ha

125   250   600   1000   2000   4OOO
                                                                          BOOO
                        --  0.01  0.03  0.08  0.14   0.32   0.89   3.62   12.13

                     Although these value*  were  derived by MWRA'a consultant to five
                     alnlaua   ataospherlo  absorption,  they  do  not  Mlve   results
                     dlfferlna: aimlfIcantly pr«ssed  aa  dB attenuation
                     ptr IOO feat, the ataoapherlc abaorptlon live* O.OB dB/lOO ft for
                     the dleael apectrua at 2.500 ft.  0.06 db/100 ft  for  the  dlesel
                     spectrum at 6.00O ft.  0.2 db/100 ft for the plle-drlvlna; apectrua
                     at  2.buO ft.  and 0.16 db/lOO ft for the plle-drlvlnc  spectrum at
                     6.000 ft.  (Tha  ataiospherlc absorption affectively decreases with
                     Incraaaini distance aa the hlcher frequencies are eliminated.I

                     The results can bo  further  adjusted  for ••cess attenuation (ia
                     addition   to  atmospheric  absorption)  for  downwind.    neutral
                     temperature/light  wind,  and upwind conditions.  Valuoa of  acceae
                     I. H*M. Biff.  HI. p.  ma. Secondary Treatawnt Facilities Plan.
                       Vol.  III.   Noise  and  Sound   bate.   Point  Shirley. App.  D.
                       Massachusetts Mater  ftosourcea  Authority,  Charlestovn. Haas.

                     2. Craber.   1987.  Letter  to   Dan  O'Brien   of   HMRA  regarding
                       Secondary raclllties   Treatment Plant Mork  Product  FJ36A  -
                       Evaluation *nd Scrncnlna;  of  Unit Processes  -  Noise Analyses.
                       March 4.  lattV.

-------
U.B Environmental Protection Agency. Realon I
July 18.  1989
                                                          -17-
ettenuation previously applied over • 4.600-foot distance on Deer
Island (but aotually derived for • 2.020-foot distance) are given
below1'2'3:


               Octave Band Center Frequency - Hs

  31.6   63   126   260   500  1000   2000   4000   6000

                     DONMUND nCIPTOB

    -0   «T   46    -7    -6   -2     -0     -0     -0

              NEUTRAL TEMPERATURE. LIOHT WIND

          I   *6    -6   -16  -14     -6     -0     -0
    -0
         -6
              -6
                      UFHINP RECEPTOR

                   -16   -21   -20    -IT
                                            -10     -0
for comparative purposes  these values were linearly proportioned
from  2.020  ft  to  2.600  ft.  which  overestimates the  eicesa
attenuation since excess  attenuation per unit distance decreases
vlth distance.4 The linearly proportioned values were  then used
to  calculate the additional attenuation over  2.60U  ft  due  to
eacess attenuation of the dleael  and  pile  driver  apeetra. The
results for the three meteorological conditions  and  two apeetra
live attenuations st 2.600 ft as follows:
I. Parkin.  P.M..  and   Bcholea.  HE..   1966.  'The  Horlsontal
   Propagation of Bound from a Jet Engine Close to the Ground, at
   Hatfleld-. J. Sound Vib.. 2. 363 - 374.

3. CE Hsgulre. Inc.. 1986.  Letter to David Oraber from Jeffrey N.
   Paul.  Re:  Noise Propagation from Pile Driving at Deer Island,
   November 19. 1966.

9. Qraber. 1986.  Letter to Jeffrey H. Paul, CB Haguire.  Subject:
   Deer Island Pier Facilities. December  8.  1968.

4. Perkin 4 Beholea. cited  above.
                                                                                 U s Environmental  Protection Agency,
                                                                                 July IK.
                                                                                                                     Heglon 1
                                                                                                                                             -IB-
                                                                                        Diesel Spectrum

                                                                                             Downwind Receptor           2 dB
                                                                                             Neutral Temp.  Light Mind    7 dB
                                                                                             Upwind Receptor            19 dB

                                                                                        Pile Driving Spectrum

                                                                                             Downwind Receptor           -1 dB
                                                                                             Neutral Temp.  Light Mind    6 dB
                                                                                             Upwind Receptor            i7 dB

                                                                                  (Note  that  under certain conditions  there  can  be negative excess
                                                                                  attenuation. I

                                                                                  Totaling ell  emcess  attenuation (actors  (including  ataioapheric
                                                                                  Ib»rption"  and converting  to  db/100  ft.  give,   the  tollowlng
                                                                                  (based on 2. MO ft):
Diesel Spectrum

     Downwind
     Neutral
     Upwind.

Pile Driving  Spectrum
 4 dB • 100/26OO
 9 dB s 100/2600
21 dB « IUO/2600
                                                                                              Downwind
                                                                                              Neutral
                                                                                              Upwind
                 4 dB • 100/2600
                11 dB • 100/2500
                22 dB • 100/2600
                                                                                                                           0.16 dBA/100 ft
                                                                                                                           0.36 dBA/lOO ft
                                                                                                                           0.64 dBA/100 ft
                   0.16 dBA/100  ft
                   0.44 dBA/lOO  ft
                   0.88 dBA/100  ft
                                                                                     _.- ...it  waliua  loer  100  ft>  would  be leee  for  greater
                                                                                            Sue I* £•• He... anom.lou. attenuation  with distsnc.
                                                                                         arkln I Wholes, that  attenuation  would  be elgnif icantlr
                                                                                   i    .t   aay   6?000  ftl  and  due  to high frequency loaa with
                                                                                   distance. A. discus. ed below, source height effects  also gre.tlr
                                                                                   the hlghir value.
                                                                                                    j-srsa -assras-ssar as

-------
U.S Envlronsnntal Protection Anency, Hello.
July 18. l«8a
                                                            -19-
further work of Scholes and Parkin'  Is useful in this connection
The upshot of  an  evslustion2  of   that work is that under light
wind conditions sources shove 6 feat above (round will evperlence
significantly reduced excess attenuation. Quantitatively,  bchole
a Parkin's  results  substantiate  the  statement  by  Piercr and
tebleton tin Harris*  HanObiiok_«l	Hol»O_CfiJUrfil. 1»TB. p. 3-1J.
end  in   reference   to   the   neutrel,   downwind   conditions
eorrespondlna: to their Figure  3.10)  that  at  distances greater
than  100 enters 1300 ftl  an (arlthaetlc)  sverage  height  of  3
enters decreasee the  excess attenuation nearly to  zero  Harris*a
Figure  3.10  Is  ssld  by  the  authors  to  be  "suitable  for
conservative engineering practice'.

He  conclude  fro* the above, that  the  DSEIS  uses  sn  excess
attenuation value which la 1/0.06  to  1/0.2 = 1O to IB.7 tlaes
those of the Secondary Treatment  Facllitla  Plan,  and  which we
believe to bo appropriate.

It  should  be  noted   that  the   above  conclusions  are  not
significantly  effected by  barrier  attenuation  (referring  to.
e.g., the Deer Island bereal.

He will now return to the  question of the  diatanco  between  the
center of secondary treatannt noise  sources and the center of the
residuals   processing  area.  Referring  first  to  the   backup
calculations prepared in support of  the Secondary Facilities Plan
projectlone, we  note that the construction elte was divided Into
Zones A. B. and C for purposes of construction noise assessments.
Zone A  waa  the  s»st  distant  from  Hlnthrop. at 4,1«U feet.  A
review  of  the  calculations  shows  that  Zone  A  la  a  very
significant  contributor  to secondary  treatannt   construction
noise.  In fact smelt  of the heavy earthwork  occurs  at  or  near
(Including south of I   the  residuals  processing site. Furthermore,
some of  the  noisiest  of  the  secondary  treatment operational
facilities (e.g.. the cryogenic  facility)  will  be  much closer
than 2.bOO feet from  the  residuals  srea. Thus the USEIa argument
that the creator distance   of  the   residuals facilities does not
hold up.
1. Scholes. H.E.. and Parkin.   P.H..  1867.  -The Effect of email
   Changee  in Source Height on the  Propagation • of  Bound  Over
   Qraaaland'. J. Bound Vlb..  6.  424 - 442.
2. Oraber. 1866. Letter to  Kevin  O'Brien.
   Island Pier Facilities. August  16.  1988.
IMKA.  Subject! Deer
                                         U.S Invlronnental Protection At»ncy. Real on  I
                                         July IB.  1UBB
                                                                                                                                                   -20-
                                         Th.  dl.cu.sion  of  inter  Islnnd  noise    impects   i.
                                         Inadequate relative  to  construction   and  operation  of
                                         Incineration  facilities.  There  ere   eerlous  ««»«»t4o"»  V°,
                                         considered re.ardlnil the  ability  to   complete  the  £•' '»*
                                         construction on  schedule.  within   agreed-upon  •ltl««V°" fer"»
                                         (Including   avoidance   of   nl«ht-tlme.   weekend.  and  holiday
                                         construction   noise).   if   additional    reslduel.   f.cilitie.
                                         constructed at Deer Island.
                                         He  also are co.cer.ed about th.  possibility  of  *«gboaV
                                         noises associated  with   residuals  operations.  DSEIS  •»•*!•»
                                         states that  barging  can occur  at  any  time during the day or
                                                The Interim  Sludge  KIR  haa  indicated  that night-time.
                                                               -
                                         the   magnitude   and   duration   of  long-term  sludge  barging
                                         operational  impact*  and  mitigation.
                                         Miscellaneous
                                                             its follow:
                                                                                     improved,  particularly
-  The graphic* could be substantially
   the clarity of overlays.

-  There are numerous cross-reference •"»«• "** •» °"
   1-42  4-60. 4-161.  4-1B6.   S-llli  •"<  6-112.  Thl*  —
   Portions of the report difficult to folio., particularly In
   £hose cases where the Intended cross  reference  to tables.
   etc. cannot be determined by the reader.
                                             -  In Subsection 4.3.2.2 (pane  4-6T).   the  sentence         ,
                                                the potential .ewacn »l«d«e  incinerator. . .are  oat  one of
                                                th*.^ "  should read "M«lther  the potential sewa«e  aludce
                                                Incinerator... ere one of the ---- "


                                          r !..!!•  we ash that EPA  and  their consultants prepare the FSEIS
                                          in a i'nne? sl.llar  to   the   K8K1B   for Boston Harbor H.stew.ter
                                          ionv."™: ' ly~l~.  .»-  thus  avoid  burdenln.  reviewer,  with
                                          repetition of DSK18 docuawntation.

-------
U.S Environmental Protection Anency.  kealon I
July  IB.  198B
Thanh  you for the  opportunity to  aube>lt theaa co
                                    Vary truly jroura.

                                                                 -21-
                          {\Tmitutc, Office* qf&uMrofunf/Ual jffiiv*

                                                     . ?«a/t
                                                                                       Conwbutl Ottvy
                                                                                         Anting Outturn
                                    6.  David Qraber
     Robart E. Noonaa. Chainan.  Minthrop Board of Salectaen
     Richard P.  DiNento. Minthrop Salectaan
     Richard N.  Bangs. Ninthrop EelectBan
     Vlrtlnla  L   Nlldar. Hinthrop Dlr. of Coaaninlty Davalopavnt
     aailia OIHanto. FPCAC/Hlnthrop
     Marr Kallar, Chalraan, Minthrop Conaarration Coaalsaion
     Thoaaa I. Rellly. Jr.. HHHA  Board of Dlractora
     Kathlaan  Haarn. MHRA
     Erie Buahrena. IWRA
     Dan O'Brien. MHRA
     Marr Oaovles. HWRA
     Steven O. Llpawn. DEW
     Marllrn Hotch. HHRA
     Harlan Dollnar. McGregor.  Shea ft Dollnar
     David Stand lay. (luincy Consultant
                             Qktfttuta, of "Water SMfuhoa, Gbalrot

                          On* Winter Jlrceti GBotloOi Mat*. Of/Of
                                                                                                                                   July 19. 1989
              . Dlvlalon
U.S. EPA. NBjlOD X
JPK Building
Boaton. Ml 02309
BSi Draft	
    Siting and Evaluation
    of Icchnoloalea for
    Pacllitlaa
                , of anvlronaantal Protection
Bft'a Draft 8BU for the referenced project and baa tba I
                                                                                       •   Proa an overall raedabUlty/underatanlablllcy parapactlve. tba
                                                                                       DuanaaaU found the docuaant'e fonat inordinately coopllcatod. and
                                                                                       difficult t* follOH.  Thla aada the onnmrlam of eltee and qptlona
                                                                                       oonplex. requiring the reader to oonatantly refer to prior port lone of
                                                                                       docwnta.  Tha Dayaitaam raapactfully
                                                                                       In it* preparation of tba final BKU.
                                                                                              4.3J.«

                                                                                           - Tha atat* and federal osone atandaida era Identical.
                                                                                           - Tha DapartB¥ant Mill be pzapnalng to adopt UN federal H»-10 atandorda
                                                                                           later thla year.

                                                                                       aactloa 4.3 J.B.

                                                                                           - Odon fim aaataairiir facllltiee are jointly ragiilatad by the
                                                                                           Dlvlalon of Mr Ouallty Central and tba Dlvlalon of Hater Pollution
                                                                                           Ckntiul.
                                                                                                                    Olgnol on Recycled Papa)

-------
                                  -1-
      > 4.3.2.9
                   tea • ehort-tana » guideline which U not aentloned
    deficiency.

Section 4.3.3.5

    - The entln
               	ith la attalnant  for BHOi eeaeured valuee have
               tto etandaid. Certain araaa wan noB-Wtalnaent for tto
- Table 4.3-Si  Tto DAflC air Quality SunelllaneeBianch CAOBB)  ahould
to contacted for correct Intonation regarding aablent aoiltorlng In
tto OaBBOMaalth. f-* alao emaaniert background air toxlca data.
       4.3-7iii»i ml 10

     m-10 la not nanli
                          at all tto altae Indicated.  Again, tta
                      lor tto correct Inf onatlon.
Section 4.1.1.4

    -Again, tto

Section 4.5.3.3.
                               1th la atta
                                                form-in.
        5.4.9.1

     - Camming • predicted exceeding at • MOB TB» tto DSBU etatee ttat
     TBVe do not canetltute regulatory Italta. but an guideline which
     Dear. ua« to a*MM air o^alley Inpaeca f nm amlaalon aouicn and
     tharafora. tto a»uaovla«* not*d would not nanaaarlly pracluto atat*
     uinlttlng of an incinerator*.  Ihla BtaUnent la alao i	
     anwa Mithln Bjctlon 5.4 and onraly gl»w tht favrawion thata
     T-^-t-^- |B inoonaeguantUl.  AN.'a and HL'a an haalth baaad
     for «fclcn DBQB vlll noiln •Itloation aaaauna to aaaun pddlc toalth
     la pratactad.
                                      ajor aoueaa. D0 raoulna ttat
                	   	        Kcaedanen of a TO. or AM. la
     .	.	U» probability of ODcaur* ia than analyiad.  If tto
     gmnml m*llc la not aqnaad txcauae the oceadenc* oocura on tto
    - la all eaaaa. both anjar and
    tier to avpltad.  If attar BftCr an
    pradlcud
                       in unliwiabltad araae auch aa earahea or open water.
     tton no further •Itlgatlon la naceeaaryi but If tto general public la
     •iiliiiael, OGQE will  raquln additional alligation, which eUght  Includei
     higher levele of air pollution control, of feeta, reduced feed  Input. «
     denial of an air ealealona pmlt for tto facility.
                                                                                                        In tto report and Appendix B. eaeeeeJentee of AM.'a an referred to but
                                                                                                        location an not atown.  They atauld to Indicated In PSEIS.

                                                                                                        It la uncertain whether aetaorologlcal oondltlona wen told eonetant
                                                                                                        throughout tto entln analyeea for all tto altea.  Thla atauld to
                                                                                                        verified and clarified in PSEU.

                                                                                                        It laluncertaln whether tto aodel cptlone activated wen oonaletently
                                                                                                        applied to all altae.  Thla atauld alao to verified.
                                                                                                     •   fane 3-M f2nd Mil.
                                                                                                     require* • 9 foot vertical
                                                                                                                                     Incorrectly atatee ttat
                                                                                                                              eeparatlon between
                                                                                                    and tto bouoe at tto liner eyeteeu  Ito correct
                                                                                                    feet.
                                                                                                                                                     In
                                                                   ta
                                                             ar elevation
                                                             tlon la 4
                                                                                                    ^J,	 3-«4 and Floura 3.4.-14t  During tto naat oouple of eontte.
                                                                                                    additional  technical infomatlon tea been obta
                                        i obtained by t	
 Public Mane DOM)  nlatlve to tto excavate/dredged eaterlala to to
 moved aa part of tto Central Artery/Third Raifaor Tunnel Project.   B	
 upon thla new intonation K>M bellevee that uptaraa of 13 edlllon yaida  of
 eaterlal will need to to dlepoeed at Spectacle lelend.  Thla will requln
 additional lateral and vertical expanalcn beyond ttat Indicated In tto «»«
 report.  It la likely ttat thla altuation will affect tto potential  for •
 MMA'e uee of a portion of the laland for long-torn naldumla. and EPA
 ahould addnea thla  in ita Plnal SOB.

 •   Pane 4-31.  Section 4.1.7.3i  Tto report only briefly refere to tto
 ongolna 31E site Aeafanuiit and Baeadlatlcn actlvltlee tolng perfeiead at
 tto PUS*.  Tto Depenaent tellevea thle laeue  atauld to dlecueeed to a
 greater extent In tto PRIS ae It nlatea to construction of tto coBpoetlng
 facllltlee leee tto Departaent'e April 1989 oceaenta filed with M3>A on tto
           >DE1M.

                                                               eanMent
                                                                                                    •   Page 4-71. Section 4.3.3.9i  Tto dlacueelon nlatlve to
                                                                                                    air quality guldellnee for Dlotlne and Purane j
                                                                                                    ravlalona by DnQC (eea attactoent ftto. II.
                                                                                                              •a. Section 5.1.4.11
                                                                                                                                            •Ion regarding federal regulatory
jurladlctlcn le confining, particularly ae It nlatea to tto etatoognt
nlatlve to 'Incinerator aah*  and Baludge Incinerator aah*.  Thle ahould
to clarified In tto PSE38.
                                                                                                            5-23. Section 5.4.a - ttijuu-ilon 3i  T*                 	
                                                                                                    aablent air concentration (predicted Increecntal for tto pmrJeLt pine tto
                                                                                                    background aablent air concentration) «•» coopered to tto DBQE end EXn
                                                                                                    guldellnee liated above.   If tto total astolent air concentration i
                                                                                                    guideline, tton tto lapacta an coneldered to to algnlf leant*.

-------
                                   -s-
     It la unclear f mm Urn tart vtether till* •Him nl rafera to both
 criteria and non-criteria eontaalnBnta.  If It refer* to non-criteria
 eontaeliianu lair UK Ice), Urn •tatenent !• Incorrect relative to Vtf
 guideline..  the Departo«nt don not directly incorporate •background* Into
 lu air toilce a.inieMiL.  Cumulative Impacta era addreeead through tte
 nee of Interactive Modeling praceduraa for than epeclf Ic cantaalnanta
       eatkBted e»le.lon impact excnd. 1/10 of an Miyra. (an attechmit
                                                                         I ataCf wltli an eye taeirda
                                                                                                         :raticn to tte
                                                           .  In* largeat, and east recent prajact
                                                    pmrlda. for th. blandln, of o«r 1300 £bte
     all*
 S.S.J.J
                olatllea vlll alao main In tte aluog.
 ..
 U««r «d lorgnlM ttet Inhabit thla
 anytnln.
                  on tte
la River Hater* wed for
M>U S.S.1
 5.».5.4
                                   In aoll or •ater. bat It Is
                                  Ibl. ahould te clarified.
 '-;• -»—»»«•» -«» "«w> •*•« men an eye UMeroa aeaonetratlon to th
 public and potential aajor Inatltutlanal/comrcUl ueere of eludge
 f01****-* •*• blntllta «• •» ••Ined.  and safety of utilising MOM aludge
 a~Mnieii.eji   •Mi.* l.aiev^asB*'  	• •»»«••		•	—  •	  -    _     f Tnnnl
                                                               16» 1909)
                                                                  Mlth
 „.  .-.	—_  -j; ——-——•——• —  - •—• auuwi.ii. uaiu jn ins TOMI of
 ?!l^?li     iS?lJ.(l1?^ j°°?«*t •nd •°1I> «PP"«« to tte elte «aa
 claa.lt led aa a lypa II sludge product. ttfUle tte ocapaat Itealf falla
 •Ithln tte lyp. Ill claa.lflc.tlon due to ooncentratlona of tapper.  If tte
 Depiraiant «ere to aonerlcally classify tte eludge conprjet betnT^proaucadl
 by  the Authority at Ita Dear laland  Dam.tr.tlon Ob^ost PaclHtyTtnar
 claa.lflc.tlon wold be Type III.  Since there sre/»pUn. todlaulbuM
 this oasaoat In a non-blended fom.  tte only raault of ^classifying  it^
          ' mild ba to unnecessarily confuae tte public and tte age
                I to «ork •Ithto  build a base for long-tan, compost
	— •— - ol tte OapsrtMent'. technical rsvlav of tte Mnthion
Athletic Field project.  «e  perforaad a detailed rlak aaaaaaaant  Mtte
prapoMl.  Tte niri.unt ahOMd ttet  tte risk, to tte public era
aoceptabla and therefore tte project MB. allo*ed.  oven though tte
theoretical  claaalf IcaUcn  of tte  non-blended coapoat MuLlba lypa XIX
     	.	•> nte calculated for contact vita akin?  It snould
2^t^"II*( aetlaatad ttet final eoapoat praduced froa
                                                          -     J «w prlnary/aaDandary eludge fro. tte new Dear laland Plant
                                                        te • Type II notarial.  If one agree, vltn ttet analyala. then
                                                    Claaalfylng aviating or»s,»iet. «4Uch la algnlf Icantly rrn confcaslnat.
                                                    tte future dudg..!!! be. tea not — Si., f^J^par.^^^
                                                                                                                                                i nubile thereby adMraely
                                                        >" •«•"* tte Departeant tellevea ttet O*>a requlrenant ttet tte
                                                    ^	      ganrlcslly claaslfy tte eoapoat froa tte Daw laland
                                                    Daeanatntlon Oapoat Facility la not only Irrelevant to tte long-ten
                                                    eludge Banagenant lauuian, but could confua. tte public tteraby advsuea:
                                                    •f f acting long-taaa rausa/racycle progn

                                                        Attactemt N>.  3 la a coapllatlon of
                                                    Office of naSBtrch  and Standard..  PI
    	; atatea. •Prior to laeuenee of Ite Plml •**. tte I
obtain a claa.iflc.tlan fro. tte Naseadueette DepBHaau. of
Ouallty Bflginnrlng of tte ooanott being produced by tte cam
plant currently operating on Deer laland. and It ahould begin a pnjgra. of
;'"?!?l~B?.*l"«rU"ltl" «* "»« eoapoet.  Thla mild oaean.trat.tte
                                     .    .   mi  oanttatette
IMW'a ability to negotiate tte regulatory procn. for onpnt distribution
and to develop anrtotlng agieoaanU with  "   -' '
                                                                                                  ODmellu.p'Leury
                                                                                                  acting Director
                           ttat during tte past IS aontte r*rjB a
                           "^"L"* C?*"t •"P1««t»«n P™j«cte. aonly
                      clea.  Theae projccu «era develojied by Matt In
                                                   •kVaf
                                                   U-rodnayl
                                                   oci Brie

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                        TOWN OF WINTHROP
           NOISE, AIR POLLUTION AND AIRPORT HAZARDS COMMITTEE
                                                                                   Facilities Planning Citizen Advisory Committee
                                                           TovaHrt
                                                     WiMhiop, MuudnacmOll
                                                          |M1)M6-IM2
                                         July 17. 1989
U.S. BPA Region 1
JPR Building
MQK 1900 C
Boaton. MA. 02201

Attantioai Hlchaal Daland

Doar Mr. Daland!

I Blah to raglatar tho folloving eonBanta on behalf of ayaalf
and aaabera of tha Nintbrop Molae. Air Pollution and Airport
•asarda CoBBlttoa concerning SPA'a Environmental lapact
BtataBaat (or long tarn roaiduala dated May. 19B9.

I abjact to BfA'e auggeeting incineration •• a technology to
proeoaa eludge. oven aa a back up Baaauro.  Tour Agoncy looaaa
credibility by auggaatlng tba Boat environmentally threatening
technology available.  It la diaturblng that no conaldaratlon la
given to tba oacalating concerna around global Barning. ilalng
•aa lavela. or air pollution in general, particularly by tha
agency charged with protecting tha environment.

In addition, I find your auggaatlon to incinerate on Deer Iiland
to bo irreaponaible. if not recklaaa.   Pirat.  the conblned
effecta of burning nay cbeaicele together baa neither been
atudiad, nor Boeeured.  Secondly, propoeing that auch a facility
be pieced neat to a aeeondary waatevater treatment plan, a heat
drying facility and a najor international airport daaonatrataa •
lack of concern for Ninthrop realdaata.  bordering on contenpt.

Hinthrop realdeata bave long auffered  froa the air pollution
ceuaed by activitiee at Logan International Airport.   Me have
too long been vlctlalsed by the development at the Airport and
for the peat fifteen yeara.  have baan  denied the quality of life
that each realdent ia entitled to under any clrciuatance.

•ince BPA baa not eatended to Hinthrop tho courtoay of  a local
public neeting. I intend that theae conaante be entered into the
public record in lieu ol teatiBony.
                                    Wecjr truly
CAROL A. DaHIO
CABOLTH PISICHBI.LA
CHBI* LANZA

cei Boila OiHanto
                                                                                                          cfo MWRA PuUie Aflain
                                                                                                           OuricttcMni Nivy Y«id
                                                                                                             100 Fail Avenue
                                                                                                             Beaton. MA 02129
                                                                                                          (617) 242-4000 CM. 1191
                                                                                                              oniheSccandnyTnMiiM
                                                                                             Combined Sever Overflows for die Batlon Haibor Ounup Ftafnun
                                                                                  Ann Rodney
                                                                                  US. EPA. Region 1
                                                                                  WQE-1900C
                                                                                  |FK Fedcnl BuUdinc
                                                                                  Boston, MA 02203
                                                                                 lulf 18.I9W


                                                                                 Dew Ann:

                                                                                 EnctoMd AM lh» PPCACt coraennu cotnmenti an EPA't Dra
                                                                                 Environmental Impact Statement (DSEIS).
                                                                                 Thank you.
                                                                                X^<^£*rl
                                                                                 RM«bJ> ami     '
                                                                                 FFCACChaJrpenon
                                                                                 oc
                                                                                 Eric Buehmw
                                                                                 Steven Davit
                                  XlBROHS B. PAtBO.
                                   ROBERT DRISCOLL
                                   CHARLBS HICCINS
                                   HABIB TURNER
                                                     CHAIRMAN

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       11*1 till If !•!•
                                                             Itm 1*1 •»•
TlLLINCHAST  COLLINS &  GRAHAM
  coi tn i in « •» •«»
                                                              |M «tt «!• *»••!
                                       July 18, 1989
      Nc. Michael R. Deland
      Regional Administrator
      United State* Environmental
        Protection Agency
      Region I
      JFK Federal Building
      Boston, Haaaachuaetts 02201

          He:  Environmental Protaetion agency Draft  Supplraental
               Environmental I .pact Statement— Nay, 1989. Long-term
               Residuals Management Cor Hetionolitan  Boaton	

      Dear Mr. Ml and:

               The Town of Norfolk, Naaaaehuaetta I'Tom*) has en-
      aaged  the  law flrMe of Tllltnghaat Coll In. » Craha., Providence.
      Rhode  la land, and Anderaon 1 Krelger. Boaton. Massachusetts, to
      "epreaent  Ite intereat concerning the altlng of a Minor re-
      alduala and aludge  landfill  in ml pole, Hasaachuaette  by the
      Haaaachuaetta Hater Reaourcea Authority «•"«»•».  In  thle
      capacity,  we  submit the encloaed commenta relative to  the
      Environmental Protection Agency'e |-im*l Draft Supplemental
      Bnviron.ental  Impact Statement. Nay..I£*;.U«J»» »«?'°
      Management for  Netropolltan  Boaton I'DSEISM.  The Town'e
      •enta  focua on  the  landfill  aapecta of the OSBIS.

                The  Tovn of Norfolk, on whoae border the NHRA Intenda
      to alte a landfill  for  grit, acreenlnga, scum,  ash and •^•r
      •trenuoualy objecta to  the aelectlon of the Halpole-NCI •»»•••
      a location of thla  facility.  The aelectlon of the Halpole-NCI
       aite violatea applicable provlalona of  law. threaten!  unique
       and irreplaceable  reaourcea, lapoaea eevtre burdens on The Tonn
       (not an NHRA comunlty» and  la othemlae eerloualy • agulded.
       The BPft'a uncritical  acceptance  of the  NWVa selection of the
       Halpole-HCI alte for  the landfill la unconscionable.
Nr. Michael R. Deland
July 18, 1989
Page 2
         under the Clean Hater Act, 31 O.S.C. IS 12M et aeg..
the EPA la authoriied to prevent, or at leaet significantly
reduce, the Industrial pollutants released Into Boaton  Harbor.
Had the EPA been diligent In ita enforcement of the Clean Hater
Act, aludge fro* the Boaton Harbor could be uaed aa fertilizer
or Marketed In other waya.  The EPA acknovledgee, however,  that
the anticipated quality of the aludge Makes ita Marketability
questionable.  OSBIS, 5.1.4.2.  In fact, if the BPA'a propoaad
regulations on the disposal of aewage aludge, S4 Fed. Reg.
S746, February 6, 1989, are adopted, NURA'a Executive Director
adalts it will be virtually impossible to do anything with  the
aludge.  See StateMent of Paul Levy, Executive Director,
Massachusetts Hater Reaourcee Authority Before the Environ-
mental Protection Agency on Ita Proposed Standarda for  the
Disposal of sewage Sludge, 40 C.F.R. Parts 257 and SOI.  Even
ao, the EPA uncritically aceepta landfllllng the unmarketable
aludge near a sole source aquifer, a lone II recharge area,
wetlands, endangered apeclea and town reaidenta.  The EPA  la
adopting one forai of pollution over another and the Town ob-
jects!

         Not only la' the EPA adopting a landfill proposal which
threatens a public water supply. It la attempting to circumvent
the regulatory process by which Its actions are Monitored.   The
Town.is dlatraught by recent comments by the EPA and U.S. Dla-
trlci court Judge Naisone (aee U.S. Response to MHRA'S  June IS.
1989'Compliance and Progress Reporti Beaton Globe, July 11,
1989 p. 8) which iMply that the altlng of the landfill  In
Halpole la a fait accompli.  Aa you well know, the EPA  la pro-
hibited by federal regulation from taking any action which
liMlte eonaideratlona of alternatives prior to the Issuance of
a record of decleion.  The Town urgea the EPA to give the
Town's concerna aerloua consideration and not to Merely rubber
ataep the aelectlon of the Halpole-NCI aite.

         The Town bellevee ita position ia adequately aupported
by Coewenta by the Town of Norfolk on the Massachusetts Hater
Reaourcea Authority's Draft environmental Impact Report |*DE»
COMMcnta*) to the Naaaaehuaetta Environmental Protection Agency
I*HBPA*).  The DEIR Comments are attached hereto.aa Exhibit I
and  Incorporated herein by reference aa part of the Town's
comments on the EPA1a DSEIS.  The Town would like to draw your
attention to certain specific concerna relative to the  DSEIS
and  the altlng of a landfill at the Halpole-NCI site.   Each of
the  following is briefly discussed in the attached CosMenta
with additional support in the DEIR Comments.

-------
Mr. Michael R. Deland
July 18, 198*
Page J
Mr. Michael R. Deland
July IB, 1989
Page «
   1.    THB BPA'S UNCRITICAL ACCEPTANCE OP  THE  HWRA'S  ASSUNP-
         TIONS RELATIVE TO THB IMPACT ON GROUNDMATER OP A LAND-
         PI LL AT THE MALPOLE-NCI SITE MUST BE  REVOKED AND AD-
         DITIONAL MODELLING AND STUD* MUST BB  COMPLETED.

  II.    THB EPA HAS PAILED TO ADEQUATELY  CONSIDER  THB  APPLIC-
         ABILITY OP THB FEDERAL FARMLAND PROTECTION POLICY ACT
         AND, THEREFORE. HAS ERRONEOUSLY ADOPTED MMRA'S SELEC-
         TION OP THE MALPOLB-NCI SITE AS ACCEPTABLE FOR A LAND-
         FILL.

 III.    THB EPA HAS FAILED TO RIGOROUSLY  EXPLORE AND OBJEC-
         TIVELY EVALUATE ALL REASONABLE ALTERNATIVES  INCLUDING
         EACH ALTERNATIVE CONSIDERED BY THB  NMHA AND ACTIONS
         NOT CONSIDERED BY THE HHRA.

  IV.    TNB BPA'S IDENTIFICATION OF FEDERAL STATUTES AND REGU-
         LATIONS IS INSUFFICIENT TO PERMIT AN  ANALYSIS  OF REA-
         SONABLE ALTERNATIVES AND THB IDENTIFICATION OF A PRE-
         FERRED ALTERNATIVE.

   V.    THB BPA HAS NARROWLY INTERPRETED  THB  NO ACTION AL-
         TERNATIVE THEREBY ELIMINATING  CONSIDERATION OF CUR-
         RENTLY AVAILABLE LANDFILLS AS  A REASONABLE ALTERNATIVE
         WARRANTING FURTHER STUDY.

  VI.    THB BPA SHOULD NOT DETERMINE THAT THB MALPOLE-NCI SITB
         IS ENVIRONMENTALLY ACCEPTABLE  WITHOUT FIRST DETERMIN-
         ING IF THE NMRA LANDFILL WILL  COMPLY  WITH  FEDERAL DIS-
         POSAL STATUTES AND REGULATIONS.

 VII.    THB BPA HAS FAILED TO ADEQUATELY  ADDRESS ALL ENVIRON-
         MENTAL IMPACTS IMPLICATED BY SITING OP  A MINOR RE-
         SIDUALS AND SLUDGE LANDFILL AT THB  MALPOLB-NCI SITB.

 VIII.   THB EPA MUST CONSIDER THB APPLICABILITY OF THB CLEAN
         WATER ACT SINCE THE NALPOLE-NCI SITE  IS IN CLOSE PROX-
         IMITY TO NAVIGABLE WATERS.

         Based an tttm Information heroin presented, the Town

 respectfully requests that you
          b    eshauat ell reesonable elternatl.ee  to the
               walpole-NCI eltei
          c    issue euch further ordere end  finding, ee ere
               within your euthorlty.

                                    Respectfully eubsiltted by
                                    The  Town of Norfolk

                                    By ite  ettorneye,

                                    TILLINCRAST COLLINS a GRAHAM
                                    Christopher H. LlUle
                                    Judith Raoueelnefcl
                                    Chrletlne1 M. Grevelle
                                    One Old Stone  Square
                                    providence. Rhode Island 0290J
                                    (4011 456-1200
                                     ANDERSON t KREIGER
                                    1 stepnen ~D. Anderson  /
                                     Arthur P. Krelger   /
                                     33 Nt. Vernon
                                     Boston, Massachusetts
                                     (617) S23-1624
   1896s

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                                                                                                                                                     o/r*
7-22-aa

Hr. Ronald Nanfredonle. P.B.
Chief. Hater duality Branch
USBPA
J.r.R. Federal Building
Boaton. HA  02203

Dear Ron:

    Thla HNRA  Harbor Cleanup fiaaoo la beaming  a dlagrae* to our
atat*. To aaa  our leglaleturea weete ottlsana  tlse and acnoy o*ar
where tha  HHRA Binagoaent building  ahould  bo  la absurd I Soaehoa
the prlorltlaa of  our Clean Hater Act eeeaj  to  have boan placed In
the  loweat  agenda,  while  aalnlna  thlnga like office location
rectove  laglalatlvo  attention.  I  uaed' to   think I lived In an
Intelligent atata but. I •• beginning to minder.

    I  and  othara  concerned  with  envlroaontel protection, tha
affeeta  and  eoata  tha  HHRA  Harbor  Cleanup will oraato to tha
citizens of  our atato. are deeply worried   that  tha HHRA haa loat
alght  of  Juat  what  Ita  prlaary  objeettvea  ahould be and ara
apendlng to aueh tlae. effort and soney on thlnga that have little
effect  on long-tars  envlroaentel protection or  the effect their
plan  vlll have on the average  oltlsene who uee  HHRA eervlce. For
Inatanoa:

To thousands of hoaeownero who aae tha HHRA  Ita projected • 120B  a
rear bill to pay  for harbor cleanup Mill, without  a doubt, ba an
enoraoue annual bill. A bill that  aany can  not afford and Hill ba
unable to pay.  Once thla happena the  NHRA  Mill  be left  abort of
operating aoney to aafoly run Ita progria. What  la It going to do
then? It aay heve addreaaed thla potential problea but. I have not
aeen it, ha* It ?

Then to eee  any dapartaent or eoapany  apend over 3 yaara  In th*
deelgn  of  a  new  operation  which  will   produce  a product for
••rketlng. •• tha HHRA elalsed Ita coapoat would  b*. and llatan to
It wake  elalaa on how large a aarket Ita oonpoet would have, even
print It In  Ita final atudy papera In 1899. and then aee It drop
tha  eoapoat  production  plan   a  couple   of  aontha   later, la
one  of the Boat unprofaaalonal  bualneaa parforaenoea I have aeon
In By 60 yaara of Ufa.

    If  yon  and  I  foraed  a  bualnaaa and   perforaed a alallar
operation,  I  can  aaaure  you  we  would ba bankrupt ahortly and
probably  b* tarred and feathered by the atookholdera who  Inveated
In our groat new projaot.

    I aha11 not go  Into detail on the HHRA'a highly unprofeaalonal
and Blatake loaded  landfill Bite  selection  BB  I  believe that  aaa
olearly ahown In our Beetlng of 7-14-80 but. you  cen reat eaaurred
that  If we did  alwller ectlona In the Beka-belleve bualneaa  aeen
above, we  would be brought  to court by our stockholders for our
Ineonpotent business ectlona.
 2.
 7-22-B9
 Hr.  Ronald Hanfradonia P.B.
     Ron.  aoaaone HOST  atep In  and take aotlon to aea that the HHRA
 oorrecta   ita  aerloua   aiatakea  before  It puta  our atate  Into a
 woree  envlroBental  condition  then It  allready hea.  The high danger
 potential  Ita  selection   of  tha Halpole  alto  appltaa  to tha
 drinking   water   of the   residents  of  Norfolk  and Hslpole. th*
 wetlande  In and  around the alto, the  beautiful waters of tha  Stop
 and  Cherloa Rlvara. tha Clean Hater  Aot  Itaalf. I* far too great
 to   even  take  tha chance of letting the HHRA build ita landfill at
 Helpole'a Ceder  Junction Point.

     Ha appreciate tha  fact that  tha  Boaton BPA haa little oontrol
 over  HHRA'a waetefull end tnoo*petent  buaineaa aotlona. auch a*
 the  reoent aanegenent   place  frivolity, but.  it doe* hav*  strong
 control over protection of our  watare. our mviroaont.  Therefor*.
 based   on  th*  deta   recently  aubalttod  regarding the high risk
 factor th* Halpola Site  hea,   the fact  that tha  HHRA haa other
 alt*«   which offer  oonalderebly   Bore envlroaontal protection, the
 fact  that  th*   Halpol*   Bit*   fella  to  Beet  a  Bultltud*  of
 regulatlena and  goal*  called out In CFR 40.  tha fact that If it la
 need  thar* is  an  eitreaaly   high probability  that It  will break
 Una of tha Clean Hater Act. oen we depend on Beaton's BPA to take
 leasedleto atrong action to see  that  the Halpole ait* la not uaed.
 that  tha  Clean Hater Aot and other federal laws  pertaining to
 our  waters,   our  wetlanda, our envlroasnt.  and the Boaton Harbor
 Cleanup are adhered to in  th* Boat etrlngent Banner?

     Looking forward to your reply.  I  a*.
                     Reapeotfully yours.
                     Larry Baeaignani
                     P.O.Boa 83
                     Horfolk. HA  82flSB
doo 3; 28 • 38
                             OlA.

                                                                                                                                                           J&

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                                                                      o/r/
             ^rinkltn  "Jfatk  ^Uprobenifnt  Association
                         •f JM  Jrftrr.
                                e/o  77 Ube*fy Avenue
                                >k>. £•«»«., MA oi*f\
 Jut* IS.  1*19
United Sfotet FniMAonBentaf P*oteetioii Ajeney
Region I JFK hitting                     *
e/o Ann Rodney
~  -     Mtacfcutettt OffOI
PCM Mi. Rodneyi
                                              REi  PSEIS - Ifay 1919
                                                   long-Te*B Retidtatt Nmogciwirf
                                                    04 Hif<0inf i fun Botton
                                                   f 04
Mt apologize fM being t*te nick out e4.
         JI0 CMR 10.15-10. Ml 4tatc tkc 4tandMd fM matt ucwk ncM th4t Mca
         •NCAC it it pa*t of a anadAonaut/eataMounaut f44k *un it "M9APVERSE
         EFFECT*.  Tkc ttandaAd IOA a HMtk it cwcn MAC 4tAinaent. 4ta£tna tfcat a
                                                                                                                            fo« a HM4k 44 cwcn «MC *t*4Jigeiit. ttatimg tftt a
                                                                                                                            RW AW  FUBTIOM OF THE SAtT MARSH AMP SHAH HOT HAIff
                                                                                                                                                               tkc Sec Ptane
                                                                                                                                                                     tke
         Tkc WC pbuu  to 4jut4lutc • 00444VC *ce*catiaMt MCO MM
         Ba44Ji.  He 4CC peopte today #«w~«g, elawuig and f44k4Jia
         MM4k adjacent to tke Sea PCane IOAUI.

         At • ftegJonat  Ta4k Fo*e'e He-be* of tke IMU MAC 
-------
                            - I -
                                                   |Pu|( • SCIS Ceii'41
ItH 00* opiiuMi flat a U*Hilt el OUA tqpt eontd ptuca( a doaoftMg c(|fe< m
kit outetamiiiM AMOIMC* 4| a btcaet *• Me faw<(U4 tuiM MMC to kapptii.  la
«tv««aiag t»e «u|t SCIS M •*« once %k at ROM Quo/uy w*tM ^ufteaiU
        o( etevoXcJ eoiKCiiC«att0al o| votoUCt o*gojuc co-pound* IVUC'«I « .
    WV.P-WQB
IS July 1889

Mr. Ron* Id Nanfradonia. P.I.
Chief, Vatar Quality Branch
Nan England Hagton
USEPa
J.P.I. Federal Building
Boaton. HA  B22B3

Dear Ben:

In  our .acting yaatorday you aeked that •• *hon yo* .hot  har* th.
aelpale Landfill Sit*  noold  oauaa to th. mtlend. and  Stop Rtirer.
•haraaa I a*   not  an onwlro.enlel  engineer tha beat   ananar I can
erfar  eo.a.   fro. U.B.Coda  33 .  .action   1339.  utllla.tlon of
oalatlni  data.  Stud lea  dona  for  th.  IP* by Oeoaervloea Inc.
O.r.ghty t  Millar.  th. pr.a.nt.tlon ..do to Subooi.lt t. on H.turel
Raaourea*.  agrieultur*  Haaourca  and  Bnvlro.ental Coraaltto. on
Science 6 Technology by IPa'a Nr. -Ill la. Sanjour.  publtoatlona or
Mcb.r.nd  «Sn  i«h .ho. that All Infill.  Mil te.k •"-/»»«"
tha  aatera  In  and   Oatalda  thalr  Boundrtaa. • that  881 of th.
 landfill* a tod lad   had oonta.tn.tod tha  underground water OUTS1DI
 thalr boondrlaal   following our  •••tin* I oontaotad aoa.  .apart*
 intb. field  of  landfllla and If do.ir*d/r*o,uir*d .111 forward you
oopy of thalr raply.   Plaaaa advtaa.

 I alao »loh to  Introduo. 08 Cod. 39 aaotlow  1311 .<•>.<*> M*t  *lao bo  addraaaad •• It  oloarly
 •tat*,  that  »0  diiohirg.  .ball  b.   pr.*ittad  If  ttar*   t. •
  ""       It.rn.tiv. t. th. prop..*d  dl.oh*r.* ^"«'»«5.-~>d-
       mAmmwmm  iapaot  on  tho  aquatic  •ooayat**.  •!•*. tb*
 .oflnl! atiT*. If lh.r.  I.  1... nOBMIUTff *f ——  l-»"t
 •t anotbar alta than  It ahonld bo aalaotadl

 Sa  tha eonoarn ra«ardln« th* Valpol.   alt*  i* not ja.t hM bad  or
 Shin  It Snib^oo*! pollut*d. bot  in.taad  1* th* fact that .ban  It
 do!.  It Sill oaualhar.  to mt.r quality,  drinking ..t.r. fi.h and
 • lid Ufa   tha "creation   in and   on  our  na.lMbla «at.r..   TIT.
 ?h.»ll virtually MO PKOBABILITT  of  thl* happonlnfl at •  alt* that
 do!,  nit ».:. naii-Sl.  «t.r   *.  It.  bord.r or that  I.   in  * to«
                                                                                          sto?
                                                                                                                                                .-  .    i
                                                                                          ba .ithin  lla budget It

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                                                                               19 Jono 19B9
                                                                                                                                    RECEMED-EPA
IS July 1989
Mr. Donald Nanfrodonl.,
P.B.
Another Important factor part.InIng to tho u.e of Spectacle I*l*nd
I.the foot that  tbo ..t.rl.l being  tronoported to the landfill
."to OH bo treneported .1. barge  Juet llko tb. oludgo which oholl
be eent to tho Oulney. Thlo totally •li.tn.t.. tho  po.eiblllty of
thodlaee.o-oerrylng  bacteria a   «lrao  It  oontolno being  oprood
onto our  roidVduo to  • v.blolo  ooeldont.  ebould gre.lly reduce
ohlp.onl oo.l.. <..p.ol.lly  for tho ol>  .onth oludgo  backup
plan",  and olUln.too  tho Hood   to hov.  two (2) .hipping .od.o.
which by lto.lt I. • ooro pr.otle.l and  eoono.toal buetnee. .odel
Tho 00.1 .."ing.  It off.ro wi.t   bo oon.ldor.blo. otherwioo  th.y
•ould bo trucking tho .ludgo to Qulnoy.

l.g.rdlng water quality: drinking  ..tor protection: "«'••'»•»  »•
and on *.t.r;  Mtl.nd protection: protootlon of  fl.h 9 wildlife
protootlon of  rlvor.i th. BPCTCA; ••«•»••• r?;U"on, "I.?!^
•ot for onvlroMntol protootlon:   then tho uoo of Sp.ot.ol. I.lend
I. f.r ..for Md f.r .or. prob.blo off motIng/oowlying «lth tho.l

•o. th. Tow of ttorfolb w.t.r det. you voo.ao.tod In oar Boot Ing.
Norfolk h.. >WS dwlllng..  S2I.  . of th.. h«. «<""<••»".
tho   roMlnlng 49 •. <1B8B) h.»o  prlv.t. if.ll.. Tho oolorod ro.d.
on th. .naloood ..p .ho. .nor. towi «.t.r  1. proTlded.
Currently Porfolk  ho. too  C2> towi  *otor rail..  On.  !• 49 feet
deep, tho other ftl ffoel doop. fooo o.p>. al.o.   log1.letIon p.i.ed
 In  I84S .lion. Norfolk to obt.tn nt.r  fro. prloon »elle.
Regarding  aurfaoe Hater mil., "any  of   It. hou.o. whloh are over
 25  yoor. old uae ourf.ee Motor nolle  for water.  Por   Inotoneo.  th.
Ce.pb.ll St. Highland Lake Drive. Lincoln  9d.  .action  ha.  19 ho...
of  which  • oee mrfaee water  ..11. .OB.  no deeper   than  13 feet.
 (.00  hand  dram .ap  enol.).  But. aurfaoo .olio  or. not  tho only
.oil. to bo  concerned with aa an Individual  eunfc  an  .rtl.l.n well
 at  tho Junction of Routee  IIS and la to  provide water to house.
 and bu.lnoo... being  built there and It haa   b.oc.e pollutod.  (ooo
 onolo.od hand  drawn BBP).

 Th. placing of •  landfill  at tho  Hilpolo Cedar Jonotlon  point 1.
 far too dangerou.  to  even bo eon.tdered. It  .uat b. provontodl

 Toor. truly.
H199 aWlli «—	 -•
U.S. BPA. Red ion I
•QB-1B00C
IPX Federal Building
Beaton HA  «2Zfl3

     HI.. Rodney:

    ,„ accord	Ith th. IPA „ r^u.-t for oo.^nt. I  off-r tn.
                                                            The ,:o.tln,tlon of  th, BPA 'to-J;-  -Jloh         .
                                                        , ha.   All L».,dr 111. ft 'cSS 33*7r* lloU« Pr.vnt.llon Ch.ptor
                                                        l.or.l^r.. «.-t.  and.  U.S. Cod. 33 • ^|J"J» ^^  Bnd oporat»d  In
                                                        •••6 cl-«rly »hn.  that should .   »«""'  ,."_  operation »• can."  «n
                                                        «.l,...lr  al th.  Cedar J»"?"«"  .^.hoi. ?h.! "I.olng .  landfill

                                                                                                   s
 »l.   w           th.
Zhow. no new.  d.al-n. no n.«
landfill. curr.ctly  In •P".'
        rreforo. tt. p«rfor
          e of
                                   ,. .„. „»
                                   of r.r. no
                                                                                                        1.  «n» bwtt.r than
                                                                                                        *T.  nit  .. good a.
                                                                                                        evoBont to th« poor
                                                                                                        •'          any thing
                                                                                            ...1
                                                                                                         b, o.r Con.ro..
  foil.
                                                                                                                   saa
                                                         I he Fwleral KHA.  Thank yon.

                                                         Your, truly.
 Larry Baaalgnanl
 P.O.BOB 69
 Norfolk. HA

 eo: lathleen Haiti  Ann  Rodney; Owen Rut.i Donne
 enol: P.L 9B-B1B. IPA Leaehate Coll.etlon • Oaa Info, a.pe

 CAC3 doo 3. 21 9 22
                                                         Anthnny L.
                                                         P.O.Hoi i«3
                                                         Norfolk.  HA
                                                                                 one I:
                                                                 Lovy
                                                                                               ,,V,M.,,f,T,PS:H,  Tl ..... t.ol., 6-1. 1-tt.r

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                                     REF-1

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                            REFERENCES (Continued)
MWRA, ISPD, VII, 1989.  Residuals Management Facilities Plan.  Interim Sludge
     Processing and Disposal Project.  Vol. VII:  Sludge Characterization
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MWRA, RMFP, Air Derivation, 1989.  Residuals Management Facilities Plan Air
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MWRA, RMFP, DEIR, 1, 1989.  Residuals Management Facilities Plan, Draft
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MWRA, RMFP, FEIR, 2, 1989.  Residuals Management Facilities Plan, Final
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MWRA, RMFP, FEIR, 3A,  1989.  Residuals Management Facilities Plan, Final
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MWRA, RMFP, Landfill,  I,  1988.  Residuals Management Facilities Plan, Draft
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MWRA, RMFP, Landfill,  II,  1988.   Residuals Management Facilities  Plan, Draft
     Report on Minor Residuals Landfilling.  Vol. II:  Final Analysis of
     Landfill Options.  Massachusetts Water  Resources Authority,  Charlestown,
     Mass.
                                     REF-2

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                             REFERENCES (Continued)
 MWRA, RMFP, Options, I, 1988.  Residuals Management Facilities Plan, Draft
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 MWRA, RMFP, Screen,  I-III,  1988.   Residuals  Management Facilities Plan,  Draft
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                                    REF-3

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                            REFERENCES (Continued)
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                                     REF-4

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